20221490 Ver 1_More Info Received_20221222

Moore, Andrew W
From: Joel Lenk <[e-mail]>
Sent: Thursday, December 22, 2022 11:48 AM
To: Moore, Andrew W
Cc: [e-mail]; Leslie, Andrea J
Subject: [External] RE: Request for Additional Information, Phase I Door of Hope Campus, Polk County (DWR
Project #20221490)
Attachments: P22044-DOHM AGENT AUTH SIGNED.pdf; P22044-DOHM Updated PCN Impact Table.pdf; P22044-
DOHM Updated PCN Impact Table.pdf
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Andrea & Andrew,
Hope you are well. Please see the project teams responses to the requested information below and
attached. Numbered responses below correspond to the numbers in Andrew's Request for Additional Information.
The owner has changed the material for the 69-ft culvert to be installed in UT-1 from HDPE to CMP.
1. An executed agent authorization form for the project is attached along with the NC DEMLR SESC Plan Approval
for Phase I of the project. Please use the following link: Door of Hope Ministry, Brooks Engineering -Updated
Plan Set, Phase 120221220 to access the updated, approved plan for the project.
2. A culvert cross-section detail showing the provisions for aquatic life passage/culvert burial [15A NCAC 02H
.0506(b)(2) and (3)] can be found on Sheet C-5.6 of the linked plan.
3. An updated stream impact table is attached and includes stabilization work associated with culvert and ford
removals as well as the stabilization/restoration work proposed upstream and downstream of the double arch
culvert. One of the 20' culvert removals in UT-1 is in the same location as the proposed 69' CMP
culvert. Temporary impacts associated with other historic culvert removals that will include daylighting stream,
streambank stabilization and restoration of streambanks discussed in the PCN narrative, were not included
originally in the impact table because these actions will ultimately result in benefits to water quality and
habitat. If the regulatory community agrees with this and evidence is provided before, during and post
construction the owner and developer of this project would respectfully request that lengths of restored
reaches of stream be subtracted from the permitted permanent impacts associated with the project.
4. Installation of the double arch culvert will require the footer/foundation proposed within Wheat Creek. Please
review the additional construction details for the double arch culvert that show how the structure will be built
such that flowing water will not contact curing concrete on Sheet C-5.7 of the linked plan.
Please note that final structural engineering plans for the double arch culvert are in production by Odom
Engineering and can be provided once completed. Wheat Creek and its tributaries within the project area are
not within a FEMA mapped floodplain and a FEMA flood study is not required for this project. Abutments
associated with the double arch crossing are proposed outside of the USACE verified jurisdictional area for
Wheat Creek at a width that provides a similar cross -sectional area for stream flow, at and below the
OHM/bankfull elevation/"2 year event, as the existing condition. The existing condition of streambanks along
Wheat Creek and in the vicinity of the proposed crossing are poor and unstable. Stabilization and restoration of
streambanks within the project area, through removal of historic culverts and the proposed stabilization and
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restoration work associated with the proposed crossings for this project, will provide greater global stream
stability than currently exists. Fill outside the USACE verified jurisdictional area of Wheat Creek has been
reduced, and may be reduced further, in the final Odom Engineering Plan for the double arched
crossing. Reduction of fill in the relic floodplain is proposed in an effort to allow stream flows that are greater
than existing top of bank to pass the crossing area in the existing floodplain without causing significant
erosion. Please note that Wheat Creek is an incised stream and that no field evidence was observed during
Quible's work, that indicates that Wheat Creek frequently accesses the upper relic floodplain where fill for the
approach to the double arched crossing is proposed.
5. The linked Brooks Engineering Plan for the project shows how the project meets the definition and design
requirements for low density, and provides the following:
a. A detailed stormwater drainage plan including all stormwater drainage patterns and outlets to clearly
show that the project meets 15A NCAC 02H .1003(2)(b) "Projects shall be designed to maximize
dispersed flow through vegetated areas and minimize channelization of flow."
b. A detailed stormwater drainage plan that clearly shows that the project meets 15A NCAC 02H
.1003(2)(c) "Stormwater that cannot be released as dispersed flow shall be transported by vegetated
conveyances". Design plans and calculations for all vegetated conveyances such as swales, and/or level
spreader, etc. are provided. [15A NCAC 02H .0502 and .0506]
6. Wastewater from the proposed project during construction will be disposed of through the use of portable
toilets that are pumped and cleaned regularly by a licensed wastewater disposal company. Wastewater will be
disposed of properly. Ultimately, wastewater at the site will be disposed of through a appropriately designed,
County approved, on -site wastewater system.
