20131200 Ver 2_Emails_20141113

Strickland, Bev
From: Lucas, Annette
Sent: Thursday, November 13, 2014 11:18 AM
To: Lucas, Annette; David Odom; Kelly Hefner
Cc: Fox, Tim; Chris Waters; Devane, Boyd; Pickle, Ken; William Hunt (bill_hunt @ncsu.edu);
Andrew Anderson (arander5 @ncsu.edu); Strickland, Bev; Pickle, Ken; Burdette, Jennifer
Subject: RE: 13- 1200v2 Tryon Horse Complex
Attachments: Tryon Equestrian Center.pdf
I have reviewed the stormwater submittal received in this office on October 27, 2014. Some of the items tha
requested in the October 1, 2014 email below were included but some were missing. The attached letter will be sent
From: Lucas, Annette
Sent: Monday, October 20, 2014 12:59 PM
To: 'David Odom'; 'Kelly Hefner'
Cc: Fox, Tim; 'Chris Waters'; Devane, Boyd; Cranford, Chuck; Pickle, Ken; 'William Hunt (bill hunt @ncsu.edu)'; 'Andrew
Anderson (arander5 @ncsu.edu)'; Strickland, Bev; Pickle, Ken
Subject: RE: 13- 1200v2 Tryon Horse Complex
I am expecting to see a Stormwater Management Plan for the Tryon Horse Complex at some point this week. It is
important that we move forward with this project in light of the 401 Certification and the August 4 2014 NOV, which can
be viewed at: http: / /its.enr. state. nc. us /WebIink8 /0 /doc /249547 /Page1.aspx.
the Cherry Gardens installations as they pertain to the PEP program, then please provide a cover letter and hard copies
of anything you would like me to review. I cannot review the information you have conveyed to me on a flash drive.
Please let me know as soon as possible if there is a problem with submitting the stormwater plan this week or if you
have questions.
From: Lucas, Annette
Sent: Wednesday, October 01, 2014 12:59 PM

To: 'David Odom'; Clemment Riddle
Cc: Kelly Hefner; Chris Waters; Devane, Boyd; Cranford, Chuck; Pickle, Ken; William Hunt (bill huntCa)ncsu.edu); Andrew
Anderson (arander5Cd)ncsu.edu); Strickland, Bev
Subject: RE: 13- 1200v2 Tryon Horse Complex
From: David Odom [ mai Ito: davidodom (a)odomenaineerina.com]
Sent: Wednesday, October 01, 2014 12:58 PM
To: Lucas, Annette; Clemment Riddle
Cc: Kelly Hefner; Chris Waters; Devane, Boyd; Cranford, Chuck; Pickle, Ken; William Hunt (bill huntCa)ncsu.edu); Andrew
Anderson (arander5Cd)ncsu.edu); Strickland, Bev
Subject: Re: 13- 1200v2 Tryon Horse Complex
Annette
I would like to see if we could do the call Tuesday at 9 am rather than 10 am if that works for you. See below
for some additional information regrading your comments.
GENERAL OVERVIEW:
• A reminder to everyone that this stormwater plan is to fulfill the requirements of a 401 Certification issued for
this project on February 17, 2014. This certification can be viewed
at: http: / /its.enr. state. nc.us /WebLink8 /DocView.aspx ?id= 217849. My understanding is that there is
currently a Notice of Violation for this project due to use of the facility before the implementation of a
stormwater management plan as well as deposition of sediment into the receiving stream. Perhaps Chuck
Cranford from the Asheville Regional Office can elaborate on this when he returns next week.
• You are also requesting that this project be considered as a submittal to the PEP program.
• This submittal must be sufficient to address the programmatic issues associated with the 401 Certification
program, resolution of the Notice of Violation and the requirements of the PEP.
PEP REQUIREMENTS:
• Please provide a design narrative that states the design objective, summarizes in words the design approach,
and concludes with the assertion that the design is compliant with the relevant rules?
• Please provide a QAPP for our review and a commitment to stay the course over 12 months of testing.
• Pleae provide an agreement to replace or tweak the Isolator Rows if they don't work to achieve 85% TSS or an
effluent concentration of 20 mg /L or less.
We will provide the additional information requested above in conjunction with ADS.
PLEASE EXPLAIN:

