20060447 Ver 2_Mitigation Plans_20090805

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Soil & Environmental Consultants, PA
11010 Raven Ridge Road • Raleigh, North Carolina 27614 • Phone: [phone] • Fax: [phone]
www.SandEC.com
August 5, 2009
S&EC Project No. 4865.D2
Mr. S. Daniel Smith
DWQ Raleigh Regional Office
3800 Barrett Drive, Suite 101
Raleigh, NC 27609
Reference: Olde Towne Subdivision
Stream & Buffer Restoration Plan
Wake County, NC
Dear Mr. Smith:
AUG 5 2009
DENR - WATER QUALITY
WETLANDS AND STORMWATER BRANCH
Soil & Environmental Consultants, PA (S&EC), has been engaged by National City Bank
and Capstone Realty, Inc. to prepare this Stream & Buffer Restoration Plan in response to
the Settlement Agreement (Agreement) signed on June 10, 2009 by the North Carolina
Division of Water Quality (DWQ). The purpose of this letter is to describe in detail our
plan for the stream and adjacent buffer restoration, and the restoration of a small wetland
area impacted by previous site clearing and grading activities.
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 on Sheet 1 of the attached Construction Drawings.
Project History
On June 10, 2009 Capstone Realty, Inc. entered into an Agreement with the State of
North Carolina Division of Water Quality (DWQ) to resolve issues indentified in two
previous Notices of Violation letters dated March 7, 2008 and April 16, 2008. These
violations were further described in the Findings and Decision and Assessment of Civil
Penalties document issued on January 8, 2009. It should be noted that Olde Towne, LLC
was specifically cited in the above referenced violations. National City Bank and
Capstone Realty, Inc. have since assumed responsibility for the property and project.
Olde Towne Stream & Buffer Restoration Plan August 5, 2009
Soil & Environmental Consultants, PA Project No. 4865.D2
On August 26, 2008 S&EC prepared a letter to DWQ in which was outlined our concept
for the restoration of the impacted stream and wetland area. This concept was
subsequently approved by DWQ. Since the time of the Agreement S&EC was engaged
to prepare a plan to restore and relocate the impacted stream (686.8 square feet) and
wetland (1,733 square feet) area inadvertently impacted, and described in the above listed
letters. DWQ also required the restoration of a minimum 30-foot wide riparian buffer
along the restored stream reach.
Proposed Stream Restoration Plan
From our previous analyses of the site, topographic data provided by Priest, Craven &
Associates, Inc. of Raleigh, NC, as well as data from the Stream Restoration Institute
(SRI) Piedmont Regional Curve, we determined the typical repaired stream bankfull
dimensions for the restored stream reach. The restoration design for the stream was
based on recognized natural channel design principles and techniques utilizing the
appropriate reference data and the existing channel conditions survey data. Reference
data utilized in the design included the original (pre-impact) stream pattern and
approximate dimension, data from North Carolina Piedmont Regional Curve (SRI), and
other available sources. This approach was used to develop the appropriate dimension,
pattern, and profile for a natural stable channel for approximately 343 linear feet of
stream (686 square feet) parallel to the existing wooded wetland area. See the attached
Construction Drawings for additional details.
The implementation of our restoration design will result in an appropriately dimensioned
riffle-pool system. Meanders of varying radii (as captured from the original stream
alignment) were integrated along the length of the restored reaches to mimic the
variability of a natural channel and utilize the available project area to the maximum
extent possible based on existing site conditions. The integration of meanders into the
proposed restoration serves to reduce overall channel slope by increasing channel length.
The incorporation of riffles, runs, pools, and glides into the longitudinal profile will
provide the necessary bedform characteristics and be similar to those observed in nature.
Riffles will be located along straight segments of the channel, runs connect the riffles to
the pools that are located along the outside meander bends, and glides connect the pool to
the next successive riffle.
Based on concerns raised by DWQ the restored stream will be separated from the existing
wetland area (immediately to the east) through the construction of small earthen levee
running the length of the stream to the east. This levee will serve to reduce the potential
for a "draining" effect on the wetland area, an issue that was raised by DWQ. The levee
will however be constructed low in height to allow for flooding from overbank events to
discharge into the wetland area thereby providing supporting hydrology to the wetland
area.
