HomeMy WebLinkAboutSW3221201_Response To Comments_20221206ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
BRIAN WRENN
Director
NGM Real Estate, LLC
Attn: Heather Meyers
5922 Weddington Road
Wesley Chapel, NC 28104
Subject: PROJECT RETURN
NORTH CAROLINA
Environmental Quality
March 24, 2022
Stormwater Management Project No. SW3210502
Carolina Pets Animal Hospital
Union County
Dear Mrs. Meyers:
The Division of Energy, Mineral and Land Resources received and accepted a State Stormwater
Management Permit Application for the subject project on May 17, 2021 and requested
additional information on June 16, 2021 and October 19, 2021. A review of the file and delivery
logs indicates that, as of this date, the information requested on October 19, 2021 has not been
received in this Office within the stipulated timeframe. A submission was provided on January
25, 2022 in response to the information requested on October 19, 2021, but the submission did
not sufficiently provide the requested information. Please refer to Attachment A for a list of
unaddressed comments from the October 19, 2021 Request for Additional Information Letter.
Per the requirements of Title 15A NCAC 02H .1042(3)(a)(ii) of the Stormwater Management
Rules, this Office is hereby returning the subject application as incomplete. The $505.00
application fee has been forfeited and a new fee will need to be provided if you choose to
resubmit this application in the future.
If you wish to pursue construction of this proposed project, you must reapply for a permit to the
Division. Your application package must include a completed and signed application form;
supplement form; signed O&M agreement; application fee; signed, sealed and dated calculations;
and 2 sets of signed, sealed and dated site layout and grading plans with details.
Please be aware that the construction of any impervious surfaces on the property prior to receipt
of a stormwater permit, other than a construction entrance under an approved Sedimentation
Erosion Control Plan, is a violation of NCGS 143-215.1 and is subject to enforcement action
pursuant to NCGS 143-215.6A.
If you have any questions concerning this matter, please contact Jim Farkas at (919) 707-3646 or
via e-mail at Jim.Farkas@ncdenr.gov.
North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center I Raleigh, North Carolina 27699-1612
NORTH CAROHNA
oeperhnent of Environmental gml\ r 919.707.9200
Sincerely,
Pin qwd "wd 4 A1,ww 57a r4"
Brian Wrenn, Director
Division of Energy, Mineral and Land Resources
Enclosures: Attachment A — List of unaddressed issues from the 10/19/2021 Request for Additional Information Letter
cc: Brian Smith, PE — Urban Design Partners
Attachment A
List of Unaddressed Comments
From October 19, 2021 Request for Additional Information Letter
This is a list of the comments that were not addressed from the October 19, 2021 Request for Applicatic
Additional Information Letter. Once the permit is reapplied for, it will be subject to re -review to reflect
and additional comments may be generated. Xtalcs
1. Original Comments 3a-3e — "'Please correct the following issues with the table iV
Section IV, 10 of the Application:' Please provide a revised copy of the Application with
these corrections made. " The sum of the On -Site Drainage Area (66,211 sf) and Off -Site
Drainage Area (0 sf) do not add up to the Total Drainage Area (66,281 sf). There is also
StagE
1,159 sf more "future" BUA shown in Section IV, 10 of the Application than is shown in
now ii
the calculations, and plans.
calcul
foreb;
2. Original Comment 12h — "'Sand Filter MDC 2 — Please provide stage -storage tables
charn
hydro
for each chamber of the sand filter so that their respective volumes can be compared.'
The requested stage -storage tables clearly showing the cross -sectional area and volume
for each chamber do not appear to have been provided. " This item was not provided. Af
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3. Original Comment 13d — 'SHWT...'— The provided soils report indicates that the S f
SHWT was not encountered at or above elevation 618.7 (618.7 = 634.0 —15.3) however up
plan sheet C-5.1 indicates that the SHWT is at elevation 631.33 ("Outlet Structure: Sand su
Filter" detail). Please revise as needed for correctness and consistency. " The provided
plans and Supplement-EZ Form still indicate that the SHWT is at elevation 631.33 ft
which results in an insufficient vertical separation between the SHWT and lowest
excavated point of the sand filter (Sand Filter MDC 1).
For
4. Original Comment 14a — " `PDFs must be uploaded using the form at:
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https://edocs.deg.nc.gov/Forms/SW-Supplemental-Upload' Per 15A NCAC 02H.1042(2),
you are required to provide an electronic copy of all required Application submittal
materials (including revised documents). Please use the link to upload an electronic copy
of the documents submitted as part of the September 16, 2021 submission and please
ensure that all items that are included in the next resubmission are uploaded to this link. "
O&M ag
Electronic files from the 9/16/21 submission were not provided.
been up
level spr
5. Prior Comment 16 — "Please clarify the purpose/function of the proposed level //
included
spreader filter strip as it does not appear to be treating any on -site BUA. If the level
spreader filter strip is not being used for treatment, it is not required to be included in the
supplemental forms. " The level spreader is still included on the O&M Agreement Form.