• Which portions of the site are already built and which areas are paved versus gravel.
• How the Notice of Violation will be resolved and the stream will be restored. It sounds like the site
has caused a significant amount of sediment to be deposited in the stream.
• Please also explain how the Isolator Row devices will be protected from sediment after their
installation, particularly the devices that will be located downslope of permanently unvegetated areas
like horse rings and trails.
• Which portions of the stormwater plan you are requesting approval for now and which areas will be
designed /built in the future (if any).
I will provide you with a drawing that indicates what is built and where construction is continuing. The NOV is in
the process of being resolved now. The drawing will indicate what we are requesting approval for now and what is
for the future. Additional information will be provided to address your other questions.
CALCULATIONS:
• Flow calculations were provided for every catch basin and pipe in the storm drainage network.
However, for every drainage area, C was estimated to be 0.5 and for many inlets, the storm intensity
was given to be 0 inch /hour. Please double- check.
• Please provide calculations for the sizing of the Isolator Row systems.
We will review this immediately.
PLANS — PLEASE SHOW:
• Drainage easements or deed restrictions for the stormwater control measures.
• How the Isolator Row systems will be accessed.
• Clear details of the Isolator Row systems, including inlet and outlet details and elevations.
• Dimensions, elevations and pipe sizes for every stormwater diversion device that will be used with
supporting calculations.
• A construction sequence.
We wall provide this shortly along with the items below,
MAINTENANCE & MONITORING
• Please provide a signed and notarized Operation & Maintenance Agreement for the stormwater
control measures.
• Please provide a monitoring plan for one of the Isolator Row systems, including the equipment,
procedures and frequencies for cleaning the devices.
• Please provide a signed and notarized agreement stating that the Isolator Row systems will be
replaced with another stormwater control measure if monitoring data show that they are not working
effectively.
On Wed, Oct 1, 2014 at 8:15 AM, Lucas, Annette <annette.lucasgncdenr.gov> wrote:
David, Chris and Kelly,

Ken Pickle and I have reviewed the submittal received in the Division of Water Resources Central Office on September 9,
2014 for the above named project. In our review, we noted the following issues.
GENERAL OVERVIEW:
A reminder to everyone that this stormwater plan is to fulfill the requirements of a 401 Certification issued for
this project on February 17, 2014. This certification can be viewed
at: http: / /its.enr. state. nc.us /WebLink8 /DocView.aspx ?id= 217849. My understanding is that there is currently a
Notice of Violation for this project due to use of the facility before the implementation of a stormwater
management plan as well as deposition of sediment into the receiving stream. Perhaps Chuck Cranford from the
Asheville Regional Office can elaborate on this when he returns next week.
You are also requesting that this project be considered as a submittal to the PEP program.
This submittal must be sufficient to address the programmatic issues associated with the 401 Certification
program, resolution of the Notice of Violation and the requirements of the PEP.
PEP REQUIREMENTS:
• Please provide a design narrative that states the design objective, summarizes in words the design approach,
and concludes with the assertion that the design is compliant with the relevant rules?
• Please provide a QAPP for our review and a commitment to stay the course over 12 months of testing.
• Pleae provide an agreement to replace or tweak the Isolator Rows if they don't work to achieve 85% TSS or an
effluent concentration of 20 mg /L or less.
PLEASE EXPLAIN:
• Which portions of the site are already built and which areas are paved versus gravel.
• How the Notice of Violation will be resolved and the stream will be restored. It sounds like the site has
caused a significant amount of sediment to be deposited in the stream.
• Please also explain how the Isolator Row devices will be protected from sediment after their installation,
particularly the devices that will be located downslope of permanently unvegetated areas like horse
rings and trails.
• Which portions of the stormwater plan you are requesting approval for now and which areas will be
designed /built in the future (if any).
CALCULATIONS:
Flow calculations were provided for every catch basin and pipe in the storm drainage network. However,
for every drainage area, C was estimated to be 0.5 and for many inlets, the storm intensity was given to
be 0 inch /hour. Please double- check.
• Please provide calculations for the sizing of the Isolator Row systems.
PLANS — PLEASE SHOW:
• Drainage easements or deed restrictions for the stormwater control measures
• How the Isolator Row systems will be accessed.

