20060447 Ver 2_Reauthorization Response_20080826

Ola- 0tAL 77Y2_
Soil & Environmental Consultants, PA
11010 Raven Ridge Road • Raleigh, North Carolina 27614 • Phone: [phone] • Fax: [phone]
www.SandEC.com
August 26, 2008
S&EC Project # 4865.W9
DWQ No. # 06-0447, Ver 2.
Division of Water Quality
Attn: Ian McMillan/Annette Lucas
2321 Crabtree Boulevard
Suite 250
Raleigh, NC 27604
DWQ- Raleigh Regional Office
Attn: Natalie Landry
3800 Barrett Drive
Raleigh, NC 27609
Re: Reply to the Division of Water Quality's 6/17/08 and 7/18/2008 request for
additional information
Olde Towne Development -REAUTHORIZATION
Wake County, North Carolina
Dear Mr. McMillan, Ms. Lucas and Ms. Landry:
This letter is in i esponse to your letter dated June 17, 2008 and July 18, 2008 which
requested additional information for the proposed Olde Towne Development
Reauthorization. The following restates your questions/comments and is then followed
by our response.
Additional Infonnation Requested on June 17, 2008
The June 17, 2008 letter from NC DWQ stated "... 813 (PCN incorrectly reports 803
linear feet total stream impact) linear feet of stream (300 linear feet permanent perennial
stream impact, 114 temporary, perennial stream impact, 49 linear feet permanent,
intermittent stream impact and 340 linear feet temporary, intermittent stream impact... "
Our original application tables are correct and have been included here for your
reference. The above stream impact totals as listed by NC DWQ are identical to the
totals listed in our Stream Impact Table (page 8 of 18) which we have confirmed total
803 linear feet of proposed stream impact.
0 I R ?_ R
AUG 2 6 nn
DENR-%4 ,iL : '.
WETLANDS ANDi;O MWXfE BRANCH
Charlotte Office:
236 LePhillip Court, Suite C
Concord, NC 28025
Phone: [phone]
Fax: [phone]
Greensboro Office:
3817-E Lawndale Drive
Greensboro, NC 27455
Phone: [phone]
Fax: [phone]
REVISED STREAM IMPACTS REQUESTING REAUTHORIZATION
Stream Impact Perennial Average Impact

Number
or Stream
Length Area of
(indicate on Stream Name Type of Impact Intermitte Width (linear Impact
map) nt? Before feet) (acres)
Impact
UT to Walnut Road crossing-
P-7 (was P-3) Creek culvert & Perennial 1-2' 150' 0.0059
UT to Walnut Road crossing-
P-11 (was P-5) Creek culvert & Perennial +/_ 4' 150' 0.0144

P-9 (was P-15) UT to Walnut Road crossing- Intermitte
'
49,
0
0045
Creek culvert & nt 4-5 .

T-13 (was T-1) UT to Walnut Utility crossing
Perennial
+/_ 6'
31'
0.0044
Creek (temporary)

T-6 (was T-? UT to Walnut Utility crossing
Perennial
3'
31
0.0024
Creek (temporary)

T-7 (was T-8) UT to Walnut Utility crossing
Perennial
+/_5? ,
32
0.0036
Creek (temporary)
T-15 (new UT to Walnut Utility crossing Perennial +/- 3' 20 0.0014
impact) Creek (temporary)
T-16 (new UT to Walnut Stream Intermitte
'

