HomeMy WebLinkAbout20230477 Ver 1_More Info Received_20230707 (2)Moore, Andrew W
From:
Joyce, Crystal <crystaljoyce@hdrinc.com>
Sent:
Friday, July 7, 2023 11:35 AM
To:
Moore, Andrew W; Mularski, Eric
Cc:
Fuemmeler, Amanda J CIV USARMY CESAW (USA); Leslie, Andrea J; Hamstead, Byron A; Shultz,
Matthew; Prosser, Darin; Carson, Hunter
Subject:
RE: [External] RE: Request for Additional Information, Carrier Bridge Pump Station Replacement
Project, Buncombe County (DWR Project #20230477)
CAUTION: External
email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
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Good morning Andrew,
In regard to the DWR Project #20230477 (USACE PCN application SAW-2021-01395) for the Carrier Bridge Pump Station
Project in Asheville, NC, please find the below links for the full submitted response package pertaining to USACE
comments made May 16, 2023 (documents submitted to USACE on June 16, 2023). In addition, please find the
responses below for the three items requested in the DWR June 23, 2023 email:
1. Please copy the Division on your response to the US Army Corps of Engineers' (USACE) May 16, 2023
comments, and specifically comment 4. [15A NCAC 02H .0506(b)(1)]
a. Response: Links are provided below for the USACE submitted responses and supporting documents. In
regard to USACE comment 4, please see Appendix A pages 1-3 for response details (PDF pages 4-6 of
283 pages).
Regarding the response to request 7, the Division appreciates MSD's willingness to implement the
contingency bank stabilization plan. The Division discussed this approach with the USACE and it appears this
approach is favored by the agencies. A condition of the 401 will require submittal of the plan prior to
implementing the project. If it's determined that bank stabilization beyond the limits of the cofferdam is
needed as a result of the project, the Division can modify the 401, in coordination with USACE requirements,
to include any additional bank stabilization work that is needed. There is no need to respond to this comment,
unless further discussions regarding this approach are requested. [15A NCAC 02H .0506(b)(1)]
a. Response: Understood, thank you.
3. Regarding the response to request 8, the bank stabilization details include options that involve the use of
erosion control matting products that contain plastic mesh and netting. The Division's Water Quality General
Certifications and Individual Certifications contain standard language that prohibit the use of erosion control
matting that incorporates plastic mesh and/or plastic twine along streambanks as aquatic organisms can
become entangled in these products. Please revise the Stream Stabilization Details to exclude matting
products containing plastic or clearly explain why 100% biodegradable products cannot be used. [15A NCAC
02H .0506(b)]
a. Response: The bank stabilization measures proposed will comprise of natural materials only that are
100% biodegradable. The options to utilize bank stabilization measures that may contain plastic mesh
and/or netting have been removed from the proposed measures to stabilize the streambanks. MSD will
notify and provide justification to the agencies if it is determined later that permanent stabilization
measures will require incorporating materials that are not considered 100% biodegradable. This revision
to the proposed bank stabilization measures to use only natural materials that are 100% biodegradable
is provided in the USACE response package (link below) comment response 5a, Appendix A pages 3-4
(PDF pages 6-7 of 283 pages).
We hope the additional information provided here should support the requests made from DWR to complete the permit
application. Please do not hesitate to contact us if you have any further questions or require additional clarifications on
the project information provided. We greatly appreciate your continued review and processing of the application
submittal. Thank you so much.
I'm using Adobe Acrobat Cloud with the file sizes being so large to transfer.
