SW6230807_Response To Comments_20240328

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ROY COOPER 11 4. _- gi
Governor ■!,i``•. C
ELIZABETH S.BISER "" _ ?
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Secretary 4
WILLIAM E.TOBY VINSON,JR NORTH CAROLINA
Interim Director Environmental Quality
March 8, 2024
Harrison French&Associates
Attn: Christopher Wall, PE
1705 S. Walton Blvd, Suite 3
Bentonville, AR 72712
AND
Love's Travel Stop and Country Stores
Attn: Shane Wharton, President
10601 N. Pennsylvania Ave
Oklahoma City, OK 73126
Subject: Request for Additional Information
Stormwater Permit No. SW6230807
Love's Travel Stop (Store 412)
Harnett County
Dear Mr. Wall and Mr. Wharton:
The Division of Energy, Mineral and Land Resources (DEMLR), received a Stormwater
Management Permit Application for the subject project on December 11, 2023. A review
of that information has determined that the application is not complete. The following
information is needed to continue the stormwater review:
1. Previous Comments Unresolved:
a. Per Sheet C7.7, the post-development drainage area is 9.63 ac, but the drainage
area utilized in the calculations provided was 9.55 ac.
Current Comment: Ensure consistency throughout the package. Each of the
following items is meant to provide information pertaining to the drainage area
served by the SCM, outlined in red to ensure clarity. These areas should be
consistent throughout the package. Currently there are contradictions in the package
such as the drainage area provided on sheet C7.7 (9.63 ac), Supplement-EZ (8.32
ac), and the drainage area provided in the calculations (9.55 ac).
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Basin Information rainage Area 1 DRAINAGE AREA INFORMATION Entire Site 1
Receiving Stream Name Mingo Swamp 4 Type of SCM Wet Pond
Stream Class • C;SW 5 Total drainage area(sq ft) 419,623 362,498
Stream Index Number' 18-68-12-2 6 Onsite drainage area(sq ft) 416,247 357,998
7 Offsite drainage area(sq ft) 4,500 4,500
Total Drainage Area(sf) 419,623 8 Total BUA in project(sq ft) 278,342 278,341
On-site Drainage Area(sf) 416,247 New BUA on subdivided lots(subject to
Off-site Drainage Area(sf) 34,412 9 _permitting)(sq ft)
New BUA not on subdivided lots(subject to
Proposed Impervious Area"(sf) 278,342 10 permitting)(sf)
% Impervious Area'(total) 66.63 11 Offsite BUA(sq ft) 4,500 4,500
Impervious"'Surface Area Drainage Area 1 12 Breakdown of new BUA not on subdivided lots:
Parking(sq ft) 221,231 221,231
On-site Buildings/Lots(sf) 24,569 -Sidewalk(sq ft) 6,841 6,841
On-site Streets (sf) 0.00 . -Roof(sq ft) 24,569 24,569
On-site Parking (sf) 221,231 -Roadway(sq ft)
On-site Sidewalks (sf) 6,841 . -Oth r ft)
-Other,,p plelease specify in the comment box
Other on-site (sf) 20,801 below(sq ft) 20,801 20,801
Future(sf) 0.00 New infiltrating permeable pavement on
Off-site (sf) 4,500 13 subdivided lots(sq ft)
ExistingBUA'•'(sf) 227,813 New infiltrating permeable pavement not on
14 subdivided lots(sq ft)
Total (sf): 277,595 Existing BUA that will remain(not subject to
15 permitting)(sq ft) 21,201 21,201
16 Existing BUA that is already permitted(sq ft)
17 Existing BUA that will be removed(sq ft) 206,610
18 _Percent BUA 66% 77%
19 Design storm(inches) 10.1 in
20 Design volume of SCM(cu ft) 42530 cf
21 Calculation method for design volume Rational Method
b. Per 15A NCAC 02H.1042 (2) (h) (i), the plan details shall include labeled side
slopes and a benchmark for clean-out.
Current Comment: The revised plan details include additional labeled slopes,
however, to ensure compliance with General MDC 2 ("Side slopes of SCMs
stabilized with vegetated cover shall be no steeper than 3:1"),please label the
side slopes of the SCM. This will include the side slopes of both sides of the
dam embankment.
A benchmark for cleanout was not provided on the SCM detail sheets,please
provide. Please refer to Chapter C-3 of the Stormwater Design Manual, Figure
2: Wet Pond Example: Cross-Section View 1, for an example figure of noting
sediment storage depth.
c. Per Wet Pond MDC 5 (b), the forebay entrance shall be deeper than the forebay
exit.
Current Comment: The cross-section detail provided on Sheet C7.9 does not
indicate compliance with this minimum design criteria, nor does the plan view
of the SCM. For a visual representation of this MDC, please refer to Chapter C-
3 of the Stormwater Design Manual, Figure 2: Wet Pond Example: Cross-
Section View 1.
d. Provide engineering calculations demonstrating the inlets of the wet pond are
designed to protect the SCM from erosion resulting from stormwater
discharges. The outlets of SCMs shall be designed so that they do not cause
erosion downslope of the discharge point during the peak flow from the 10 year
storm event. Rip-rap apron sizing calculations should be provided, and the
class and dimensions of the rip-rap aprons should be specified on the plans.
Current Comment: Per General MDC 4: The inlets of SCMs shall be designed
to protect the SCM from erosion resulting from stormwater discharges. The