impact)©
Creek Relocation

Y. I
nt +/- 2 340 0.0156
Total Stream Impact (by length and acreage) *803' 0.0274 temp.
/0.0248 perm.
©please note the impact table (sheet 2 of 16) shows the stream channel length to be 380 LF, the correct
length is the 340 LF listed here
* of the 803 LF of total impact length, 503 LF is temporary
1. Per the requirements of the Neuse Riparian Buffer Rule, you must
show that this site meets diffuse flow requirements with a level
spreader or other BMP per Chapter 8 of the BMP Manual (see
http: //h2o. enr.state. nc. uslsulbmp_ forms. htm).
In the original application submitted to DWQ on June 6, 2008, it was not clearly stated
that the proposed stormwater BMPs are constructed stormwater wetlands and therefore,
the direct discharge of the treated stormwater through the protected riparian buffer is an
allowable activity per 15A NCAC 02B .0233 (6) Table of Uses. The original application
package did account for the riparian buffer impact associated with the stormwater outfalls
for the proposed constructed stormwater wetlands (see pages 13 of 18 through 15 of 18
for an enumeration of stormwater outfall buffer impacts). Additionally, we have included
copies of the Stormwater Management Plans for the Olde Towne development which
detail the specifics of the stormwater treatment for the project. It should be noted that all
stormwater is directed to the appropriate stormwater devices and there is no "untreated"
direct discharge to any of the streams on the subject property.
2. Please provide detailed stream, wetland, pond and buffer restoration
plans per the DWQ Raleigh Regional Offices' NOV dated March 7,
2008. If it is not clear from the NOV as to where the buffer violation
occurred, then you must contact them directly to clarify.
The NOV dated March 17, 2008 from the DWQ Raleigh Regional Office (RRO) did not
require restoration of the pond and the wetlands. "Requested Response Item No. 3" in
the March 17th NOV required a sediment removal plan, which S&EC provided to the
DWQ RRO on April 15, 2008. The "Olde Towne Subdivision Revised Sediment Impact
Delineation Report, Clean-up and Stabilization Plan " was approved by the DWQ RRO
on April 15, 2008 (see attached letter signed by Mr. Danny Smith). The sediment clean-
up and stabilization was completed on June 24, 2008 (see attached S&EC Completion
Letter).
Additionally, as stated in our April 3, 2008 NOV Response letter, S&EC has been
engaged by Olde Towne, LLC to provide the NC DWQ and the USACE with a Stream
Stabilization plan as well as an "after-the-fact" permit request for the channel relocation.
The stream stabilization plan was supplied and approved in the above mentioned
documents. The applicant has requested a stream relocation approval for 340 linear feet
of intermittent, un-buffered stream channel. The applicant requested approval of the
conceptual design submitted in our original application package. At this time, the
applicant wants concurrence from both the USACE and the NC DWQ as to the proposed
relocation of the stream before moving forward with a full stream relocation plan (i.e.
pattern, dimension, and profile of the newly relocated channel). Once the applicant
receives concurrence from both the USACE and the NC DWQ as to the acceptability of
the relocation of the stream, S&EC will work with the applicant in the preparation and
submittal of the stream relocation documents for your review.
Previous discussions with Ms. Natalie Landry of the NC DWQ RRO have addressed the
alleged buffer violations. Namely, the previously approved buffer impacts are associated
with the constructed stormwater wetlands that will be utilized for stormwater
management. In other words, these are not in violation of the Neuse River Riparian
Buffer Rules but in fact, are in compliance with the DENR/DWQ Stormwater BMP
Manual. Additionally, these buffer impacts were re-requested in our reauthorization
submittal on June 6, 2008.
Ms. Landry also questioned temporary sediment basin No. 4 on the Olde Towne site (see
attached page from the approved Sediment and Erosion Control plan) which is located
next to the buffered tributary to Walnut Creek. We have included photo documentation
that the sediment basin outlet and level spreader are installed in accordance with the
approved sediment and erosion control plans. As evidenced by these photographs, the
buffer stakes are still in the ground (blue) which clearly shows that the level spreader and
the silt/tree protection fence is outside the riparian buffer by at least two feet.
Additionally, the site experienced a significant rain event (see attached rain gauge