You can view "Section404_USACE_Additional Information —Carrier Bridge PS_06162023_reduc.pdf" at:
https://acrobat.adobe.com/link/review?uri=urn:aaid:scds: US:ddfb25fa-d781-4e39-a2c9-543a4la9bff3
You can view "MSD_CarrierBridge Project. kmz" at:
https://acrobat.adobe.com/link/track?uri=urn:aaid:scds: US:118cdl84-d2eO-4f83-9015-f66febOc67ea
You can view "Tree_ Clearing_20230614.kmz" at: https://acrobat.adobe.com/link/track?uri=urn:aaid:scds:US:1f401926-
fa4d-4bdO-bell-3eb538f7d63a
You can view "Tree_ Clearing_20230614.zip" at: https://acrobat.adobe.com/link/track?uri=urn:aaid:scds:US:79ec6bdl-
959d-4a63-aef1-079668322ade
You can view "ActionArea_20230614.zip" at: https://acrobat.adobe.com/link/track?uri=urn:aaid:scds:US:3fb48449-
d75b-4aa3-a 132-95c2ce2ecc77
Crystal Joyce (nee Allgood), CEP, CPESC, CISEC
D 210-841-2975
h d ri n c. co m/fo I I ow-u s
From: Moore, Andrew W <andrew.w.moore@deq.nc.gov>
Sent: Friday, June 23, 2023 3:41 PM
To: Mularski, Eric <Eric.Mularski@hdrinc.com>
Cc: Fuemmeler, Amanda J CIV USARMY CESAW (USA) <Amanda.Jones@usace.army.mil>; Leslie, Andrea J
<andrea.leslie@ncwildlife.org>; Hamstead, Byron A <byron_hamstead@fws.gov>; Allgood, Crystal
<Crystal.Allgood@hdrinc.com>; Shultz, Matthew <matthew.shultz@hdrinc.com>; Prosser, Darin
<dprosser@msdbc.org>; Carson, Hunter <HCarson@msdbc.org>
Subject: RE: [External] RE: Request for Additional Information, Carrier Bridge Pump Station Replacement Project,
Buncombe County (DWR Project #20230477)
CAUTION: [EXTERNAL] This email originated from outside of the organization. Do not click links or open attachments
unless you recognize the sender and know the content is safe.
Eric,
On March 29, 2023, the Division of Water Resources (Division) received your application requesting a 401 Water Quality
Certification from the Division for the subject project. Additional information in support of the project was received
June 2, 2023. On June 13, 2023, we discussed the outstanding items remaining to complete the application and I was
under the impression those items were forthcoming. As those items have not yet been received, 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. Please copy the Division on your response to the US Army Corps of Engineers' (USACE) May 16, 2023 comments,
and specifically comment 4. [1SA NCAC 02H .0506(b)(1)]
Regarding the response to request 7, the Division appreciates MSD's willingness to implement the contingency
bank stabilization plan. The Division discussed this approach with the USACE and it appears this approach is
favored by the agencies. A condition of the 401 will require submittal of the plan prior to implementing the
project. If it's determined that bank stabilization beyond the limits of the cofferdam is needed as a result of the
project, the Division can modify the 401, in coordination with USACE requirements, to include any additional
bank stabilization work that is needed. There is no need to respond to this comment, unless further discussions
regarding this approach are requested. [15A NCAC 02H .0506(b)(1)]
Regarding the response to request 8, the bank stabilization details include options that involve the use of
erosion control matting products that contain plastic mesh and netting. The Division's Water Quality General
Certifications and Individual Certifications contain standard language that prohibit the use of erosion control
matting that incorporates plastic mesh and/or plastic twine along streambanks as aquatic organisms can
become entangled in these products. Please revise the Stream Stabilization Details to exclude matting products
containing plastic or clearly explain why 100% biodegradable products cannot be used. [15A NCAC 02H .0506(b)]
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 July 14, 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.
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: (828) 296-4684
Andrew.W.Moore@deq.nc.gov
D- E
NORTH CAROLINA7.9� Q
ki;
Department of Environmental Duality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Mularski, Eric <Eric.Mularski@hdrinc.com>
Sent: Friday, June 2, 2023 2:26 PM
To: Moore, Andrew W <andrew.w.moore@deq.nc.gov>
Cc: Fuemmeler, Amanda J CIV USARMY CESAW (USA) <Amanda.Jones@usace.army.mil>; Leslie, Andrea J
<andrea.leslie@ncwildlife.org>; Hamstead, Byron A <byron_hamstead@fws.gov>; Allgood, Crystal
<Crystal.Allgood@hdrinc.com>; Shultz, Matthew <matthew.shultz@hdrinc.com>; Prosser, Darin
<dprosser@msdbc.org>; Carson, Hunter <HCarson@msdbc.org>
Subject: [External] RE: Request for Additional Information, Carrier Bridge Pump Station Replacement Project, Buncombe
County (DWR Project #20230477)
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Andrew,
Please find the attached responses to the incomplete 401 Water Quality Certification application notification
received from the Division of Water Resources (Division) via email on May 3, 2023. The additional information
provided in this response should provide the Division a complete application. Do not hesitate to contact us if
you have questions or require additional clarifications. We appreciate your continued review and processing of
our application submittal.
