20171559 Ver 3_More Info Requested_20211105

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
CONFIDENTIAL INFORMATION
NOT FOR PUBLIC DISCLOSURE
This document contains confidential business information not for s ublic disclosure
ursuant to NC General Statute 132-6.
November 5, 2021
DWR # 20171559 v3
Randolph/Guilford County
Greensboro Randolph Megasite Foundation
Attn: Mr. Jim Melvin
324 W. Wendover Ave, Suite 207
Greensboro NC 27408
Delivered via email to: [e-mail]
Subject: REQUEST FOR ADDITIONAL INFORMATION
Greensboro Randolph Megasite
Dear Mr. Melvin:
On July 28, 2021 the Division of Water Resources (Division) received your application requesting a 401
Individual Water Quality Certification from the Division for the subject project. We have received
additional information on September 27, 2021, October 20, 2021, and October 27, 2021 and have
completed our review of this information. The Division has determined that your application is
incomplete and cannot be processed.
Pursuant to 15A NCAC 02H.0506(b) "a 401 Water Quality Certification may only be issued upon
determining that the proposed activity will comply with state water quality standards which includes
designated uses, numeric criteria, narrative criteria and the state's antidegradation policy, as defined in
rules of 15A NCAC 02B .0200... In assessing whether the proposed activity will comply with water quality
standards, the Division shall evaluate if the proposed activity in accordance with Items (1) through (6).
Specifically this request is in reference to Items: (1) has avoided and minimized impacts to surface
waters and wetlands to ensure any remaining surface water or wetlands, and any surface waters or
wetlands downstream, continue to support existing uses during and after project completion; (2) would
cause or contribute to a violation of water quality standards; and (3) would result in secondary or
cumulative impacts that cause or contribute to, or will cause or contribute to, a violation of water
quality standards;" We currently do not have the necessary information to evaluate the project
GA1E
NORTH CAROUNA
Department of Environmental Quality
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11650 Mail Service Center I Raleigh, North Carolina 27699-1650
919.707.9000

CONFIDENTIAL INFORMATION
Greensboro Randolph Megasite Foundation
DWR# 20171559 v3
Request for Additional Information
Page 2 of 9
according to the rules outlined above. This information has been previously communicated and
transmitted to S2 Consulting and HDR. The application is on -hold until all of the following information
is received:
Site Plan
In our September 2, 2021 letter, the Division requested additional information that supports the specific
design and layout of the project necessary for an evaluation and assessment of avoidance and
minimization pursuant to 15A NCAC 02H .0506(b). To date, we do not have sufficient detailed
information that supports the specific layout and resource impacts necessary and are unable to
determine the project meets the rule requirements of 15A NCAC 02H .0506(b).
1. We have requested a supporting narrative that expands upon the broad outline and process
flow description recently provided in order to further document Avoidance and Minimization for
proposed manufacturing facility. The response received on October 20 uses broad speculative
language such as "has the capability to manufacture" and "potential use". Please provide an
updated process narrative that is more specific as to what is occurring on the site.
2. Based on the response received October 27, please explain this statement: 11111
hat
shared resources are providing avoidance? What shared resources result in minimization?
3. The parking area is based on "planned employee capacity." What is the planned employee
capacity? How many parking spaces/area is needed to meet this capacity?
4. It's stated that the rail yard/warehouse area is based on the raw material storage and product
storage. What are the storage area needs as related to the specific materials and products being
stored?
5. Please explain this statement that was included in the October 27 information submittal: "It is
not possible to have different pads on the site due to the manufacturing process and logistics
through the site." What specifically about the manufacturing process and logistics requires a
contagious pad?
6. In the October 27 information submittal you stated: "there may be potential to take these
elements off the pad and potentially reduce the impact to the channel at this location" in regards
to a proposed solar farm and wastewater pre-treatment facility. Your response indicates that
the removal of these items may be feasible and result in impact avoidance. Please clarify if these
components are being removed from the pad and update exhibits and impact maps accordingly.
If the components are not being removed from the pad please explain why.
7. Please explain the statement in your October 27th response: "Parking decks would inhibit
movement through the site as required by the end user". What specifically about a parking deck
will inhibit movement and contradict the end users requirements?
£ D_E
NORTH GAROUW
Department or environmental Quality
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11650 Mail Service Center I Raleigh, North Carolina 27699-1650
919.707.9000

