HomeMy WebLinkAboutRe [External] Re Request for Additional Information, Bost Rd Sewer Improvements, Burke County (DWR #20221768)1
Winston, Joey
From:Megan Bollero <megan@cws-inc.net>
Sent:Wednesday, March 15, 2023 10:47 AM
To:Winston, Joey
Cc:Boggs, Brandee C CIV USARMY CESAD (USA); Leslie, Andrea J
Subject:Re: [External] Re: Request for Additional Information, Bost Rd Sewer Improvements, Burke County
(DWR #20221768)
Attachments:Attachment B - Impact Figures(REVISED)(red).pdf
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Hi Joey,
I have responded to your questions below in red:
1.
The application indicates that horizontal directional drilling will be used to install a sewer line beneath the
Catawba River. This portion of the Catawba River is regulated by a state Riparian Buffer Rule. Project plans
indicate that a 250‐foot riparian buffer conservation easement is present on the eastern shoreline of the
Catawba River that will not be impacted. Please clarify whether any impacts will occur to the 50‐foot state
riparian buffer, particularly along the western shoreline of the Catawba River. If impacts are proposed, please
quantify and clearly depict them on plans. A Buffer Authorization may be required for these impacts. [15A NCAC
02B .0611(b)(1)]
No surface impacts will occur beyond the location of the bore pits, which are outside of the 50' riparian buffer.
The engineer has added the 50' buffer to the drawings.
2. The application indicates that horizontal directional drilling will be used to install portions of a sewer line
beneath surface waters, which has the potential to release drilling fluids to surface waters through inadvertent
returns. Please provide an Inadvertent Release Contingency Plan that establishes procedures for prevention,
containment, and clean‐up of any potential inadvertent returns. [15A NCAC 02H .0506(b)(2)]
As I mentioned to you in the previous email, this will be done at a later date by the contractor. They said the
contractor is the one who typically provides that as the contractor will hire an HDD sub for
installation. The engineer added technical specification languagege for the HDD requiring the
contractor to prepare and submit and comply with a contingency plan.
3. The project proposes permanent impacts to 10 feet of perennial stream for riprap bank stabilization. Please
elaborate on why this stream requires permanent impacts while other streams within the project footprint do
not. Please also clarify why natural stabilization techniques, such as a vegetated buffer, cannot be utilized. [15A
NCAC 02H .0506(b)(1)]
The rip rap is only a temporary impact, and will be removed upon completion, and the banks will be stabilized
using natural stabilization methods.
4. Project plans indicate that a portion of wetlands will be isolated by the permanent fill for the pump station.
Plans also indicate that an existing culvert will be extended, disconnecting additional wetlands. The application
and plans identify impacts to these isolated and disconnected wetlands as temporary; however, temporary
impacts are those that are of sufficiently short duration to have no impacts to the ecology of the area, and
within a reasonably short duration will restore to their original, preconstruction function. The Division believes
that because of the proposed permanent impacts, secondary impacts will result in a post‐construction loss of
2
additional wetlands. Please revise plans and impact estimates or provide a detailed narrative explaining how a
permanent loss will not occur. [15A NCAC 02H .0502(a)(4)]
The engineer has changed this so that the severed areas will now be considered permanent impacts. This
wetland is so small that the impact numbers are still 0.01 acre of permanent and 0.01 acre of temporary impacts. The
area of temporary impact will still have connection to downstream waters via the culvert, as it will be buried 1' below
existing grade. Additionally, this wetland is a low quality roadside ditch. There is also one additional stream impact (now
S2 on sheet C1.2) associated with the culvert. The ESC reviewer has required them to add a rip rap apron in the outlet of
that culvert, resulting in 16 lf of permanent impact.
I have attached the updated drawings below. Please let me know if you need anything else from me.
Thanks,
Megan Bollero
On Fri, Feb 24, 2023 at 12:30 PM Winston, Joey <joey.winston@ncdenr.gov> wrote:
Hi Megan,
Yes, adding that language should be enough to meet our requirements. We’ll also likely add it as a condition to the 401.