Restoration of a suitable riparian buffer will enhance the recovery and protection of the
restored stream as well as the adjacent existing wetland system. A protected buffer
(minimum of 30 feet) will be restored on both sides of the restored stream reach as shown
Page 2 of 7
Olde Towne Stream & Buffer Restoration Plan
Soil & Environmental Consultants, PA
August 5, 2009
Project No. 4865.D2
in the plans. The buffer on the east side of the stream will tie to the existing wooded
wetland area and as such the planting width will be less than 30 feet. No buffer will be
restored in the immediate vicinity of the existing detention pond embankment however
stream bank planting will occur in this area. The wooded corridors that will be
established as part of this restoration will also increase the vertical and horizontal
structure perpendicular to the channel along the reach helping to increase species
composition and abundance. Additionally, the presence of a wooded buffer parallel to
the channel not only increases in-stream habitat quality by cooling water and increasing
oxygen content, it also provides cover, travel corridors, and access to adjacent natural
areas for upland and avian species.
In-channel Structures
In order to provide grade control for the restored reach, rock and log cross-vanes
and j-hooks (with or without steps), will be constructed to reinforce and stabilize
the proposed channel. The structures will protect the outside meanders from
lateral erosion, improve channel facets, and improve sediment transport.
All structures will be constructed of natural materials typically consisting of
quarried boulders (likely available on site) or logs. The upstream side of these
structures will be lined with a non-woven fabric where necessary and backfilled
with excavated channel material (and in some cases imported stone aggregate) to
improve stability and reduce the potential for piping. These in-stream structures
concentrate stream energy toward the center of the channel and away from the
near-bank areas. This reduces shear stress along the banks and prevents bank
erosion. In-stream structures also facilitate grade control within the bed of the
channel, reduce the potential of head cutting, create a stable width/depth ratio
(Wbkf /dbkf), and promote sediment transport capacity.
If deemed necessary at the time of construction NCDOT #57 stone or similar (on-
site natural) material will be added to the restored riffles in order to "seed" the
riffles and protect them from headcuts due to stream adjustments occurring after
construction completion.
Pump-around Operations & Erosion Control Measures
As DWQ has required that stream restoration efforts be phased in such a manner
that work is performed "in the dry" S&EC proposes the use of a pump-around
operation for the duration of the stream restoration construction. As described on
the Construction Drawings we propose the installation of a small, low-head
cofferdam at the upstream end of the restoration reach. This cofferdam will serve
to intercept natural flow from the contributing channel allowing for this flow to
by pumped into the existing stormwater pond to the immediate east of the
restoration reach.
Page 3 of 7
Olde Towne Stream & Buffer Restoration Plan
Soil & Environmental Consultants, PA
August 5, 2009
Project No. 4865.D2
One or more small low-head gravel check dams will also be installed (as shown
on the plans) to allow for the filtering of excess seepage leaving the construction
area. These check dams will be tied to the proposed perimeter temporary silt
fence serving to protect the adjacent wetland area from inadvertent damage during
construction. Dewatering pumps with Special Stilling Basins (DirtbagTM)
will be utilized as necessary during construction. The exact location and
configuration of the various components of the pump-around operation may vary
depending on conditions encountered during construction and as such may be
modified from those shown on the Construction Drawings.
As deemed necessary by the Engineer or the Contractor supplemental erosion and
sediment control measures (ie. silt fence, check dams, erosion control matting,
etc.) will be utilized. It is our understanding that works associated with the
described restoration will be performed under the existing City of Raleigh Land
Disturbance Permit and as such no new application will be made.
Bank Stabilization
Erosion control matting (CF-7 / C 125 coir matting) and temporary seeding will be
utilized to reduce bank erosion immediately following completion of the channel
and to provide bank stabilization. The restored channel banks will be planted
with native vegetation in the form of live stakes (of woody shrub species).
Erosion control matting (coir matting), temporary seeding, and live stakes will
reduce the potential for bank erosion immediately following completion of the
channel and provide bank stabilization.
Live stakes will be installed in two rows along both channel banks on 3-foot
centers. Species selection was based on a survey of the vegetation from the
upstream channel segment and from reference literature that details native
species. Planting details along with live stake species lists are provided on the
Construction Drawings.
Buffer Restoration
As previously described buffers adjacent to the restored stream reaches will be
planted with a mix of tree and shrub species. Buffer areas within the 30-feet of
the stream bank will be planted with randomly intermixed bare root seedlings
from a variety of woody tree and shrub species. We proposed planting to be
performed on 10-foot centers (approximately 435 stems per acre). Transplants
will be utilized where available and where deemed appropriate by S&EC.
Species selection was based on a survey of the vegetation from adjacent
undisturbed buffer areas and reference literature that details native species.
Species may require substitutions (with Engineer approval) depending on
availability of plant material. In order to achieve the highest survivability, bare
Page 4 of 7
Olde Towne Stream & Buffer Restoration Plan
Soil & Environmental Consultants, PA
August 5, 2009
Project No. 4865.D2
root seedlings will be planted between mid-January and mid-April. Planting
details along with tree and shrub species lists are provided on the Construction
Drawings.