• Clear details of the Isolator Row systems, including inlet and outlet details and elevations.
• Dimensions, elevations and pipe sizes for every stormwater diversion device that will be used with
supporting calculations.
• A construction sequence.
MAINTENANCE & MONITORING
• Please provide a signed and notarized Operation & Maintenance Agreement for the stormwater control
measures.
• Please provide a monitoring plan for one of the Isolator Row systems, including the equipment,
procedures and frequencies for cleaning the devices.
• Please provide a signed and notarized agreement stating that the Isolator Row systems will be replaced
with another stormwater control measure if monitoring data show that they are not working effectively.
I suggest we schedule a conference call to discuss these items in more detail. If you are interested in that, please let me
know some dates /times in the next week or so that you will be available.
Thanks,
Annette
Environmental Engineer
I •
Phone: [phone] Fax: [phone] Email: annette.lucasgncdenr.gov
Website http: / /portal.ncdenr.org /web /lr /stormwater
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5

AG'P'A
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Energy, Mineral, and Land Resources
Land Quality Section
Tracy E. Davis, PE, CPM
Director
November 13, 2014
Mr. Jeff Brown
2659 Sandy Plains Road
Tryon, North Carolina 28782
Mr. Roger Smith, Registered Agent
Tryon Equestrian Partners, LLC
360 Ken Miller Road
Rutherfordton, North Carolina 28139
Pat McCrory, Governor
John E. Skvarla, III, Secretary
DWR Project # 13 -1200
Polk County
Subject: REQUEST FOR MORE INFORMATION
TRYON EQUESTRIAN CENTER STORMWATER MANAGEMENT PLAN
Dear Messrs. Brown and Smith:
On February 17, 2014, the Division of Water Resources (DWR) issued a 401 Water Quality
Certification to impact 0.49 acre of wetland and 150 linear feet of stream or waters in order to
construct the proposed development in Polk County. In order to meet Condition 6 of the 401
Certification for this project, a stormwater management plan was submitted to the DWR on
October 1, 2014. Because you propose to use a proprietary stormwater management system
known as the "Isolator Row," the DWR has delegated the review of the stormwater
management plan to the NC Division of Energy, Mineral and Land Resources (DEMLR), the
agency that handles reviews of these types of devices.
The first stormwater management plan submittal was received by DEMLR on October 1, 2014.
The deficiencies in that stormwater management plan were communicated to your consultant,
Mr. David Odom, PE, of Odom Engineering, PLLC, on October 20, 2014. On October 27, 2014,
DEMLR received a revised stormwater management plan. DEMLR has determined that the
revised stormwater management plan remains incomplete. Please provide the following items
so that we may approve the stormwater management plan. Pursuant to Title 15A NCAC 02H
.0502(e), the applicant shall furnish all of the requested information for the proper
consideration of the application. If all of the requested information is not received in writing
within 30 calendar days of receipt of this letter, DEMLR will be unable to authorize the use of
Isolator Row technology on this site and you may be left with no alternative except to install
conventional stormwater BMPs at every outfall.

