20171559 Ver 3_More Info Requested_20211216

Homewood, Sue
From: Homewood, Sue
Sent: Thursday, December 16, 2021 3:54 PM
To: 'Miller, Vickie M. (Raleigh)'; Wojoski, Paul A; Mcdaniel, Chonticha
Cc: Wendee Smith
Subject: RE: [External] GRMS Follow-up - Baseline Water Sampling and Stormwater
Hi Vickie,
The Division has reviewed your responses to items 26-31 of the November 5, 2021 Request for Additional Info that were
submitted on 11/10/21 and your responses to items 9-23 submitted on 11/16/21. The Division is providing partial
feedback on these items.
The Division is unable to complete a full review of all of your responses because of some of your responses are
dependent upon a complete review of other items related to the proposed site development and avoidance and
minimization for which we have not received a response.
The Division provides the following items/comments:
• The US Fish and Wildlife Service has requested that the GRMF utilize innovative stormwater designs and other
BMP's to reduce impacts to downstream waters and habitat during all phases of the project and to maintain
buffers on all remaining streams. Please address this request.
• The reconfiguration of Wet Pond B2 appears to partially resolve the Division's concerns regarding potential
indirect impacts to Stream S1. Please provide a plan sheet that shows the location of the edge of fill impact and
the location of the proposed outlet of Wet Pond B2 at a sufficient scale to clearly determine the length of
stream channel S1 between the two points so that we may further evaluation the potential impacts on this
channel.
• Studies and modeling conducted by the Division indicate that watershed size cannot be used as a predictor of
the presence or absence of a stream, therefore the assumption that a certain watershed size will continue to
provide hydrology to these streams does not satisfy the Division's concerns. You have indicated that underdrain
systems will be installed "in the existing stream channel and will remain in place and provide additional
hydrology to streams S17 and S18", however streams 17 and 18 begin below the footprint of the construction
pad, therefore the Division is not confident that providing underdrains in these locations will be sufficient to
support existing uses in downstream waters. The Division continues to have concerns that since many piedmont
headwater streams are fed by interflow and shallow groundwater as a result of infiltration from surface flow
and since a significant portion of these watersheds will be redirected away from these features there is likely to
be indirect impacts from reduced hydrology in these channels. Please provide a detailed hydrology analysis
and/or model to document the downstream waters will be maintained or provide a monitoring plan that
establishes baseline conditions and a specific monitoring protocol to document hydrology in these channels and
adjacent wetlands for a minimum of 3 years post construction.
• It appears that Wet Pond C2 has been reconfigured so that it impacts a pond that as shown as Isolated on the
jurisdictional map previously provided to the Division. As indicated in Item 24 of the November 5th Request for
Additional Information, please provide confirmation of all Isolated features from the USACE and provide total
impacts to all isolated features evaluated pursuant to 15A NCAC 2H .1300
• Pond IDs are confusingly referenced throughout the document due to the change in the design, however, the
document should be revised for its accuracy and consistency. Some examples of these discrepancies are:
- Wet pond A is referred to as pond Al but sometimes as pond A3 in the narratives, calculations, and forms.
- Drainage area of wet pond A is 278.5 acres under the narrative but 224.6 acres in the calculations.
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- Supplemental EZ form's cover page still lists 4 dry ponds for the project.
- Supplemental EZ form still has the now -removed dry ponds Al and A2.
- Supplemental EZ form, drainage areas 6 and 7 are incorrectly identified for ponds Al and A2 where they
should be for dry pond Cl and wet pond C2.
- Dry pond sheet, under item #4, it was indicated that the ponds are not located away from contaminated
soils.
- Dry ponds exhibit on page 70 of the document shows dry ponds being identified as B2 and C2 where they
should be ponds B1 and Cl.
• Scour hole calculations for wet pond C2 still used Q10 (364 cfs) from the previous version, the new Q10 is 388
cfs according to the updated HydroCAD.
• Wet pond C2 is moved slightly south and is now located over an existing pond. Please provide reason for the
relocation and whether the existing water feature(s) will be accounted for as new impact.