CONFIDENTIAL INFORMATION
Greensboro Randolph Megasite Foundation
DWR# 20171559 v3
Request for Additional Information
Page 3 of 9
8. Based on your statement, "Parking decks are cost prohibitive," please provide justification or
cost analysis that eliminates a parking deck option due to cost. The component cost as a
percentage of overall project cost is a common metric used to determine cost prohibition.
Stormwater Management Plan - Overall
9. Based on your October 27th response, explain what is meant by "The SCMs located internal to
the pad use areas that cannot be avoided but can be for temporary storage of Stormwater." If
the stormwater SCMs were located off the pad, what specifically makes the pad impact
necessary?
10. In the justification for dry attenuation basins provided on October 27, it was stated that dry
ponds were selected "to take advantage of the available site area internal to the pad." Why is
there available site area in the pad if it has been minimized to the maximum extent and why
does removing dry attenuation basins from the pad "not significantly reduce the size of the
pad"?
11. Based on the information provided in the most recent site plan and conceptual stormwater
management plan, all surface flow from the project is proposed to be rerouted through three
wet detention basins. The outlets from the wet basins are proposed to be located as indicated
on the conceptual stormwater management plan. The rerouting of the drainage area and
surface flow from the "site" through the three stormwater basins has the potential to remove
existing hydrology within multiple waters of the state and therefore remove existing uses within
the stream channels and wetlands. Specifically, the Division notes that according to the
information available on the most recent site plan and stormwater management plan and the
stream identifiers as noted on the jurisdictional determination map submitted on October 15,
2021:
• The entire watershed draining to stream S45 will be redirected to Wet Pond A3. The
outlet of Wet Pond A3 discharges to stream SN. The portion of stream S45 below the
impact limits to the confluence of SE (as shown on the maps below) will experience
significant indirect impacts from the loss of hydrology to the channel.
• The entire watershed draining to stream S1 and HDR WA will be redirected to Wet Pond
B2. The outlet of Wet Pond B2 discharges to a downstream location on Dodsons Lake.
The portion of stream S1 and wetland HDR WA (as shown on the maps below) will
experience significant indirect impacts from the loss of hydrology to the channel and
wetland.
• The majority of the watersheds of stream S18, Stream S17, wetlands WW, W15, W17,
W18B and W16 (shown on the maps below) will be redirected to either Wet Pond B2 or
Wet Pond C2. The outlets of Wet Ponds B2 and C2 are located within different drainage
areas. These streams and wetlands will experience significant indirect impacts from the
loss of hydrology to the area.
£ D_E
NORTH GAROUW
Department or environmental Quality
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11650 Mail Service Center I Raleigh, North Carolina 27699-1650
919.707.9000

CONFIDENTIAL INFORMATION
Greensboro Randolph Megasite Foundation
DWR# 20171559 v3
Request for Additional Information
Page 4 of 9
Provide one of the following for all locations noted:
i. Updated impact tables, impact maps and mitigation amounts to account for indirect
impacts.
ii. Provide detailed engineering evaluations providing clear documentation/calculations
indicating that existing uses will be retained in streams and/or wetlands noted above.
iii. Provide a specific monitoring plan, including a baseline monitoring plan and post
construction plan for a minimum of 3 years, that will document post construction
conditions of the streams and/or wetlands noted above. The monitoring plan shall
include clear and measurable parameters which will provide evidence of whether the
features support existing uses equivalent to pre -construction existing uses and a
detailed resolution plan should monitoring indicate a loss of function of any stream
and/or wetland.
DE
NORTH CAROLJNA
Department of Environmental Ueali�
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11650 Mail Service Center I Raleigh, North Carolina 27699-1650
919.707.9000

CONFIDENTIAL INFORMATION
Greensboro Randolph Megasite Foundation
DWR# 20171559 v3
Request for Additional Information
Page 5of9
12. You have provided a stormwater management plan that indicates that the proposed Wet Pond
A3 will be constructed within a natural drainage way where Pond P17 currently exists and Pond
P16 and W3 are upslope of this area. The Division has the following concerns regarding this
design:
A detailed analysis must be provided to document that impacts to jurisdictional features has
been avoided and minimized throughout the project, including impacts beyond the footprint of
the "site". This should include a detailed analysis of any possible upland locations for
stormwater treatment and any possible alternative stormwater treatment control measures
which would avoid impacts to jurisdictional features. Possible alternatives may be multiple wet
ponds on either side of the jurisdictional feature or alternative stormwater control measures
that provide smaller land requirements such as bioretention basins or sand filters.
If sufficient justification and documentation is provided to support the proposed location of Wet
Pond A3, the Division has concerns regarding directing existing hydrology and/or flow through a
stormwater control measure. Provide for further details about how existing hydrology will be
rerouted so that it does not impact the long term function of Wet Pond A3.
DE
NORTH CAROIJNA �/
Department or Environmental Duali
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11650 Mail Service Center I Raleigh, North Carolina 27699-1650
919.707.9000