Temporary and Permanent Seeding Operations
Temporary and/or permanent seeding measures (brown top millet, rye grass, or
the most appropriate erosion control grass as dictated by the season) will be
applied to areas disturbed during grading operations to allow for localized
stabilization while riparian species establish themselves. Switchgrass (Panicum
vergatum) will be planted in the restored buffer outside restored wetland areas,
and areas within restored wetland areas will be permanently seeded with a
wetland seed mix approved by the Engineer. A wetland seed mix will be applied
within the wetland restoration area. See the Construction Drawings for further
details.
Proposed Wetland Restoration
At the downstream end of the stream restoration a small wetland area will be restored.
This area will consist of approximately 0.04 acres and is similarly intended to offset
previous inadvertent impacts to a small wetland spur which previously existing at the
downstream end of the original channel alignment. Excess fill and other debris placed in
this area will be removed and the area described on the plans will be graded to its
approximate original grade based on observed site conditions. We anticipate that final
grading will closely match the adjacent wetland elevation. The restored wetland will then
be seeded with native wetland seed mix and over-planted with native vegetation with tree
and shrub species at densities similar to those describe above for the restored buffer area.
Further details are provided in the Construction Drawings.
Implementation Schedule
The attached Construction Drawings will be finalized (including any necessary review
comments) and "Issued for Construction" once Agency reviews have been completed and
the plan is approved. As required by the Agreement, restoration work will be completed
within 120 days of the review and written approval of this plan by both USACE and
DWQ. Based on experience with similar projects, we anticipate the construction work
(with the exception of proposed planting operations which will be delayed until the
appropriate season) can be completed (barring any inclement weather) within 60 to 90
days of the approval of this plan.
Project Completion Reporting
S&EC will perform a walk-through inspection of the completed project work to ensure
that the restoration was completed in accordance with our design intent. We will notify
DWQ and the U.S. Army Corps of Engineers (USACE) of the completion of project
construction within 60 days of completion as required by the Agreement.
Page 5 of 7
Olde Towne Stream & Buffer Restoration Plan August 5, 2009
Soil & Environmental Consultants, PA Project No. 4865.D2
Future Monitoring & Maintenance
Once stream and wetland restoration has been completed, the following monitoring
actions will be performed based on the items described in the Agreement:
1. Monitoring shall consist of a traversing the length of the restored stream/buffer and
wetland for the purpose of observing the condition of the channel bed and banks,
installed structures, and general vegetative success.
2. Monitoring stations (including photo points and vegetation monitoring plots) will be
established at select locations within the restoration area. A total of three (3)
buffer/wetland monitoring plots (1 Om x IOm) to evaluate bare root seedling success.
Two (2) buffer plots and one (1) wetland plot are proposed. Two (2) bank vegetation
monitoring plots (50 feet in length including left and right channel banks) will also be
installed to monitor live stake success. Monitoring plots will be installed upon
completion of construction and be located to represent general conditions within the
restoration area.
3. Monitoring of the existing adjacent wetland (to the immediate east of the restoration
reach) will be performed to determine if the wetland is being negatively affected by
the stream restoration (ie. draining, excess sedimentation, etc.). This evaluation will
be qualitative and consists of visual evaluation of the wetland surface and vegetation.
Shallow hand auger borings will also be performed along the wetland boundary to
evaluate existing soil conditions and hydrology indicators.
4. Monitoring will be performed for a period of five (5) years following the completion
of restoration construction. Visits will be conducted on a quarterly basis for the first
year and on an annual basis for the remaining four years of the monitoring period.
5. An annual report summarizing each quarterly visit (for the first year) and overall
success for the monitoring year will be submitted to DWQ by December 1St of each
monitoring year. This report shall include the date of each inspection, a qualitative
description of the condition of the restoration reaches, digital photographs of each
monitoring station, the results of vegetation monitoring, and describe any repairs or
corrections, including dates of completion.
Limitations
Our evaluations, conclusions, and restoration recommendations are based on project and
site information available to us at the time of this report and may require modification if
there are any changes in the project or site conditions, or if additional data about the
project or site becomes available in the future. This report is intended for use by National
City Bank, Capstone Realty, Inc., DWQ and USACE on this project. These findings are
not intended or recommended to be suitable for reuse on extensions of the project or on
any other project.
Page 6 of 7
Olde Towne Stream & Buffer Restoration Plan
Soil & Environmental Consultants, PA
August 5, 2009
Project No. 4865.D2
Reuse on extensions of this project or on any other project shall be done only after
written verification or adaptation by SOIL & ENVIRONMENTAL CONSULTANTS,
PA, for the specific purpose intended.
Please contact us if you have any questions or comments regarding this plan. We thank
you for your assistance and project input to date and look forward to the successful
completion of this project.
Sincerely,
TANTS, PA
Patrick . S ith,
N.C. License No.