• In a previous response to the Division submitted on October 27, 2021 it was stated that "If the need to connect
to the public water supply is a result of contamination due to processes on the GRMS, then the manufacturer
will be responsible for financing the connection." The Division has expressed concerns for both surface water
contaminants and yield reduction impacts to adjacent wells Please update the Well Testing and Resolution Plan
to include a statement that the need to connect to a public water supply may also be a result of well yield
reduction due to the GRMS facility, and that in either case the manufacturer will be responsible for financing the
connection. Provide a copy of the updated plan to the Division.
• The Residential Well Testing Resolution Plan dated 11/02/2021 indicates that wells proposed for testing are
those within 150 feet of the GRMS property line. You indicate that in most cases this will be well beyond the
500 feet requested based on the location of the 1000-acre construction pad. However, the application indicates
additional construction activities outside of the "construction pad" limits which include utilities, roadways and
stormwater control measures. The Division reiterates that the Well Testing Plan should address a 500-foot
distance from the site limits/property lines.
• The Division specifically requested documentation of assurance from Randolph County of the commitments
identified in the Residential Well Testing Resolution Plan.
In addition, the Division has the same questions/concerns as have been itemized in an email to you from the USACE
dated December 8, 2021. Please provide the Division with a copy of your responses in order to assist with our continued
review.
Any changes to the plans and/or responses provided to the Division as a result of final design will require the Division to
conduct another review to ensure the measures provided at this time to resolve concerns remain part of the final
design.
Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
[e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
Errs cofiesiconrierce to and fr= this address is su4iecl to the
Nark Carana Pubic Rem t.eW and mey be crisciosed to thict pales_
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From: Miller, Vickie M. (Raleigh) <[e-mail]>
Sent: Monday, December 13, 2021 11:53 PM
To: Homewood, Sue <[e-mail]>; Wojoski, Paul A <[e-mail]>; Mcdaniel, Chonticha
<[e-mail]>
Cc: Wendee Smith <[e-mail]>
Subject: RE: [External] GRMS Follow-up - Baseline Water Sampling and Stormwater
TCAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Hi Sue, Chonticha, and Paul,
I thought I would check in again to see if you had a chance to review the information that has been provided so far. I
know the County is anxious to get the well monitoring started to fulfill their commitment. Also, we are still waiting on
the end user to provide a few more items for us to complete the remaining responses.
We appreciate any comments you can provide on the items that have been submitted or if the responses were
acceptable.
Thank you,
Vickie
From: Homewood, Sue <[e-mail]>
Sent: Tuesday, November 30, 2021 8:35 AM
To: Miller, Vickie M. (Raleigh) <[e-mail]>; Wojoski, Paul A <[e-mail]>; Mcdaniel,
Chonticha <[e-mail]>
Cc: Wendee Smith <[e-mail]>
Subject: RE: [External] GRMS Follow-up - Baseline Water Sampling and Stormwater
CAUTION: [EXTERNAL] This email originated from outside of the organization. Do not click links or open attachments
unless you recognize the sender and know the content is safe.
Hi Vickie,
Due to the holiday we have not been able to meet internally to discuss our reviews. One of us will be in touch as soon as
we can.
Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
[e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
ErIkt4 COTOSp0frialCO to and from this address is St ct to too
North Cartiry Public Aoca& Law and may be d'sciosed to des.
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From: Miller, Vickie M. (Raleigh) <[e-mail]>
Sent: Monday, November 29, 2021 6:35 PM
To: Homewood, Sue <[e-mail]>; Wojoski, Paul A <[e-mail]>; Mcdaniel, Chonticha
<[e-mail]>
Cc: Wendee Smith <[e-mail]>
Subject: [External] GRMS Follow-up - Baseline Water Sampling and Stormwater
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Hi Sue, Chonticha, and Paul,
I hope you all had a nice break for the holiday!
I wanted to share a quick update and check in with you all on the well sampling and stormwater reviews. On our end we
are still waiting on the end user to supply information for a few of the comment responses and hope to have those
soon.
Are there any additional comments on the baseline water sampling plan that was provided on 11/10? It is important
that we make certain everyone is good with the plan since the county wants to put the plan into operation with
sampling soon. Please let us know if there are any additional comments or if we need to have a discussion related to the
plan.
Also, I wanted to check on the stormwater plan review. We submitted that on 11/16. At this point I thought I would see
if there are any initial comments on the plan.
Thanks,
Vickie
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