Sincerely,
Eric Mularski, PwS, PMP
South Atlantic Area Resources Business Group
Environmental Sciences & Planning Manager
HDR
440 S. Church Street
Charlotte, NC 28202
D 704-973-6878 M 704-806-1521
Eric. mularski(@hdrinc.com
hdrinc.com/follow-us
From: Moore, Andrew W <andrew.w.moore@ncdenr.gov>
Sent: Wednesday, May 3, 2023 9:16 AM
To: Mularski, Eric <Eric.Mularski@hdrinc.com>
Cc: Fuemmeler, Amanda J CIV (US) <Amanda.Jones@usace.army.mil>; Leslie, Andrea J <andrea.leslie@ncwildlife.org>;
Hamstead, Byron A <byron hamstead@fws.gov>
Subject: Request for Additional Information, Carrier Bridge Pump Station Replacement Project, Buncombe County (DWR
Project #20230477)
CAUTION: [EXTERNAL] This email originated from outside of the organization. Do not click links or open attachments
unless you recognize the sender and know the content is safe.
Eric,
On March 29, 2023, 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:
Please provide a figure that depicts the future extension of the 60-inch diameter gravity sewer interceptor pipe
from the South River Crossing and extending upgradient/south. The Division understands these plans may not
be finalized at this time, so conceptual plans are acceptable. [15A NCAC 02H .0502(a)(9) and 15A NCAC 02H
.0506(b)(1)]
Please clarify if the current proposed plans include upgrading the 48-inch diameter South French Broad
interceptor from the South River Crossing to the Amboy Road Bridge (i.e. through Carrier Park, former Edaco
junkyard, etc.). The PCN Supplemental Information narrative indicates this is not part of the current plans.
However, previous meetings and a number of figures included with the PCN (e.g. Three Oaks PJD, Environmental
Management Plan) indicate this upgrade is part of the project scope. [15A NCAC 02H .0502(a)(9)]
During a site meeting conducted on April 27, 2023, with staff from the Division, NCWRC, MSD, and HDR, there
we discussions that indicated the rockfill cofferdam was still in consideration for the project. The PCN narrative
indicates a sheet pile cofferdam will be implemented for the project. Please clarify if the rockfill cofferdam is still
being considered for the project. [15A NCAC 02H .0502(a)(9)]
4. The PCN project narrative indicates either a sheet pile with king piles or the brace box sheet pile construction
will be implemented for the cofferdam.
a. The Division understands the king piles will require drilling into bedrock along the riverbed prior to
setting the sheet piles. Please provide a construction sequence that details how this work will be
conducted so that the river flow does not come in contact with the disturbed area and/or how the river
will be protected from turbidity during the drilling process.
b. Both the sheet pile with king piles and brace box sheet pile construction are likely to require grouting to
seal the sheet piles from seepage. Please note that cement that contains lime and comes in contact with
water can have detrimental effects on aquatic life due to changes in pH. Please explain how the grouting
will occur to preclude contact with the river flow. [15A NCAC 02H .0506(b)(2)]
5. Will the proposed South River Crossing cofferdam block or impede flow from stream SA's channel with its
confluence with the French Broad River? [15A NCAC 02H .0506(b)(1) and (2)]
6. There is a stream in the vicinity of the North River Crossing that is not depicted on any of the figures or in the
PJD request package. Please revise the figures to include the stream. Please also clarify if any impacts,
temporary or permanent, to the stream will be required to complete the North River Crossing. [15A NCAC 02H
.0502(a)(9)]
Based on the April 27, 2023 site meeting, the Division understands that rather than preemptively installing the
temporary streambank stabilization measures downstream of the proposed cofferdam locations, which would
involve extensive disturbance to the well -established woody riparian buffer, the applicant is considering a
contingency bank stabilization plan approach in which permanent bank stabilization measures consisting or rip
rap would be installed only after indications of bank instability or degradation were observed. Please provide a
narrative description of the contingency bank stabilization plan. The plan should include a qualitative evaluation
of the riverbanks downstream of the two river crossing locations as well as a routine assessment of the
riverbanks during construction. [15A NCAC 02H .0506(b)(1) an (2)]
8. Please provide construction details for the permanent natural bank stabilization that will be installed in the
vicinity of the cofferdams after installation of the gravity sewer and force main are installed. [15A NCAC 02H
.0502(a)(9)]
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 June 2, 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.
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: (828) 296-4684
Andrew.W.Moore@ncdenr.gov
, �: D E '� 7' `
NORTH CAROLINA ka;
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.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.