Attachments: Construction Drawings (Preliminary), Sheets 1 through 13
Cc: Ms. Cyndi Karoly, NCDENR-DWQ 401 Oversight/Express Permitting Unit, 2321
Crabtree Blvd., Suite 250, Raleigh, NC 27604
Ms. Lauren Witherspoon, NCDENR-DWQ Raleigh Regional Office, 3800 Barrett
Drive, Suite 101, Raleigh, NC 27609
Mr. John Hennessy, NCDENR-DWQ Wetlands and Stormwater Branch, 1617
Mail Service Center, Raleigh, NC 27699
Mr. Monte Matthews, U.S. Army Corps of Engineers, Raleigh Regulatory Field
Office, 3331 Heritage Trade Drive, Suite 105, Wake Forest, NC 27587
Mr. Chuck Buttle, National City Bank, 2000 Auburn Drive, Suite 400,
Beachwood, OH, 44122
Page 7 of 7
- JUN 1 20

June 15, 2009
John R. Gassie
Vice President
20 N. Orange Avenue
Suite 1108
Orlando, FL 32801
RE: Restoration Agreement Olde Towne, Raleigh, NC
Dear Mr. Gassie:
Poyner Spruill LLP
H. Glenn T Dunn
Partner
D: 919.783.2842
F: 919.783.1075
[e-mail]
I am sending you the executed original Agreement regarding restoration of the stream at the Olde
Town development in Raleigh, NC. Please note there are certain deadlines for completion of the
measures required by the Agreement, beginning with submission of the restoration plan to the Division of
Water Quality within 60 days of the date of execution, which is June 6, 2009. It is my understanding that
the Consultants preparing the plan, S&EC, are already working on it and I will ensure they know the
deadline by sending a copy of this Agreement to Patrick Smith.
Please don't hesitate to contact me if you have any questions.
Regards,
H. Glenn T Dunn
Partner
cc: Charles Buttle
Patrick Smith
WWW.POYNERSPRUILL.COM RALEIGH / CHARLOTTE / ROCKY MOUNT / SOUTHERN PINES
301 Fayetteville Street, Suite 1900, Raleigh, NC 27601 P.O. Box 1801. Raleigh, NC 27602-1801 P: 919.783.6400
RALEIGH 5945570
STATE OF NORTH CAROLINA
COUNTY OF WAKE
IN THE MATTER OF
PROPERTY KNOWN AS
OLDE TOWNS
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL
RESOURCES, DIVISION OF WATER
QUALITY
AGREEMENT
The North Carolina Department of Environment and Natural Resources, Division of
Water Quality ("DWQ") and Capstone Realty, Inc. ("Capstone") (collectively referred to as "the
Parties"), hereby enter into this Agreement in order to amicably resolve matters relating to the
restoration of Class C NSW and Class WL waters at the site known as Olde Towne, previously
owned by Olde Towne Company, LLC, and located east of New Hope Rqad, north of Rock
Quarry Road and west of Barwell Road in Wake County, North Carolina. Olde Towne
Company, LLC, caused unauthorized impacts to surface waters and wetlands on the Olde Towne
property. These unauthorized impacts resulted in violations of State water quality standards,
specifically 15A NCAC 2B .0211(2) and (3)(f), 15A NCAC 2B .0231 (a) and (b) (1) and (b)(5),
and 15A NCAC 2B .0233(5), as well as violations of conditions of the 401 Water Quality
Certification ("WQC"), DWQ Project # 06-0447-Revised-2. The unauthorized impacts and
violations are specifically set forth in DWQ letters, dated March 7, 2008 and April 16, 2008, as
well as in the Findings and Decision and Assessment of Civil Penalties on January 8, 2009, to
Olde Towne Company, LLC, attached as Exhibits A, B, and E and incorporated herein by
reference. Capstone, which intends to acquire the Olde Towne property, without admitting
liability for Olde Towne's violations, hereby enters into this Agreement with DWQ to correct the
unauthorized impacts caused by Olde Towne Company, LLC by restoring the stream and
wetlands affected by the unauthorized impacts.
IT IS THEREFORE AGREED BY THE PARTIES THAT:
Capstone shall work in consultation with an environmental consultant to submit a
restoration plan ("Plan") and to secure approval for it and the required 401 Water Quality
Certification ("401 Certification") from DWQ for restoration of the impacted stream and
wetlands. Capstone will restore the stream and wetlands in accordance with the approved Plan
and the 401 Certification according to the schedule set out below. The schedule and conditions
of this Agreement are as follows:
A. Restoration. Within 60 days of the date of execution of this Agreement, Capstone shall
submit the Plan. Within 120 days from DWQ's and the U.S. Army Corps of Engineers'
written approval of the Plan and issuance of the 401 Certification and from the U.S.