Tryon Equestrian Partners, LLC
DWR# 13 -1200
Request for Additional Information
Page 2 of 3
Additional Information Requested:
1. Please provide a QAPP (Quality Assurance Project Plan) for our review and a commitment
to stay the course over 12 months of testing. We cannot move forward with approval
without these items. (Already requested via 10/20/14 email.)
2. Please provide an agreement to replace or tweak the Isolator Rows if they don't work to
achieve 85 %TSS or an effluent concentration of 20 mg /L or less. (Already requested via
10/20/14 email.)
3. Please show which portions of the site are are paved versus gravel, (NOTE: The site plans
only indicate impervious surfaces, but do not state whether or not they are pavement or
gravel.) . (Already requested via 10/20/14 email.)
4. Please explain how the Isolator Row devices will be protected from sediment after their
installation, particularly the devices that will be located downslope of permanently
unvegetated areas like horse rings and trails. We are concerned about the long term
function of devices located down gradient from permanently disturbed areas. (Already
requested via 10/20/14 email.)
5. Flow calculations were provided for every catch basin and pipe in the storm drainage
network. However, for every drainage area, C was estimated to be 0.5 and for many
inlets, the storm intensity was given to be 0 inch /hour. Please double - check. We remain
concerned about the validity of several of the calculations reported. It may be that there
are reasonable explanations that just are not apparent to us. Please clarify for
us. (Already requested via 10/20/14 email.)
6. Please provide clear details of the Isolator Row systems, including inlet and outlet details
and elevations on the plans. (NOTE: Each Isolator Row System should be shown in profile
and in cross - section with clearly labeled dimensions and elevations.) The elevations on
the details of the diverter boxes and detention control boxes do not appear to match the
details below. Please clearly label which details correspond to which devices in plan
view. Also, please check the elevations for accuracy. (Already requested via 10/20/14
email.)
7. Please provide a construction sequence on the plans. Our primary concern is for
protection of the final unit from construction sediment overload and for evidence that the
contractor's scope of work includes cleaning out (or protecting) the units before final
acceptance of the job.

Tryon Equestrian Partners, LLC
DWR# 13 -1200
Request for Additional Information
Page 3 of 3
8. For the proposed wet detention basin, please provide a Required Items Checklist with all
required items that were omitted from the October 17, 2014 submittal, including the
soils report, drawdown calculations and stage- storage table.
9. The storage volume of the wet detention basin appears to be significantly less than the
31,008 cubic feet stated on the wet detention basin supplement form. Please check.
10. The proposed level spreader - vegetated filter strip does not meet Chapter 8 of the BMP
Manual. Please review this chapter and redesign the level spreader- vegetated filter
strip accordingly. Please provide a completed LS -VFS supplement form with all required
items for our review.
DEMLR will require the above additional information to approve the stormwater management
plan for the subject property. Please provide the following information so that we may
continue to review your project. Please also be aware that the 401 water quality certification
issued on February 17, 2014 is contingent on obtaining an approved stormwater management
plan and any work done within waters of the State prior to obtaining this approval may be in
violation of North Carolina General Statues and Administrative Code. You are welcome to
contact me at 919- 715 -3425 if you have questions or would like to set up a meeting.
Sincerely,
avlv�� fil - qV' e_)"
Annette M. Lucas, PE
Environmental Engineer
AMLI aml
cc: USACE Asheville Regulatory Field Office
Mr. David Odom, PE, Odom Engineering, PLCC (via email)
Mr. Kelly Hefner, PE, Advanced Drainage Systems, Inc. (via email)
Dr. Bill Hunt, PE, PhD, NCSU -BAE (via email)
Mr. Andrew Anderson, El, NCSU -BAE (via email)
Mr. Ken Pickle, PE, DEMLR (via email)
Mr. Boyd DeVane (via email)
401 & Buffer Permitting Unit file, DWR
ARO 401 file (via email)
Filename: 131240TryonHorseFarm(Pofk)_Hold SW.docx