20231456 Ver 1_More Info Requested_20231207

Moore, Andrew W
From: Moore, Andrew W
Sent: Thursday, December 7, 2023 2:26 PM
To: Mona Ellum
Cc: Anderson, Mitchell L CIV USARMY CESAW (USA); Leslie, Andrea J
Subject: Request for Additional Information 2, Weaverville Pump Station and Force Main Improvements,
Buncombe County (DWR Project #20231456)
Ms. Ellum,
On October 25, 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 November 17, 2023, and November 27, 2023. 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:
The Division appreciates the revised site plans received November 27, 2023, which more clearly identify stream
and wetland impacts using color. However, the wetland and stream impacts were not labeled using the Site #
included in the impact table as requested, rather they were labeled using stream or wetland name. It remains
difficult to correlate with high confidence the impacts listed on the impact table to the site plans for streams
that are impacted multiple times (e.g. SB, SC, SJ, SN). Please revise the site plans to include a label at each
impact location that corresponds with the Site # (i.e. S1, S2, etc. not Stream B, Stream J, etc.) [15A NCAC 02H
.0502(a)(6) and (9)]
2. The impact length listed in the table for S1 (192 feet) does not appear to match the site plans for what I assume
is impact S1 (see comment above) on SB, which appears to be maybe 75 feet based on the scale and highlighted
area on Sheet C-103. Note that stream impact lengths should be measured parallel to flow. Please explain the
discrepancy. [15A NCAC 02H .0502(a)(6) and (9)]
3. Why is such a wide construction corridor needed at the second SB location (75 feet). Construction corridors
across streams and wetlands are typically limited to 40 feet wide. As this is a near perpendicular crossing at a
new impact location (i.e. no existing sewer), the temporary stream impact at this location should be closer to 40
feet or less. [15A NCAC 02H .0506 (b)(1)]
4. Please provide additional clarity on why stream impact S3 is necessary and why it cannot be avoided. The impact
table lists the impact type as excavation, however, the new force main does not cross the stream in this location.
In addition, the impact table for S3 lists the impact as 69 feet. However, based on the scale provided on Sheet C-
301, the impact appears significantly less then 69 feet. Please clarify. [15A NCAC 02H .0506 (b)(1)]
5. Please provide additional details regarding the nature of the stream S4 impact, which includes 261 feet of
temporary impact. Based on the site plans, there appears to be a significant portion of the 261 feet that runs
parallel to the force main location with a single crossing of the stream. In addition, it appears there is no
temporary construction easement in this area. What are the anticipated impacts to the stream in this location
and how will the work be completed with such limited space? Please note the stream bed cannot be used as a
haul road or as construction access for equipment. [15A NCAC 02H .0506 (b)(1)]
Stream E is depicted as a temporary stream impact in the plans on Sheet C-303, but does not appear to be
included in the impact table. Please clarify if this impact is necessary as the force main does not appear to cross
the stream in this location. Please note streams that are present within MSD's easement, but that are not

directly impacted by a crossing, should not be listed as impacts. In these locations the LOD should be moved to
avoid impacts to these features. [15A NCAC 02H .0502(a)(6) and (9)]
What restoration methodology will be used to restore impacts to Streams SB (upgradient location), H, I, L, the Js
near Pump Station #2 (one call out on Sheet C-310, but unclear which impact it points to), and upgradient N?
There does not appear to be a restoration detail call out on the plans in these locations. [15A NCAC 02H .0506
(b)(1)(2) and (3)]
There appear to be five impact locations on Stream J (1 on Sheet C-307; 1 on Sheet C-308; and 3 on Sheet C-
309). However, there are only two impacts (S10 and S11) listed in the impact table for stream J. Please revise the
impact table to differentiate each impact location or clarify the discrepancy. [15A NCAC 02H .0502(a)(6) and (9)]
9. Please explain the nature and need for impacts to Wetland N and to the upgradient impact to Stream N. These
impacts appear to be in an area where the existing force main is to remain. [15A NCAC 02H .0506 (b)(1)]
10. Many of the notes for the stream impacts include a note regarding a temporary stream crossing. For instance,
note 10 on Sheet C-302. Please provide a detail or otherwise describe what the temporary stream crossing will
consist of. [15A NCAC 02H .0502(a)(6) and (9)]
11. Why is the new force main located so close to stream J near/in wetland L? The placement of the force main in
this location is likely to destabilize the streambank resulting in secondary impacts to the stream. In addition,
Stream J is highlighted as an impact in this location. What is the nature of the impact in this location as there is
not a new line crossing the stream? [15A NCAC 02H .0506 (b)(1)(2) and (3)]
12. Heavy equipment working in wetlands should be placed on mats or other measures shall be taken to minimize
soil disturbance and compaction. Please provide details describing how this condition will be met. [15A NCAC
02H .0506 (b)(1)(2) and (3)]
13. Please provide a wetland restoration detail or restoration narrative for wetlands that will be temporarily
impacted due to excavation. You may refer to Activity Specific Condition 1.7. in Water Quality General
Certification 4276 for guidance. [15A NCAC 02H .0502(a)(6) and (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 January 8, 2024. 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]

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