Army Corps of Engineers' approval of the required §404 permit, Capstone shall complete
the required restoration. Within 60 days from the completion of restoration Capstone
shall submit written notification of the completion of the restoration to DWQ's Raleigh
Regional Office and its Wetlands and Stormwater Branch at the addresses set forth in
subsections (A)(1)(b) and (c) below. Minimum requirements of restoration activities
include the following:
1. Stream and Wetland Restoration All unauthorized impacts, which include stream
reaches that were excavated, grubbed, graded, and filled and wetlands that were
grubbed, graded, and filled at the subject Olde Towne site must be fully restored
so that the stream pattern, profile and dimension, and wetland hydrology and
vegetation are restored to the original configurations and functions or, in the
2
alternative, to acceptable configurations and functions subject to the approval of
DWQ. Alternative concepts presented by Soil and Environmental Consultants,
PA, in its letter to DWQ on August 26, 2008 and in a meeting on September 19,
2008, included a concept for a proposed restored stream (686.8 ftz) and proposed
restored wetland (1,733.2 ft2) alternative. DWQ has approved this concept and
has requested detailed designs for this alternative, which shall include a minimum
30-foot wooded riparian buffer along the length of the relocated stream, as part of
the required Plan. Capstone shall submit the requested detailed designs to the
following offices as part of the application package for the 401 Water Quality
Certification:
a. 401 Oversight/Express Permitting Unit, attention Cyndi Karoly, Mail Service
Center 1650, Raleigh, NC 27699
b. Raleigh Regional Office, Division of Water Quality, attention Danny Smith,
3800 Barrett Drive, Suite 101, Raleigh, NC 27609
c. Wetlands and Stormwater Branch, Division of Water Quality, attention John
Hennessy, 1617 Mail Service Center, Raleigh, NC 27699
If the property is sold by Capstone, Capstone shall provide to the new owner a copy
of the DWQ 401 Certification and a copy of this Agreement. The new owner, or any
successor in interest, is responsible for Capstone's obligations in complying with all
conditions in the approved Plan and the 401 Certification approval letter and in this
Agreement.
2. Restoration Sequencing. Capstone shall commence stream restoration efforts in a
phased/sequenced manner such that stream contour restoration is performed in the
3
dry. Sequencing design shall be submitted for approval by DWQ prior to the
initiation of restoration.
3. Written Notification of Completion of Restoration. Within 60 days of restoration
completion, Capstone shall submit a written report (including photographs) to
DWQ that includes the following:
a. A statement by Capstone and its consultant that restoration was completed in
compliance with the Plan and 401 Certification.
b. How Capstone determined that impacts were minimized in its restoration efforts.
c. How the stream, riparian area, and wetlands were fully restored or constructed, as
applicable.
d. The above-mentioned report of restoration shall also include a description of how
the original stream channel pattern, profile, and dimension were restored or the
alternative was constructed, as applicable, and how riparian areas and wetlands
were returned to approved grade, stabilized, and appropriately planted or seeded
to re-establish the proper vegetation, as applicable.
B. Post-Restoration Monitoring. To ensure that stability of the restoration is achieved,
Capstone shall monitor restoration at the site for a minimum of five (5) years at a
frequency of at least once every three (3) months for the first year and then annually for
the remainder of the monitoring period. Monitoring shall begin after restoration is
completed. A post-monitoring plan (stream, wetland, riparian area) shall be submitted as
part of the application package for the 401 Water Quality Certification to the 401
Oversight/Express Permitting Unit and the Raleigh Regional Office (please reference
addresses above in paragraph A(1)(a-b). Capstone shall monitor wetlands restoration in
4
order to determine whether wetlands have been drained by the relocated stream. If it is
determined that wetland drainage is occurring, the respective 401 conditions will require
the stream to be returned to its original location. Capstone shall submit written
documentation of monitoring results to DWQ's Raleigh Regional Office, attention Danny
Smith by December 1" of each consecutive year for the five-year monitoring period.
C. Monitoring-Triggered Repairs or Corrections. Following the completion of restoration,
in addition to any Division of Land Resources (or delegated local program) erosion and
sedimentation control compliance requirements and NCGO 10000 construction
stormwater permit condition requirements, if post-restoration monitoring reveals or DWQ
provides notification of degradation of the stream; unstable, eroding or rilled areas; or
dead plantings, Capstone must undertake repairs or corrections within 20 days of
observation or notification.
D. Erosion and Sedimentation Control. Capstone agrees that, during restoration and site
development activities, Capstone shall take the following actions:
1. Capstone shall comply with the requirements of the Sedimentation Pollution
Control Act (SPCA), including designing, installing, operating, and maintaining
erosion and sediment control measures in accordance with the most recent version
of the North Carolina Erosion and Sediment Control Manual (please refer to a
recent Notice of Violation from City of Raleigh - EXHIBIT Q.