Thanks,
Joey
Joey Winston
Environmental Specialist I, Division of Water Resources
North Carolina Department of Environmental Quality
Office: (828) 296‐4685 | Cell: (828) 785‐9171
joey.winston@ncdenr.gov
From: Megan Bollero <megan@cws‐inc.net>
Sent: Friday, February 24, 2023 8:13 AM
3
To: Winston, Joey <joey.winston@ncdenr.gov>
Subject: [External] Re: Request for Additional Information, Bost Rd Sewer Improvements, Burke County (DWR
#20221768)
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Hi Joey,
I am working with the engineer to respond to your questions, but they did want me to reach out and ask about your
2nd question about the release contingency plan. They said the contractor is the one who typically provides that as the
contractor will hire an HDD sub for installation. Are you ok with the engineer adding technical specification language
for the HDD requiring the contractor to prepare and submit and comply with a contingency plan and submit that to
DEQ demonstrating the contractor will provide it?
Thanks,
Megan Bollero
On Fri, Feb 17, 2023 at 11:46 AM Winston, Joey <joey.winston@ncdenr.gov> wrote:
Ms. Bollero,
On January 11, 2022, the Division of Water Resources (Division) received your application requesting a 401 Water
Quality Certification and Buffer Authorization 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. The application indicates that horizontal directional drilling will be used to install a sewer line beneath the
Catawba River. This portion of the Catawba River is regulated by a state Riparian Buffer Rule. Project plans
indicate that a 250‐foot riparian buffer conservation easement is present on the eastern shoreline of the
Catawba River that will not be impacted. Please clarify whether any impacts will occur to the 50‐foot state
riparian buffer, particularly along the western shoreline of the Catawba River. If impacts are proposed, please
quantify and clearly depict them on plans. A Buffer Authorization may be required for these impacts. [15A
NCAC 02B .0611(b)(1)]
4
2. The application indicates that horizontal directional drilling will be used to install portions of a sewer line
beneath surface waters, which has the potential to release drilling fluids to surface waters through
inadvertent returns. Please provide an Inadvertent Release Contingency Plan that establishes procedures for
prevention, containment, and clean‐up of any potential inadvertent returns. [15A NCAC 02H .0506(b)(2)]
3. The project proposes permanent impacts to 10 feet of perennial stream for riprap bank stabilization. Please
elaborate on why this stream requires permanent impacts while other streams within the project footprint do
not. Please also clarify why natural stabilization techniques, such as a vegetated buffer, cannot be utilized.
[15A NCAC 02H .0506(b)(1)]
4. Project plans indicate that a portion of wetlands will be isolated by the permanent fill for the pump station.
Plans also indicate that an existing culvert will be extended, disconnecting additional wetlands. The
application and plans identify impacts to these isolated and disconnected wetlands as temporary; however,
temporary impacts are those that are of sufficiently short duration to have no impacts to the ecology of the
area, and within a reasonably short duration will restore to their original, preconstruction function. The
Division believes that because of the proposed permanent impacts, secondary impacts will result in a post‐
construction loss of additional wetlands. Please revise plans and impact estimates or provide a detailed
narrative explaining how a permanent loss will not occur. [15A NCAC 02H .0502(a)(4)]
Pursuant to Title 15A NCAC 02H .0502(c) and Title 15A NCAC 02B .0611(b)(3), the applicant shall furnish all of the
above requested information for the proper consideration of the application. Please provide your response by March
17, 2023. 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.
Please let me know if you have any questions.
Regards,
Joey
Joey Winston
Environmental Specialist I, Division of Water Resources
North Carolina Department of Environmental Quality
Office: (828) 296‐4685 | Cell: (828) 785‐9171
joey.winston@ncdenr.gov
5
‐‐
Megan Bollero, WPIT
Project Scientist
Carolina Wetland Services Inc.
550 E Westinghouse Boulevard
Charlotte, NC 28273
Cell:(757)‐576‐6433
www.cws.net
‐‐
Megan Bollero, WPIT
Project Scientist
Carolina Wetland Services Inc.
550 E Westinghouse Boulevard
Charlotte, NC 28273
Cell:(757)‐576‐6433
www.cws.net