outlets of SCMs shall be designed so that they do not cause erosion downslope
of the discharge point during the peak flow from the 10-year storm event as
shown by engineering calculations.
Per 15A NCAC 02H .1003 (5), stormwater outlets shall be designed so that they
do not cause erosion downslope of the discharge point during the peak flow
from the 10-year storm event as shown by engineering calculations.
i. To ensure protection from erosion, separate engineering calculations are
required for each SCM inlet, SCM outlet, and stormwater discharge point.
The site-specific conditions of each structure (ex: tailwater condition,
discharge velocity, pipe diameter, etc)must be accounted for in the
calculations to determine the appropriate size and class of outlet protection.
In the last submittal, only one calculation was provided(for the outlet of the
site). One class calculation was found,but the class did not appear to be
indicated on the plans. Please provide site-specific calculations for each
protection location. Once this analysis is completed,protection which
corresponds to the calculated dimensions (length, width, thickness) and class
must be stated on the plans.
e. Supplement-EZ, Drainage Areas Page, Entire Site, Line 21: The Rational
Method is not a calculation method for the design volume, it is a method for
calculating peak flow. The calculation method that coordinates with the
minimum required treatment volume provided is the Simple Method(Schueler
1987), which was found in the calculations.
Current Comment: This was unresolved. This is required per General MDC 1.
f Per the Supplement-EZ, the bottom of sediment storage for the main pool is
231. Using this area in the stage storage table overestimates the volume that
will be stored within the main pool. It is unclear what the storage elevation for
the forebay is, so this comment may apply to the forebay stage storage
calculations as well. If 231.5 is the bottom of the pond/top of sediment
elevation for the main pool,please provide the surface area at this elevation so
that volume calculations can be verified.
Current Comment: Revise the stage storage calculations as including the
sediment storage in the volume calculations overestimates the volume provided,
per Wet Pond MDC 3. Note that the value provided in the calculations does not
correspond to the value provided in the Supplement-EZ, and the package will
need to be revised for consistency.
i. Note that revising the volume will result in a change to the average
depth.
ii. Note that the forebay storage depth was not clarified.
2. Consistency:
a. The application submitted on 8/29/23 was modified to include an additional
page. Due to inconsistencies in the page breaks, inserting the page provided in
the 12/11/23 into the Application leads to conflicting information within the
package. (Example, Section IV, 4, 7, 8, 10) To ensure a clear and consistent
presentation, the application's page breaks may need adjustment before revised
pages can be seamlessly integrated(recommended). Alternatively, with the
permission of the consultant and applicant, I can void the conflicting
information provided in the previous application. Indicate in the response to
comments letter which option to proceed with.

3. Supplement-EZ:
lx original Supplement-EZ Form and lx hard copy with the following corrections made:
(This item is required per Sections V& VI, 3 of the Application)
a. Drainage Areas Page, Line 12—For consistency, the pond's surface area should
either be excluded from the BUA breakdown on this line, or included in the
total BUA (Drainage Areas Page, Line 8).
b. Drainage Areas Page, Line 19—The provided calculations list the design storm
as 1 inch. (Refer to page 4 of the calculations provided by HFA dated 12/4/23.)
Revise for consistency. (Required per General MDC 1)
c. Wet Pond Page, Line 28 - The average depth of the main pool shall be three to
eight feet below the permanent pool elevation per Wet Pond MDC 2. Therefore,
8330.00 ft is not acceptable.
d. Wet Pond Page, Line 32—The volume of the forebay presented on this line
does not correspond with either the calculations or the plans. Revise the
package as needed for consistency. Note that per Wet Pond MDC 2, the volume
for the forebay shall be 15 to 20% of the main pool volume. If the pond has
more than one forebay, then the total volumes of the forebays shall be 15 to
20% of the main pool volume.
e. Wet Pond Page, Line 34—Revise this value to correspond to the value provided
in the O&M Agreement.
f. Wet Pond Page, Line 43 —This is the depth of the bottom of the forebay at the
entrance and the exit. Please revise to match the plans.
g. Wet Pond Page, Lines 32-34, 43-44—As the elevations and geometry of the two
forebays are distinct,please provide information for each.
4. Plans:
2x signed&sealed hard copies of a plan sheet are required per 15A NCAC 02H.1042
(2)(g) and per Section VI, 8 of the Application
a. It appears that upon resubmission of Sheet C9.3, the trash rack on top of the
riser structure was removed. While it is noted that side wall trash racks and pipe
guard grates are included, a top-mounted trash rack is still required. Per Wet
Pond MDC 10, a trash rack or other device shall be provided to prevent large
debris from entering the outlet system.
b. Due to changes that were made to the pond grading and geometry, the planting
plan needs to be revised. A planting plan is required for the vegetated shelf per
15A NCAC 02H .1042 (2) (i).
5. Calculations:
lx signed, sealed, and dated hard copy of calculations with the following corrections
made: (This item is required per Section VI, 7 of the Application)
a. The drawdown time could not be verified as the calculation method(including
equations and assumed coefficients)was not provided. This is required to
ensure compliance with Wet Pond MDC 7.
4. O&M Agreement Form:
lx original, signed& notarized hard copy of the O&M Agreement Form with the following
corrections made:
(This item is required per 15A NCAC 02H.1042(2)0) and per Sections V& VI, 3 of the
Application).