2. Capstone shall comply with the requirements set forth in the National Pollution
Discharge Elimination System (NPDES) stormwater permit (NCGO 10000) for
construction sites (see EXHIBIT D).
E. Capstone expressly agrees that, during restoration efforts and during any additional site
development activities it shall make every reasonable effort to ensure that:
1. No unauthorized waste, spoil, solids, or fill of any kind occurs in wetlands, waters,
streams or riparian areas.
2. All restoration and construction activities, including the design, installation,
operation, and maintenance of sediment and erosion control best management
practices, are conducted so as to avoid violations of state water quality standards,
statutes, or rules.
G. DWQ agrees that it will not bring any enforcement action for violations identified in
letters dated March 7, 2008, April 16, 2008, and January 8, 2009 (see EXHIBITS A, B, &
E) unless Capstone fails to comply with any of the terms of this Agreement or fails to
take other reasonable measures to prevent further water quality standard violations at the
Olde Towne property. Any future water quality standard violations will subject
Capstone, or its successors in interest to possible enforcement action by DWQ, including
the assessment of a civil penalty of up to $25,000.00 per day for each violation for as
long as the violation continues.
H. Nothing in this Agreement restricts the right of DWQ to inspect or take enforcement
action against Capstone for any new or subsequent violations of water quality statutes
and the rules promulgated thereunder arising outside of the actions addressed within this
Agreement. Similarly, nothing in this Agreement shall restrict the right of Capstone to
contest an enforcement action for any such new or subsequent violation.
1. The deadlines in this Agreement may be extended if Capstone is unable to meet them due
to circumstances beyond its control. As soon as Capstone determines that it cannot
6
comply with a deadline due to such circumstances, it shall submit to DWQ a written
request for an extension describing the circumstances and the additional time needed.
Upon confirming the circumstances and need for additional time, DWQ shall revise the
deadline(s) in question as reasonably necessary.
J. This Agreement shall be binding upon the Parties, their successors and assigns, upon
execution by the undersigned, who represent and warrant that they are authorized to enter
into this Agreement on behalf of the Parties hereto.
F" C Division o ater Quality C o e al ,Inc.
;Oha Ropaessy b rt ?vY &R. Gassie, Vice-President
Division of Water Quality
Date: U4 0/6!)
Capstone Re ty, c.
Date: :Q?'n'q
7
LIST OF ATTACHMENTS:
EXHIBIT A: NOTICE OF VIOLATION AND RECOMMENDATION FOR
ENFORCEMENT - MARCH 7, 2008
EXHIBIT B: NOTICE OF CONTINUING VIOLATION AND INTENT TO ENFORCE
INJUNCTIVE RELIEF - Aril 16, 2008
EXHIBIT C: NOTICE OF VIOLATION from City of Raleigh - FEBRUARY 10, 2009
EXHIBIT D: NCG010000 FACT SHEET
EXHIBIT E: FINDINGS AND DECISION AND ASSESSMENT OF CIVIL PENALTIES
8
RALEIGH 020597/006 588890.3 05/14/2009
ENVIRONMENTAL Fax:[phone] May 13 '09 1031 P.03
xhtb;+ A WAr?
Q Michel P. Easley, C,a vew
North Cae+olina williatt, G.'1ta55 h„ ?txlrct?ty
p Colum IL Sint m, Direnor
Div!. of w4UF Qwlity
• . March 7, 2008
r' .MA,IL, #7006 0810 0002 6048 8015
MA-MED:
12ETCTRN 1ttECEIPT REOUE LUD
01de Towne, LLC
Attn: Mr. Rocky Keim
387 Medina Road, Suite 600
Mediae, Ohio 44256
Subject: NOTICE OF VIOLATION smd
RECONEMENDATION FOR ENFORCEMENT
NOV-2008-P"158
Wetland Project ## 06-0447 REVISED-2
Olde Towne, LLC
35.7445% -78.5561°W
401 Water Quality Certi
.fication Condition
Removal of Best Usage
Wetlands Standards
Other Waste (in pond sediment)
Neale Buffer- DDii use Flow
srormwater 00MMI Permit (NC6010000) Condition.
Wake County
Dear W. Keim:
On February 29, 2008, Lauren Cobb and Natalie Landry from the Raleigh Regional Office of the Division
of Water Quality (DWQ) conducted a site inspection for the tract/pmoject ]mown as 01de Towne 'an South
New Hope Road, Wake County, North Carolina. The streams on the site are an unnamed tn't ubW (1T7)
to Walnut Creek and unnamed UT to Big Branch, both Class C NSW waters in the Neuse River.Basin.
