20131200 Ver 2 - 131200TryonHorseFarm(Polk)_Approve_SW - 4/10/2015

Strickland, Bev
From: Lucas, Annette
Sent: Friday, April 10, 2015 2:13 PM
To: 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: 131200TryonHorseFarm (Polk)_Approve_SW.docx.doc
Annette M. Lucas, PE
Environmental Engineer
NCDENR I DEMLR I Stormwater Program
1612 Mail Service Center, Raleigh, NC 27699 -1612 (M<:ffl)
512 N. Salisbury St, Raleigh, NC 276014 1 9th Floor (Loc [ion (% Pmvcls)
Phone: [phone] I Fax: [phone] I Email: annette.lucas @ncdenr.gov
Website. ltLLl ./ �l�ap� � ➢. �° lar ap t arn� ➢�,:. �ap�'� a �a °'
Before printing this email, please consider your budget and. the environment.
E -mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
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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 a
Subject: RE: 13- 1200v2 Tryon Horse Complex
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 huntCa)ncsu.edu)'; 'Andrew
Anderson (arander5Cd)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.
Please include your design information for the Tryon Horse Complex site and the Isolator Row technology together as
single, coordinated package. You should both be familiar with the other's design information.
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
F. ra I . mo
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
0 1 Mm-symm-MIM.1m
512 N. Salisbury St, Raleigh, NC 27604 1 91h Floor (Location & Parc�els)
Phone: [phone] Fax: [phone] Email: annette.lucasgncdenr.gov
Website http://portal.ncdenr.org/web/Ir/stormwater
bA, Before printing this email, please consider your budget and. the environment.
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.
6

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1 ►;
Carolina North Department of ! and Natural Resourcl
Pat McCrory
Governor
April 10, 2015
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
Subject: STORMWATER MANAGEMENT PLAN
TRYON EQUESTRIAN CENTER
Dear Messrs. Brown and Smith:
Donald R. van der Vaart
Secretary
DWR Project # 13 -1200
Polk County
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. On February 1, 2015, DEMLR received a
revised stormwater management plan, dated January 5, 2015.
DEMLR has determined that the revised stormwater management plan meets Condition 6 of the
401 Certification for this project.
Division of Energy, Mineral, and Land Resources
Energy Section • Geological Survey Section • Land Quality Section
1612 Mail Service Center, Raleigh, North Carolina 27699 - 1612.919- 707 -9200 / FAX: 919 - 715 -8801
512 North Salisbury Street, Raleigh, North Carolina 27604 • Internet: http: / /portal.ncdenr.org /web /ir/
An Equal Opportunity \ Affirmative Action Employer- 50% Recycled \ 10% Post Consumer Paper

Mr. Jeff Brown
April 10, 2015
Page 2 of 3
Conditions of Approval:
1. The SMP approved by DEMLR consists of the following:
Drainage
area
Type of practice
Impervious surface
draining to practice
(square ft)
Total drainage area
of practice
(square feet)
2&3B
Isolator Row
338,897
977,922
3A
Isolator Row
83,200
554.954
4
Isolator Row
138,521
368,953
6
Isolator Row
202,118
642,074
7
Wet Pond /Level Spreader
157,167
8
Isolator Row
467,399
1,335,114
The stormwater control measures listed above and all associated stormwater conveyances,
inlet and outlet structures, and the grading and drainage patterns depicted on plan sheets
dated October 16, 2014. The plans and specifications approved by DEMLR are
incorporated by reference into this approval and are enforceable by DEMLR and DWR
provided however that any modification of the design for the stormwater management
system that is accepted by DEMLR or DWR shall take precedence over the original plans
and specifications.
The maximum allowable drainage and the maximum impervious areas for the stormwater
control measures shall be per the table above. Any changes to these maximum areas shal
require the applicant to submit and receive approval for a revised stormwater
management plan by DEMLR or DWR.
The footprint of all stormwater management devices as well as an additional 10 -foot wide
area on all sides of the devices shall be located in public rights -of -way, dedicated common
areas or recorded easement areas. The final plats for the project showing all such rights -
of -way, common areas and easement areas shall be in accordance with the approved
plans.
4. Maintenance activities for the wet pond shall be performed in accordance with the
notarized O &M agreements signed by Mr. Jeff Brown on January 5, 2015. Maintenance
activities for the Isolator Row shall be performed in accordance with the notarized O &M
agreements signed by Mr. Jeff Brown on October 15, 2014. The O &M agreements shall
transfer with the sale of the land or transfer of ownership /responsibility for the BMP
facility. DWR shall be notified promptly of every transfer.
5. The applicant and /or authorized agent shall provide a completed Certificate of Completion
form to the DWR within thirty (30) days of project completion (available at
http: / /portal.ncdenr.org /web /wq /swp /ws /401 /certs and permits /apply /forms).

Mr. Jeff Brown
April 10, 2015
Page 3 of 3
Thank you for your attention to this matter. If you have any questions or wish to discuss these
matters further, please do not hesitate to contact me at (919) 807 -6381.
Sincerely,
Annette M. Lucas, PE
Environmental Engineer
AML /am/
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)
Rename: 131200Tryon Horse Farm (Polk)_Approve_SW.docx