picture) on 8/20/08 and there was no evidence of failure of the sediment pond or the level
spreader (i.e. no unauthorized, channelized/re-concentrated flow into the protected
riparian buffer).
Additional Information Requested on July 18, 2008 from DWO RRO
NOV Item I requested a description and quantification of impacts to
jurisdictional features and your plans to avoid further stream, wetland
and buffer impacts on your site.
a. Please explain why wetland impacts were not quantified in
totality as required in the NOV. Please note that if the purpose,
need and impact justification of this additional impact is not
explained, then the impact may not be authorized for wetland fill
and/or creation. Refer to Impact T-4 (page 6 of 18 PCN dated
June 6, 2008).
Impact T-4 is the wetland impact associated with the unauthorized relocation of 340
linear feet of un-buffered, unimportant channel. Our April 3, 2008 response did
acknowledge the impact, however, at that time, the amount of wetland impacted was not
known. We also stated in our response letter that our subsequent re-verification
application for the Olde Towne development would seek approval for the temporary
wetland disturbance.
Previous discussions with Mr. Monte Matthews (USACE) and Ms. Vicky Fuentes (NC
DWQ RRO) during the February 2008 site compliance visit and follow up
correspondence discussed the reasons and details for the relocation of the channel. The
location of the original channel was the boundary between the fairway for Golf Course
Hole #7 and a future irrigation lake (please see attached "Wetland Impact Map" from
previous Approval dated 2/20/2006) . Within this area there is a very large Carolina
Power & Light (CP&L) easement with overhead power lines. Since the date of the
original project Approvals, the irrigation lake was dropped from the project scope as
Progress Energy Carolinas (formerly known as CP&L) does not allow lakes or ponds
within their power line easements without prior approval (see http://www.pro rg ess_
energy.com/aboutenergy/transmission/carolinas/ritsofway asp, "Use Guidelines"). In
the interim, the City of Raleigh has required that the development provide a Public
Greenway Trail that is within the Progress Energy transmission line corridor. The stream
channel was relocated further to the west of the power line easement to allow for a
reconfiguration of the fairway and "tee-off' locations to avoid any potential injuries or
hazards to the public utilizing the greenway trails in the vicinity of the golf course.
b. The relocated stream length is described as 340 linear feet on
page 8 of 18 in the PCN and 380 feet on Sheet 2 of 16 dated June
6, 2008. This discrepancy is noted but not explained. Please
explain.
The impact maps provided by Withers & Ravenel contained a typographical error in the
impact summary sheet (sheet 2 of 16). The correct length of stream impacted at location
T-16 is 340 linear feet. We have confirmed this with the project engineer and have
included the correct length in the previously supplied impact tables.
c. New temporary impacts are proposed in the PCN dated June 6,
2008 (T-5) on page 6 of 18. this crossing is proposed to
temporarily impact 1455 SF of wetland, 20 LF of mitigable
channel, 1225 SF of Zone I and 830 SF of Zone 2. The impact
map does not show the actual placement of the waterline. While
the NOV requested your plans for impact avoidance, no impact
justification for this temporary impact was provided. Please
provide measures taken to avoid and minimize impacts.
In recent conversation with Ms. Landry regarding the above utility impact, it was
determined that the impact she is referring to is impact T-15, which is a new utility
crossing (see Sheet 6 of 16 submitted in original application). Over the course of the two
years since the original 404 and 401 Approvals, there have been design changes
associated with the Olde Towne Development. The Olde Towne property is better than
600 plus acres and the anticipated site build out is over the course of 10 years. Keeping
this in mind, some of the internal subdivision roads have been reconfigured, as well as
shifts of the utility lines that are servicing the property. For example, originally permitted
utility impact T-5 was dropped from the project as the City of Raleigh was not installing
the necessary sewer manhole on New Hope Road. Originally permitted utility impact T-
2 was also dropped from the original project as the City of Raleigh did not provide a
functioning manhole in the agreed upon location; therefore, the sewer line was able to be
re-routed through a non jurisdictional area.
In the case of impact T-15, which is located adjacent to impact P-3 (see Sheet 6 of 16