CONFIDENTIAL INFORMATION
Greensboro Randolph Megasite Foundation
DWR# 20171559 v3
Request for Additional Information
Page 6 of 9
Stormwater Management Plan —Technical
13. The offsite drainage in area C will be bypassed, how much volume will be bypassed? Where will
this bypass be discharged? Note that if this bypass is going to be discharged into one of the
three proposed outfalls, it should also be accounted for in the design and flow calculations.
14. Dry ponds Al and A2 are being proposed at possibly 4-29 feet below the existing groundwater
elevation. In addition, the plan states that "the groundwater will be diverted around the pads
and it is anticipated the future groundwater will be below the dry ponds". This raises concern
over how the groundwater lowering and control at the site will be accomplished since this is a
very complex and difficult task with no actual plan being provided. In addition, the amount of
groundwater that needs to be diverted and the destination of groundwater discharge are
unknown. This groundwater issue can significantly impact the stormwater wet pond capacity,
discharging outfalls, and water quality standards (for both groundwater and surface waters).
15. The plan states that "the peak discharge for all three outfalls were reduced compared to the
existing conditions". However, at outfall A, it appears that the proposed 10-yr peak discharge is
higher than the pre/existing 10-yr peak discharge (373 cfs vs 345 cfs). See tables 3 and 5 of the
SMP report. Please review these numbers/calculations and explain.
16. There are several undisturbed areas being identified on the plan with no impervious surfaces
being proposed. If these lands are to be developed in the future, will a separate stormwater
control measure be provided? Note that the currently proposed wet ponds and discharges at
outfalls did not account for future uses of these areas.
17. On the site plan, there is an unknown basin marked as "not use" (at the NE corner of the site),
please clarify.
18. In the design calculations for wet ponds, the numbers for pond bottom elevation and sediment
storage elevation switched places, please check and revise as needed.
19. On the wet pond C2 drawing, the sediment storage elevation should be at 644 (not 643), please
check and revise as needed.
20. Scour hole calculations for pond B and pond C are incomplete for the flow calculation table at
the lower bottom of each page.
21. Please explain why the forebay design of ponds B2 and C2 are greater than 20% of its pool
volume. Please note that the stormwater Minimum Design Criteria specifies the designed range
to be exactly between 15%-20%.
22. Please note that the proposed 100-yr peak discharge numbers provided in Table 5 do not match
the numbers presented on the HydroCAD Model. Please review and revise as needed.
23. Provide an overall plan sheet with proposed grading/topography that shows the entire property,
all streams, wetlands and open waters and all SCMs and drainage network.
£D_E
NORTH CAROIJNA
Department of Environmental Duality
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11650 Mail Service Center I Raleigh, North Carolina 27699-1650
919.707.9000

CONFIDENTIAL INFORMATION
Greensboro Randolph Megasite Foundation
DWR# 20171559 v3
Request for Additional Information
Page 7 of 9
Resource Delineation/Impact Maps
24. As communicated previously, the Division will need confirmation from USACE for all isolated
features in order to confirm they are subject to 15A NCAC 02H .1300. Please provide total
impacts to all non -jurisdictional features evaluated under 15A NCAC 02H .1300 to determine any
permitting requirements in accordance with 02H .1301. In the information provided, you have
shown one wetland "WD" at 0.018 acre as a non -jurisdictional feature and an isolated surface
water pond "PB". Please update your October 27th response to include this feature.
Dodson's Lake
HDR WD {Non -jurisdictional)
25. In the October 27th information submittal you stated "The original avoidance and minimization
underestimated the impacts of the two options that impacted Dodson's Lake". You also stated
"Similar to other projects which impact a lake, the entire lake is taken." Please explain why the
entire lake must be lost if partially impacted. DWR is not aware of any "similar projects" that
result in a total loss of a lake or pond aside from projects that intentionally impact dams. Please
update the avoidance and minimization analysis as needed.
Residential Well Sampling and Complaint Resolution Plan
26. Please provide a timeline for pre -construction well testing and confirm it can be done and
adequately reviewed prior to start of any land disturbing activities on the site.
DE
NORTH CAROLJNA �/
Department of Environmental Duali
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11650 Mail Service Center I Raleigh, North Carolina 27699-1650
919.707.9000

