20180581 Ver 1_More Info Requested_20180621

Water Resources
ENVIRONMENTAL QUALITY
June 21, 2018
City of Raleigh
ATTN: Public Utilities Department
Mr. Ruffin Hall
222 West Hargett Street
Raleigh, NC 27601
Subject: REQUEST FOR ADDITIONAL INFORMATION
South Saunders Street Sewer Replacement
Dear Mr. Hall:
ROY COOPER
Gnre or
MICHAEL S. REGAN
.S""Ian
S. JAY ZIMMERMAN
Di" rf"
DWR # 18-0581
Wake County
On April 25, 2018, the Division of Water Resources (Division) received your application dated
April 16, 2018, requesting a 401 Water Quality Certification and Buffer Authorization from the
Division for the subject project. The Division has determined that additional information is
required to process your application, therefore this application (PCN) is on -hold until all of the
following information is received:
Impacts
It is unclear if the proposed work will occur within an existing maintenance corridor where
vegetation is currently removed and mowed or if work will occur outside the existing corridor
and a new maintenance corridor is being proposed to be aligned with the new sewer location.
Please clarify by providing additional information as to the location of the work in relation to
any existing maintenance corridor. Please revise the plans to show the existing maintenance
and new proposed maintenance corridor, if applicable. The Division is only concerned with the
maintenance corridors (existing and proposed) where vegetation will be/is removed to
maintain the sewer line. This area will likely be smaller than the area proposed to be sanitary
sewer easement.
Mitigation
It appears that some of the proposed work may require mitigation. If the proposed buffer
impacts are outside of the footprint of an existing, maintained, maintenance corridor, are
greater than 10 feet in width and are in Zone 1 of the buffer, the activity is allowable with
Stale of North Carolina J Envirotunental Quality I Water Resources
1617 Mail service Center I Raleigh, North Carolina 27699-1617
919 807 6300

South Saunders Street Sewer Replacement
D W R# 18-0581
Request for Additional Info
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mitigation. Specifically, the Neuse Buffer Rules (15A NCAC 02B .0233) states the following
regarding crossings and parallel impacts for Non -electric utility lines in the buffer:
Crossings
Perpendicular crossings that disturb greater than 40 linear feet but equal to or less
than 150 liner feet of riparian buffer with a maintenance corridor greater than 10
feet in width — allowable with mitigation
Parallel impacts
Impacts other than perpendicular crossings in Zone 1- allowable with mitigation
To clarify, the Division is concerned with new impacts (outside of any existing maintained
corridor) in Zone 1. These include crossings with a new maintenance corridor if the corridor is
greater than 10 feet in width in Zone 1, placement of fill such as rip rap or support piers (if
outside a 10 -foot maintenance corridor), and line placement parallel to the channel in Zone 1
that requires a new maintenance corridor. For example, sheet C2.6 shows riprap placement
outside of a 10 -foot maintenance corridor in Zone 1. This impact would require mitigation.
Please calculate the impacts that fall in the above described areas and revise the Buffer Impact
table on section 6 of the PCN to clearly show these. Bear in mind that if the maintenance
corridor (or rip rap placement, etc) is greater than a 10 -foot width at a parallel crossing, the
entire impact area must be mitigated for. If the maintenance corridor at a parallel crossing is
10 -feet or less in width and all other impacts are inside that corridor, then it is allowable.
Please see the Division's Buffer Clarification Memo: Non -electric Utility Lines (Other Than
Perpendicular Crossings) - When Notification or Mitigation is Required, for more information.
This Clarification Memo can be found on the Division of Water Resources' website at:
https://deg. nc.gov/about/divisions/water-resources/water-resources-permits/wastewater-
branch/401-wetlands-buffer-permits/401-riparian-buffer-protection-
program#BufferCla rification Memos
or contact our office for a copy.
The PCN states that payment will be made into a mitigation bank or in -lieu fee program for
unavoidable impacts (Section A. 1f.), yet the buffer impact table states that no mitigation is
required and the section of the PCN on Compensatory Mitigation (Section D.2.) is not complete.
Please clarify if mitigation is being proposed for the impacts and revise the PCN as necessary.
Avoidance and Minimization

South Saunders Street Sewer Replacement
DWRtt 18-0581
Request for Additional Info
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The Division has concerns about the permeant impacts of the manholes located in Zone 1 of the
buffer. Section D. la. of the PCN stated that efforts were made during design to site manholes
outside of buffer zones where possible and that more information was included in the cover
letter. The cover letter does not include a narrative of how the minimization was attempted
and why there are no alternatives to locating the seven (7) manholes of running the sewer line
parallel to the stream (sheet C2.4) in Zone 1 of the buffer. There appears to be practical
alternatives to locating some of the manholes in Zone 1 of the buffer. For example, on Sheet
C2.3, it appears the two new manholes and sewer line can be redesigned to cross the stream
approximately 5-10 feet to the southeast and avoid impacts to Zone 1 completely. On sheet
C2.4, it appears the sewer line and manholes can also be moved southeast to avoid running
parallel to the stream in Zone 1. On sheet C2.8, it appears the manhole on the north side of the
western stream crossing can be moved slightly north to avoid Zone 1 impacts. Please provide a
narrative of avoidance and minimization measures considered in the design and explain why
the practical alternatives described above are not feasible.
Also, please clarify that the stream impacts for the placement of rip -rap in the channel for
stabilization will be at the existing channel bed elevation and conform to the existing contours
of the channel banks.
Other
Sheet C2.3 shows a laydown yard on the southwest (top right) corner of the sheet. This
laydown yard appears to be in the buffer zone of the unnamed tributary to the northeast, but is
not listed in the impact table. Please clarify if this is a buffer impact and revise the PCN if
necessary.
Sheet C2.3 shows a riprap pad listed as 24 -inches deep and 40 -feet wide with impacts in Zone 1
and 2 of the buffer. Please clarify if this is a new impact or an existing impact. If it is a new
impact, please explain the purpose of the impact and note that riprap placed in the buffer is
considered a permanent impact.
Pursuant to Title 15A NCAC 02H .0502(e) and 15A NCAC 02B .0233(8), the applicant shall
furnish all of the above requested information for the proper consideration of the application.
Please respond in writing within 30 calendar days of receipt of this letter by sending one (1)
copy of all of the above requested information to the 401 & Buffer Permitting Branch, 1617
Mail Service Center, Raleigh, NC 27699-1617 OR by submitting all of the above requested
information through this link: https://edocs.deg.nc.gov/Forms/Supplemental-Information-
Form (please note that the DWR# requested on the link is referenced above).
If all of the requested information is not received within 30 calendar days of receipt of this
letter, the Division will be unable to approve the application and it will be returned. The return

South Saunders Street Sewer Replacement
DWR# 18-0581
Request for Additional Info
Page 4 of 4
of this project will necessitate reapplication to the Division for approval, including a complete
application package and the appropriate fee.
Please be aware that you have no authorization under Section 401 of the Clean Water Act for
this activity and any work done within waters of the state may be a violation of North Carolina
General Statutes and Administrative Code.
Please contact Paul Wojoski at [phone] or [e-mail] if you have any
questions or concerns.
�n ly,
Jeff Poupart, Section Chief
Water Quality Permitting
cc: Elizabeth Steffens, Dewberry Engineers Inc
USACE Raleigh Regulatory Field Office
DWR 401 & Buffer Permitting Branch file
File Name: 180581SouthSaunders5treetSewerReplacement(Wake)_401_NRB_Addlnfo