a. The pond was revised to include multiple forebays, please provide
information for the additional forebay in the O&M Wet Pond Summary, as
the sediment removal/clean out depths are not the same in each forebay.
5. MDC Requirements:
a. The depth of sediment stored in the forebays could not be confirmed from
the calculations or the plan sheets. Per Wet Pond MDC 3, the forebay and
main pool shall have a minimum sediment storage depth of six inches.
6. Provide PDFs of all revisions, 2 hardcopies of revised plan sheets, 1 hardcopy of
other documents, and a response to comments letter briefly describing how the
comments have been addressed.
a. PDFs must be uploaded using the form at:
https://edocs.deq.nc.gov/Forms/SW-Supplemental-Upload
b. Hard copies must be mailed or delivered to the following address:
i. For FedEx/UPS:
Brianna Holland
512 N. Salisbury Street, Office 640E
Raleigh,NC 27604
ii. For USPS:
Brianna Holland
1612 Mail Service Center
Raleigh,NC 27699-1612
iii. Hand Delivery:
Please reach out to me prior to hand delivering a submission to make sure
that I (or someone else in my group)will be able to receive the submission.
Do not leave the package in the foyer with the security guard.
NOTE: Hard copies should not be sent to a Regional Office. Doing so will
delay the review process and the submission package may be lost while
being sent from the Regional Office to me in the Central Office.
While not required to be addressed, the following was noted:
- Temporary erosion control measures are not reviewed as part of this permit, so
generally, sheets like C4.2, Erosion Control Phase II are not retained in the final
set of permitted plans. Only the permanent,post construction state is considered
within this permit. It is recommended to present information such as the
easement and maintenance access on a plan sheet that reflects the permanent
conditions of the site.
- A drawdown orifice should have a turned-down elbow in order to prevent trash
or other material floating on the surface from clogging the pipe.
- Emergency overflow spillways should be designed with hardened materials to
prevent structural failures.
- The Application Section II lb- la states that this project is "new" and not a
"modification to an existing state stormwater permit." Therefore, do not select
"not started"because this means that this application was a modification to an
existing permit where the construction was not started.
- The Supplement-EZ, Wet Pond Page, Line 53 has a typo.

To ensure a fair, timely, and transparent review process, any disagreement with provided
comments will need to be addressed in writing as part of the requested information
resubmission, within the required resubmittal window. The merits of the disagreement will
be reviewed during the next scheduled technical review and, if applicable, will be
addressed in further requests for additional information. If the resolution provided by the
reviewer is found to be unsatisfactory, the applicant can agree in writing to a longer review
period, during which the dispute will be brought to the technical review committee and a
final determination will be made.
Due to staffing limitations and to ensure an efficient project review, requests for individual
meetings to discuss provided comments are decided at the discretion of the reviewer. We
encourage you to carefully review the written feedback provided and the applicable
rules. The NCDEQ Stormwater Design Manual provides additional insight into design
criteria. Any questions or further requests for clarification should be submitted in writing
in the requested information resubmission, within the required resubmittal window. We
appreciate your understanding and cooperation in this streamlined process.
Please note that this request for additional information is in response to a preliminary
review. The requested information should be received by this Office prior to April 5,
2024, or the application will be returned as incomplete. The return of a project will
necessitate resubmittal of all required items, including the application fee. Please reference
the State assigned project number SW6230807 on all correspondence.
If you need additional time to submit the information,please submit your request for a time
extension to the Division at the contact below. The request must indicate the date by which
you expect to submit the required information. The Division is allowed 90 days from the
receipt of a completed application to issue the permit.
The construction of any impervious surfaces, other than a construction entrance under an
approved Sedimentation Erosion Control Plan, is a violation of NCGS 143-215.1 and is
subject to enforcement action pursuant to NCGS 143-215.6A.
If you have any questions concerning this matter please feel free to contact me at
[e-mail] or(919) 707-9218.
NOTE: Per Division policy, the next review of this application will be the final review.
Failure to provide the requested information will result in the project being returned as
incomplete. The return of a project will necessitate resubmittal of all required items,
including the application fee.
Sincerely,
6 4,,,,,,,,,- A„e e ca
Brianna Holland
Environmental Engineer
DEMLR Post-Construction Stormwater Program
cc: Fayetteville Regional Office