If you would like to include the level spreader/filter strip as a non -enforceable SCM on
the O&M Agreement Form (so that it gets maintained) you should indicate that it is a
non -enforceable SCM on the O&M Agreement Form.
L
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6. Prior Comment 17.a.i — "Line 7 — This item refers to the width of the vegetated setback
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from surface waters as described in 15A NCAC 02H .1003(4) & .1017(10) " The
provided value, 22 ft, is less than the required 30 ft per 15A NCAC 02H .1017(10).
7. Prior Comment 17.b.i.2 — "Line 8 — This item is equal to the total amount of BUA that
will be added to this project, whether it drains to the SCM or not. It is the sum of Lines 1
and 11. " There is new BUA associated with this project (sidewalk along the roadway,
driveway, etc...) that is part of the project, but does not drain to the SCM. This BUA
should be included in this column, but not in the DA 1 column (since it does not drain to
the SCM). The Line 8 value in the entire site column is equal to the Line 8 value in the
DA 1 column, but they should not be equal. Also, the sum of Lines 10 and 11 does not
equal Line 8 (49,526 sf vs 50,685 sf).
8. Prior Comment 17.b.i.3 — "Line 10 — This item is equal to the total amount of BUA that
will be added within the project area, whether it drains to the SCM or not. It does not
include BUA that is added outside of the project area. This item is the sum of the items of
Line 12. " Similar to the earlier comment, there is new BUA associated with this project
that is part of the project, but does not drain to the SCM and should be included in this
column (but not in the DA 1 column).
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and
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9. Prior Comment 17.b.i.4 — "Line 11 — This item is equal to the total amount of BUA that
will be added outside of the project area, whether it drains to the SCM or not. For this
project, the off -site BUA will be equal to the BUA that is added to the right-of-way area. "
This comment was not addressed, see above.
Supl
10. Prior Comment 17.b.i.6 — "Line 18 — This is the percent BUA for the entire project
appl
area. It should match the information shown in Section IV, 8 of the Application. " This
reviE
item (43% does not match the value shown in Section IN, 8 of the Application (44.1%).
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11. Prior Comment 17.b.ii.1— "Lines 8 & 10 - This item is equal to the total amount of
Li
BUA that will be added to this project and drains to the SCM. Since there does not
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appear to be an off -site portion to this drainage area, Line 11 will equal zero and Lines 8
& 10 will be equal. " As previously mentioned, Line 10 does not equal Line 8 (49,526 sf
vs 50,685 sf).
LinE
12. Prior Comment 17.b.ii.3 — "Line 18 — This is the percent BUA for the drainage area to revi
the SCM. It should match the information shown in the calculations and in the table in
Section IV, 10 of the Application. " It is unclear if the BUA within the drainage area to the
SCM is 49,526 sf or 50,685 sf. This would result in a %BUA of either 75% or 77%.
13. Prior Comment 17.b.ii.6 — "NOTE: The values shown in this column do not correspond All
to the information shown in the calculations. For example, the calculations show 1.16 ac bei
_d
of BUA within the drainage area to the SCM whereas the supplement indicates only 0.86 a c
ac. Please ensure that the BUA information is correct and consistent throughout the ac(
submission. " As previously mentioned, it is unclear on the Supplement-EZ Form if the
BUA within the drainage area to the SCM is 49,526 sf or 50,685 sf.
14. Prior NOTE — "NOTE: It appears as though there is approximately 7,000 sf of new
BUA that is not being captured and treated within the proposed SCM. Per the definition
of runoff treatment method and 15A NCAC 02H .1003(3)(d), the net increase in BUA
must be treated in one or more primary (or a combination of primary and secondary)
SCMs (i.e., there are approximately 7,000 sf of BUA that are required to be treated and
are not being treated by the proposed design). You may either reconfigure the project
drainage to capture the on -site net increase in BUA or permit this uncaptured portion of
the project area as a low -density area. " The new BUA added outside of the drainage
area to the SCM was not accounted for in either manner.
Coml
provii
15. Prior Comment 18 — "Provide PDFs of all revisions, 2 hardcopies of revised plan,
subrr
sheets, I hardcopy of other documents, and a response to comments letter briefly
describing how the comments have been addressed. " PDFs of the 1/25/2022 submission
were not uploaded and a comment response letter was not provided. A comment response
letter can be useful as it provides insight as to how the comments were addressed
Supplen
has bees
16. There are also issues with how the Sand Filer Page of the Supplement-EZ Form was
revised.
completed. Some Lines (such as Lines 1, 12, & 29) contain answers that do not make
sense within the context of what is being asked for while other Lines (such as Lines 2, 5,
9, 10, 37, 39) are blank and should be filled out. The "correctness" of the other Lines was
not reviewed.