CONFIDENTIAL INFORMATION
Greensboro Randolph Megasite Foundation
DWR# 20171559 v3
Request for Additional Information
Page 8 of 9
27. Wells in this area are typically completed in the fractured rock aquifer. There is a high degree of
variability in fracture density and orientation in this aquifer. A 150-foot radius from the site is
insufficient to identify private and public water supply wells for potential impacts, especially
given the proposed de -watering scheme. A 500-foot radius is more consistent with established
regulatory setbacks for pollution sources and dewatering impacts. Please revise the residential
well sampling plan accordingly.
28. The residential well sampling plan states that a third party, Randolph County, will perform the
well sampling and well yield testing. This represents a significant resource commitment by the
County and DEQwould like to have assurances that the County accepts this responsibility and
has the financial and technical resources to carry out the specified well sampling and yield
testing. Provide documentation of assurance from the County of the commitments identified in
the plan.
29. Since the proposed well yield testing constitutes a hydrogeologic assessment, it will need to be
performed under the supervision of a NC licensed geologist or engineer. Please revise the plan
to indicate this requirement
30. The proposed groundwater quality testing parameters includes VOCs, SVOCs, and pesticides.
These tests are very sensitive to contamination during collection, transportation, and lab
analyses, and may not provide an accurate measure of possible impacts from the proposed
project on groundwater quality. In addition, these samples should be collected by personnel
specifically trained in sampling for VOCs, SVOCs, and pesticides. Please revise the groundwater
quality testing parameters to also include bacteria, metals, turbidity, and total dissolved solids
by EPA -approved drinking water testing methods, and that these analyses must be performed
by laboratories that are currently certified for these testing methods by NC DWR.
31. The proposed dewatering activities are significant, and little information has been provided on
the location, process, and duration of this activity. Construction dewatering is a deemed
permitted activity, but it must be conducted in a manner that does not result in water quality
violations. Provide additional detail on the location and groundwater extraction system
elements so that the Division may evaluate this proposed activity. It is highly unlikely that the
significant proposed lowering of the water table could be maintained after construction without
active pumping or the installation of horizontal and vertical hydraulic barriers. Please provide
further details on how this is to be accomplished.
Other Items
32. Please indicate whether the potential manufacturer intends to operate the entire facility as
shown on the proposed site plans at one time or plans to phase in operations.
33. If the US Army Corps of Engineers determines that the current project warrants an updated
public notice, the Division will not able to finalize it's review until the public comment period has
£ D_E
NORTH GAROUW
Department or environmental Quality
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11650 Mail Service Center I Raleigh, North Carolina 27699-1650
919.707.9000

CONFIDENTIAL INFORMATION
Greensboro Randolph Megasite Foundation
DWR# 20171559 v3
Request for Additional Information
Page 9of9
concluded and all comments have been evaluated. Additional information may be required
upon review of any public comments received.
34. Note that the project includes NCDOT transportation infrastructure improvements. The
application includes conceptual plans for the proposed improvements. Please provide a very
detailed description of the overall project dependency on the transportation infrastructure
improvements and the proposed schedules for construction activities of the various portions of
the proposed project.
35. You have indicated that you are unable to provide final stormwater management plans at this
time. The Division will require review of final stormwater plans before the project can begin
construction.
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.deq.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
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 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 Sue Homewood at 336-776-9693 or [e-mail] if you have any
questions or concerns.
cc via email:
Sincerely,
42Daniel Smith, Director
Wendee Smith, S2 Consulting
Vickie Miller, HDR
Jean Gibby, USACE Raleigh Regulatory Field Office
Olivia Munzer, NCWRC
DWR 401 & Buffer Permitting Branch file
DE
NORTH CAROLJNA �/
Department of Environmental Duali
Filename: 20171559v3GreensboroRandolpMegasite(Randolph)_Addinfo.docx
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11650 Mail Service Center I Raleigh, North Carolina 27699-1650
919.707.9000