,Accordingly, the following observations were noted during the DWQ inspection and fHe review;
Mr. Seam Clark of Soil and Environmental Consultants, P.A. submitted a Pre.Constr'ucucn Notifieation
(P04) and supplant ntal information on or about 0311712006 on behalf of the property owner, Olde
Towne, LLC. • The impacts w= requested under U.S. Army Corps of Engineem Nationwide Permits 12
and 39 and the corresponding Genera] Water Quality Certifications, DWQ issued an approval for the
iuxpacts on or trbout 01/08/2007, DWQ Project# 06.0447, REV[SED-2.
The 401 Water Quality Cttrtifreation DWQ Prgjeci# 06-W7 authorizes a temporary utility crossing for .
42 linear foot of mum impacts to the UT to Walnut Creek. This is identified as stream impact number
T-4. The Certification also authorizes a temporary utility crossing for 76 linear feet of stream impacts to
the YJT to Walnut Creek This is identified as stream impact number T -S,
DWQ observations dining the 02/29/2008 site inspection show that approximately 330 linear feet of the
UT to Walnut Creek located in the northwest corner of the property and east of South New Hope Road is
Nw1h C mUna Divisiom of water Q wily Raleigh Regional office Surbwe Water Protection Phone [phone] custottler St. *e
Intanet; b2mearstucmus 1628 Mail Smviae Cmw limtei311. INC 27699-1622 FAX [phone].623•x748
M > qual Opporb-!ty/tittirmntive Ac8an Employer- 50% riecycied/10% Post Consww Papa
ENVIRONMENTAL Fax:[phone] May 13 '09 .10:32 P.04
Page 2
Otde Tbvma, LLC
walm Cowaty
relocated without prior DWQ approval. This segment of the UT is located below stregm impacts T-4 and
T-5 as depicted on the map' provided in tite PCN. `
Observations also include approximately 7,480 square feet of sediment deposition in wetlands, depths
ranging from approximately S-30 inches, located immediately downstream of the relocated UT to Walnut
Creek. located•in the northwest comer of the property laid east of South New Hope Road.
Observations also include approximately 5,815 square feet of sediment deposition in the
the soutlictrl pbition of the property just north of Rock lid mated in
27-36 inches. Quarry Road, depths ranging from approximately
Observations also include concentrated flow through the buffer of the UT to Big Branch for
approximately 54 feet, located in the southwest portion of the property, northeast of Rock Quarry. Road
and below a sediment basin.
The site inspection and file review revealed that the subject project has an approved Erosion and
Sedimentation Control Plan and is covered by a stormwater general petit (NCG010000).
A copy of the approved Erosion and Sedimentation Control Plan was not found in the inspection box on
'tile subject site. A min gauge was found on the.subject situ. Erosion and sedimentation control facility
monitoring records were found on site and reviewed by DWQ personnel at the time of the inspection.
As a result of the site inspection and file review, the following violations, described below, are noted;
L 401 WaUr QuHty C catioll Condition Violation
IL Removal of Best Usage
lie. wetlands Stsstdards
IV. Other Waste (=-pond saftment)
V. NeuseBuffer -DlffnseFlaw
VL Stormwater Grenersi Permit (NCGOloooo) Condition-violation
'rite I I water Quality Certification DWQ Project# Od-t)4R7 ED -2 approval letter specifies that
,the activities mmet follow the conditions listed in the (;eneral Water Quality Certifications, as we]I as
additional conditions listed in the letter. Based on site observations and the file review, violations of
conditions 1, 2, $ and •12 occurred on the Olde Towne property. These also represent violations of Ytenls
IT - VI below.
tem oval Best Us e
Relocation of the nhvm •_.Hannal id0LftI°- Dn=0-.a,, rT•,__a rr. ..
which requires that 6 The waters shall be suitable foraquatic lift PmpapCagatir?n sCa tign 2, ad I DA iv =& ? .021 Z (2)
biological integrity, wildlife, secondary recreation, and agriculture; sources of water pollution which
preclude any of these uses on either a short-term or IOU $4== bas . ' Please see the
section for details concerning how to achieve compliance at the site. ?d Response
Item III. Xetlamds Standanu
The observed sediment deposition in wetlands is in violation of I SANCAC 02B .0231 (b) which reads as
follows:
(1) liquids, fill or other solids or dissolved gasi may not be present in amounts which may CAW-,
adverse *4cts on exdstatg wetland uses;
ENVIRONMENTAL Fax:[phone] May 13 '09 1033 P.05
Page 3
Olde Towne, LLC
Wake County
(5) Hydrological conditions necessary to support the biological and physical chsracteristicS laaturally
present in wetlands shall be protected to prevent adverse impacts on:
(C) The chemical, nutrient and dissolved oxygen regime of the wetland;
(D) The movement of aquatic fauna;
(F) Water levels or elevations.