Please feel free to call or respond to this email if there are questions or any additional information is needed.
Happy Holidays and best regards,
Joel Lenk, P.G.
WNC Office Manager
Quible & Associates, P.C.
90 Church Street, Suite B
Black Mountain, NC 28711
mobile [phone]
land line 828.357.5149
www.quible.com
G�
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From: Leslie, Andrea J <[e-mail]>
Sent: Tuesday, November 29, 2022 9:20 AM
To: Moore, Andrew W <[e-mail]>; Joel Lenk <[e-mail]>
Cc: [e-mail]
Subject: RE: Request for Additional Information, Phase I Door of Hope Campus, Polk County (DWR Project #20221490)
Joel, can you also identify what material the 69-ft culvert will be? We strongly recommend
against HDPE and RCP.
Andrea
Andrea Leslie
Mountain Habitat Conservation Coordinator
NC Wildlife Resources Commission
645 Fish Hatchery Rd., Building B
Marion, NC 28752
828-803-6054 (office)
828-400-4223 (cell)
www.ncwildlife.org
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From: Moore, Andrew W <[e-mail]>
Sent: Tuesday, November 22, 2022 4:29 PM
To: Joel Lenk <[e-mail]>
Cc: [e-mail]; Leslie, Andrea J <[e-mail]>
Subject: Request for Additional Information, Phase I Door of Hope Campus, Polk County (DWR Project #20221490)
Joel,
On October 26, 2022, the Division of Water Resources (Division) received your application requesting a 401 Water
Quality Certification from the Division for the subject project. The Division has determined that your application is
incomplete and cannot be processed. The application is on -hold until all of the following information is received:
1. Title 15A NCAC 02H .0502(a)(11) requires that if an agent signs the application, an agent authorization letter
must be provided. Please provide an agent authorization form signed by a representative of Door of Hope
Ministries granting you signature authority. A sample form may be found here
https://edocs.deq.nc.gov/WaterResources/DocView.aspx?dbid=0&id=2488211&cr=1. [15A NCAC 02H
.0502(a)(11)]
2. Please provide a culvert cross-section detail showing the provisions for aquatic life passage/culvert burial. [15A
NCAC 02H .0506(b)(2) and (3)]
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3. There appear to be inconsistencies between the narrative description of the project and the project impact
table. Please revise the impact table to include the stabilization work associated with the culvert and ford
removals as well as the stabilization work proposed upstream and downstream of the double arch culvert. [15A
NCAC 02H .0502]
4. Based on the inset detail on Sheet 1, it appears the impact associated with the double arch culvert involves a
footer proposed within Wheat Creek. Please provide additional construction details regarding the double arch
culvert, including material, dimensions, and more information regarding how the structure will be built such that
flowing water will not contact curing concrete if applicable. Please demonstrate that the reduction in cross -
sectional dimension available for flow as a result of the of the in -stream structure will not result in
destabilization or degradation of the existing streambanks and streambed within, upstream, or downstream of
the culvert. [15A NCAC 02H .0502 and .0506(b)(2)]
5. In order to document that the project meets the definition and design requirements for low density, please
provide:
a. A detailed stormwater drainage plan including all stormwater drainage patterns and outlets to clearly
show that the project meets 15A NCAC 02H .1003(2)(b) "Projects shall be designed to maximize
dispersed flow through vegetated areas and minimize channelization of flow."
b. A detailed stormwater drainage plan to clearly show that the project meets 15A NCAC 02H .1003(2)(c)
"Stormwater that cannot be released as dispersed flow shall be transported by vegetated conveyances".
Please provide design plans and calculations for all vegetated conveyances such as swales, and/or level
spreader, etc. [15A NCAC 02H .0502 and .0506]
6. How will wastewater from the proposed project be disposed. [15A NCAC 02H .0502 and .0506(b)(2)]
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 provide your response by December 22, 2022. If all of the requested
information is not received, 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 appropriate fee.
Feel free to contact me if you have any questions.
Andrew W Moore, P.G.
Environmental Specialist 11, Division of Water Resources
North Carolina Department of Environmental Quality
Office: [phone]
[e-mail]
NORTH CAROLINA ExE
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
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