from June 6, 2008 submittal), the applicant was required to move the water line from the
original location (i.e. suspended from the proposed bridge) as the City of Raleigh will not
allow it. Therefore, the applicant was required to place the waterline utility outside of the
road right-of-way which necessitated the need for additional, temporary stream, wetland
and riparian buffer impact. Incidentally, the applicant could not locate the water line near
the sanitary sewer line (i.e. utilizing the same utility trench) as the Department of Health
will not allow sanitary sewer lines to flow in the same vicinity of public water supply
lines.
2. NOV Item 2 requested a Stream Restoration Plan.
a. Please explain the purpose, need and impact justification to
restore the previously impacted stream in another location (other
than its original location) or submit a final restoration plan to
restore the stream to its original location (pattern, profile and
dimension).
As was explained in previous emails and correspondence with both the USACE and the
NC DWQ, the location of the original channel was the boundary between the fairway for
Golf Course Hole #7 and a future irrigation lake (please see attached "Wetland Impact
Map" from previous Approval dated 2/20/2006) . Within this area there is a very large
Carolina Power & Light (CP&L) easement with overhead power lines. Since the date of
the original project Approvals, the irrigation lake was dropped from the project scope as
Progress Energy Carolinas (formerly known as CP&L) does not allow lakes or ponds
within their power line easements without prior approval (see http://www.pro,gress-
energy.com/aboutenergy/transmission/carolinas/ritsofway.asp, "Use Guidelines"). In
the interim, the City of Raleigh has required that the development provide a Public
Greenway Trail that is within the Progress Energy transmission line corridor. The stream
channel was relocated further to the west of the power line easement to allow for a
reconfiguration of the fairway and "tee-off' locations to avoid any potential injuries or
hazards to the public utilizing the greenway trails in the vicinity of the golf course.
Therefore, the applicant requested a conditional approval from both the USACE and the
NC DWQ for the conceptual stream design supplied in the June 6, 2008 submittal. Once
the location of the stream has been approved, then S&EC can move forward with
supplying the stream relocation plan, which will necessarily include the patter, dimension
and profile of the relocated stream.
b. Please explain how you propose to restore the filled wetland or
explain the purpose, need and impact justification to create a
new wetland to the function of the previously impacted wetland
(newly reported Impact T-4).
As discussed above, the wetland associated with the unimportant, un-buffered stream
channel was also impacted when the channel was moved. The reasons for the impact to
the wetland are the same as discussed above regarding the relocated stream channel. Part
of the conceptual design for the stream relocation includes a conceptual design of the
proposed wetland restoration. While the proposed wetland restoration is not in the exact
same location, for the reasons cited above, there ultimately will be more wetland restored
than was originally impacted (i.e. 1,294 sq. ft. impacted vs 1,750 sq. ft. restored). S&EC
will employ standard wetland restoration techniques which likely include some minor
grading, sediment removal and seeding with a wetland seed mix.
3. NOV Item 4 requested restoration of diffuse flow in the buffer.
a. Please describe measures taken to ensure the temporary basin is
constructed in accordance with the approved Erosion and
Sediment Control Plan and that the discharge is not
concentrated when it enters the buffer.
As stated earlier in this response, we have included photo documentation that the
sediment basin outlet and level spreader are installed in accordance with the approved
sediment and erosion control plans. As evidenced by these photographs, the buffer stakes
are still in the ground (blue) which clearly shows that the level spreader and the silt/tree
protection fence is outside the riparian buffer by at least two feet. Additionally, the site
experienced a significant rain event (see attached rain gauge picture) on 8/20/08 and there
was no evidence of failure of the sediment pond or the level spreader (i.e. no
unauthorized, channelized/re-concentrated flow into the protected riparian buffer).
Additionally, we have included the Approved Stormwater Management Plan (SMP) for
Phases 13-25 of the Olde Towne Development. The supporting documentation also
includes the preliminarily approved SMP for Tract SF-1 which includes Phases 26 - 31,
the Tract C-1 Residence Center SMP which is currently under review with the City of
Raleigh and the Stormwater Analysis and Nitrogen Calculations for the development.
These plans all discuss the drainage areas, percentage impervious and water quality
volumes associated with the SMPs. An overall Stormwater map has been provided to
better illustrate the different Tracts and Phases for the purposes of SMP approval. We
reiterate our request for a conditional 401 Approval, especially in light of the fact that the
City of Raleigh has approved the SMP for Phases 13-25 which is the location of the
majority of the site work that needs to be or will be under construction in the future. The
applicant understands that no work may proceed in other Tracts and/or Phases without
SMP Approval by the City of Raleigh and the submission of those approved plans to the
NC DWQ.
We anticipate that this documentation, coupled with the above supplied information and
explanation will satisfy any outstanding issues for the Olde Towne development. Please
let us know if there is anything further that we can provide you with or do for you in
order to assist in expediting the 401 Approval for this project.
Given the complexity of this project, reauthorization and violation resolution, we request
an inter-agency meeting at your earliest convenience to discuss the issues raised in your
request for additional information and our responses. We believe that talking through
these issues in person will be the most efficient method to resolve them. The applicant is
diligent in their effort to bring this project into compliance.
Please feel free to call me if you require any further explanation. .
Sincerely,
&ole Tho o
Regulatory Specialist
Attachments: 5 copies of Response letter
5 copies of Sediment Clean-up Approval (signed by Danny Smith, April 15, 2008)
5 copies of Sediment Clean-up Completion letter
5 copies of Approved Sediment and Erosion Control Plans for Temporary Sediment Basin #4
5 copies of Temporary Sediment Basin #4 outlet structure pictures
5 copies of 2006 Wetland Impact Map (marked up)
5 copies of overall Stormwater Management Plan Map
1 copy of Approved Stormwater Management Plan (Phases 13-25)
1 copy of Tract SF-1 Stormwater Management Plan (Phases 26-31)
1 copy of Tract C-1 Stormwater Management Plan (Residence Center)
I copy of Stormwater Analysis and Nitrogen Calculations
CC: Ms. Natalie Landry (NC DWQ Raleigh Regional Office) - all attachments listed above
Mr. Monte Matthews (USACE Raleigh Field Office) - all attachments excluding SMP documents
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y+ Division Or W:itLf Quality
April 15, 2008
(tilde Towne, LLC
Attn: Mr. Mark Bertoncino
5 Cameo Glass Way
Raleigh, NC 27612
Subject: DWQ Review of Olde Towne SubdiAsion Revised Sediment Impact Delineation
Report, Clean-up and Stabilization Plan
NOV-2008-PC-0158, Nvake County
Dear Mr. Bertoncino:
On April 15, 2008, the Raleigh Regional Office of the M C. Division of Water Quality received a Devised
Sediment Impact Delineation Report, Clean-up and Stabilization flan developed by Soil &
Environmental Consultants, PA for the Olde Towne Subdivision. The Plan is satisfactory with the
following additions.
1. Regarding removal of sediment from the open water pond, stabilize any land area disturbed by
mechanized equipment following completion of the sediment removal.
2. DWQ requests that Rebecca Peterson, P.E. be present at the site during the construction of the
rock toe protection and sill and periodically throughout the restoration and stabilization
activities.
3. D Q requests copies of recent documentation issued by the Army Corps of l nigineers for Olde
Towne.
4. DWQ requests a report within 30 days of completion of the Plan activities that includes
descriptive text of the completed activities and photos of restored and stabilized areas.
Should you have any questions regarding these matters, please contact Natalie Landry at (910) 7914200.
o
S fhcer y, F
army Smith ;/ ' S'
Regional Supervisor
Surface Water Protection Section
cc: Raleigh RO •-- Water Quality
Raleigh RO - Land Quality
Jahn Hennessy, KIPS Assistance and Compliance Oversight Unit
Water Quality Central Files
Monte .Mathews, USACOE. 3J31 Heritage Trade Drive, Ste 105, Wake Forest. NC 27587
C'-yndi Karoly, 401 OversightlExpress Review Permitting Unit
Patrick Paine, City of Raleigh, 222 West. Hargett Street, PO.B 590, Raleigh„ NC.' 27602
Nicole Thomson, S&EC, i 1010 Raven Ridge Road. Raleigh, NC 27614
Rebecca Peterson. S&EC, 110101 Raven Ridge Road, Raleigh, NC 27614
"war h Cari?tliQ t)rtision o. t1'ater Quulily ttaletSh Reponal e6 e Surface Wawr Protmtint, Phiuic (919) 791-4?' )0 i Costa V't SM1M
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Soil & Environmental Consultants, PA
11010 Raven Ridge Road • Raleigh, North Carolina 27614 • Phone: [phone] • Fax: [phone]
www.SandEC.com
July 25, 2008
S&EC Project No. 4865.D1
Ms. Natalie Landry
DWQ Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
Re: Olde Towne
Sediment Clean-up Completion
Wake County, NC
Ms. Landry:
This letter serves as notification of the completion of sediment removal activities at the
Olde Towne Development located in Wake County, NC. A sediment clean-up and stream
stabilization plan was implemented in response to observations made by the Division of
Water Quality (DWQ) and United States Army Corps of Engineers (USACE) as cited in
the Notice of Violations dated March 7, 2008 and April 14, 2008, and the Cease and
Desist Letter (Action ID #200620287) dated November 2, 2007.
Site Description
The project site, a proposed subdivision and golf course of approximately 547 acres, is
located east of Highway 440, along New Hope Road, between Poole Road and Rock
Quarry Road in the City of Raleigh in Wake County, North Carolina. A vicinity map is
provided in Figure 1.
Project History
Stream bank erosion of the impacted stream channel, overwhelmed existing Erosion and
Sedimentation (E&S) devices, and a lack of outlet protection resulted in deposition of
sediment within wetland and open water pond areas. Subsequently, a sediment clean-up
plan and stream stabilization Plan were developed by Soil & Environmental Consultants,
PA (S&EC) and approved by the Division of Water Quality (DWQ) and the U.S. Army
Corps of Engineers (USACE).
In April 2008, construction bean to relocate and stabilize the impacted stream channel,
and was completed on May 2" 2008. On May 5th and 6th 2008, sediment removal from
wetland areas was begun. On June 4th, 2008, lowering of the water level of the pond was
begun in order to remove sediment. On June 24th 2008, the final sediment clean-up
activities on-site were completed. S&EC personnel made frequent site visits to advise and
confirm that sediment was removed and disposed of in an appropriate manner.
On July 10, 2008; S&EC personnel visited the site to confirm successful completion of
clean-up activities, stream stabilization, and document site conditions. The areas of
Category 1 and Category 3 sediment were observed to be adequately removed. These
areas were seeded, along with the Category 2 areas, with the approved wetland seed mix.
Please see the attached photos for before and after photos of the site.
Please contact me if you have any questions or comments regarding this notification.
We thank you for your assistance and project input to date.
Sincerely,
SOIL &l
Rebecca Petersoi%,'
NC License No. 31
5.1'x`•.
TANTS, PA
/?/cu Ct C-?a I)GdU_
David Gainey
Environmental Assessment Department Manager
Cc: Ms. Cyndi Karoly, DWQ, 2321 Crabtree Blvd., Suite 250, Raleigh, NC 27604
Mr. Ian McMillan, DWQ, 2321 Crabtree Blvd., Suite 250, Raleigh, NC 27604
Mr. Monte Matthews, USACE, 3331 Heritage Trade Drive, Suite 105, Wake Forest,
NC 27587
Ms. Vicki Fuentes, DWQ, 3800 Barrett Drive, Raleigh, NC 27609
Mr. Patrick Paine, City of Raleigh, PO Box 590, Raleigh, NC 27602
Mr. Mark Bertoncino, Olde Towne Company, LLC, 5810 Cameo Glass Way
Raleigh, NC 27612
Attachments: Vicinity Map
Site Photos
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TEMPORARY SEDIMENT BASIN #4 AND OUTLET STRUCTURE
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Fig. I & 2: Temporary Sediment Basin #4 with skimmer and weir device (note it is dry despite significant rain on
8/20/08)

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Fig. 3 & 4: Photographs of the rain gauge on the Olde Towne site
Fig. 5 & 6: Photographs of outlet structures for Temporary Sediment Basin #4 per approved E&C plan

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Fig. 7 & 8: Photographs showing location of start of the Neuse Riparian Buffer (blue staking); outlet structures are set
well back from buffer area
Fig 9 & 10: Additional pictures showing locations for the start of Neuse Riparian Buffer (blue staking); note the
silt/tree protection fence is approximately 2 feet prior to start of Neuse Riparian Buffer

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Fig. 1 1 & 12: Photographs showing outlet structure and level spreading device per approved S&EC Plans; these
photographs also demonstrate no concentrated flow into the Neuse River Riparian Buffer
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