Item M. Other Waste (in-pond sedi ent
The documented in-pond sediment deposition is in violation Of 15A NCAC 02B .0211(3)f Which reads as
follows:
Oils; deleterious substances; colored or other wastes: only such amounts as shall not render the waters
injurious to public health, secondaryrecreation or to aquatic life and wildlife or adversely affect the
palatability of fish, aesthetic quality or impair the waters for any designated uses.
Items, Nepse Buffer - Diifise Flow
Diffuse flow was not maintained it the Neuse buffer in violation of I5A NCAC 02B .0233 (5) 'Which
reeds as follows:
Diffuse flow ofranoff shall be maintained in the riparian, buffer by dispersing concentrated flow and
reestablishing vegetation.
During the inspection, a copy of the approved Erosion and Sedimentation Control Plan was not on site
and available for review. This is a violation of General Permit NCooloooo, part I, Section A: No. 2,
which reads, in past, "During active construction, a copy of the appmved plan shall be maintained on the
site."
Requested Response
You arc directed to respond to this letter in writing to D WQ at the address provided below within 30
days ofreoeipt. YOU are also encouraged to secure a consultant who specializes in buffer, stream and
wetland restoration to assist you with the development and submittal of the following:
1. Documentation depicting all jurisdie6mal features (e,g. streams, wetlands, and buffers), .A
description and quantification of the impacts to those jurisdictional features and your plans to
avoid furthor stream, wetland, and buffer impacts on the site.
2. Stream Restoration Plan - Please explain how you plan to restore the pattern, profile and
dimension of the impaot+ed stream ohaanel to include the removal of card= $11 and restooraadm of
the riparian area. The strearnbed must be restored to the original profile and the stream banks
must be stabilized, The riparian zone must be restored to the original vegetation. Please see tho
Craidelines for Riparian Buffer Restoration (October 2004) for assistance in developing your plan
(available on the web at: http; /www nceepmet/newalreports/buffers.pdfl. Be suro to include the
types of native woody vegetation selected, methodology of planting and a site map indicating the
location of the replanting efforts.
3. Pond and Wetland Restoration Plan (sediment impacts) - Sediment impacts to the pond and
wedfind must be removed. As a part of this plan, you should provide the amount (depth) of
material that has been deposited in the pond and wetland. This iid'orniation should be depicted on
a map you provide. It is recommended that you use hand labor (buckets, shovels and
wheelbarrows) to remove deposited sediment from the wetland and the pond, The sediment
should be rcrnovvd from the pond and taco wetland, taken to high ground and stabilized, Also, the
plan must address the measures that will be lased for temporary stabilizatioWsediment control
WMIc this work is under way.
ENVIRONMENTAL
Page 4
Oide Tavmc' LLC
W.ke County
Fax :[phone] May 13 '09 1033 P.06
4. A Riparian Buffor Restoration plan to this office for review and approval. Please clearly indicate
the site conditions as they currently exist and how you propose to restore diffuse flow in.the
riparian buffer,
5. Pmrmit Application - if you wish for any impacts to remaim in place, you ram contact the U.S.
Army Corps of Engineers (USACE) and the DWQ to modify your cut=t 404 and 401 permits.
Please note that sediment impacts to streams, ponds and wetlands are not persnittable,
6. Provided a statermt that the Erosion and Sedimentation Control Plan is on-site and note where
ousite the plan is kept.
Include a detailed implementation schedule with dates explafniug when the stream, wetland, pond
and buffer restoration will be accomplished. This schedule Should include a three-year monitoring
plan to ensure that the stream and wetland are restored. It is important that you adhere to t
new plan once approved by AWQ. If you make any modifications to the approved plan, DWQ
must approve them prior to implementation.
Finally, Please explain how you propose to prevent these problems from reoccurring on future
projects.
Sabmit Reanested Items T,,.
Natalie Landry
DWQ Raleigh Regional Office
3800 Barrett Wve
Raleigh, NC 27609
Thank you for your attention to this matter.. This office requires that the violations, as described
above, be property resolved. These violations and any future violations are subject to a Civil
Penalty assessment of up to $25,000.00 per day for each violation. Should you have any questions
regarding theso matters, please contact Natalie Lmndry at (919) 791-420
tnc iy,
W't2"7 V.
Surface' S'V'ater Protection Section
or,. Raleigh Ro - Water Quality
Raleigh RO - Land Quality
TOM Hennessy, NPS Assistance and Compliance Oversight Unit
Water Quality Central Files
Monte Mathew T TOArr%t7 33
31Tmmse Trade Dnve, Ste105, Wake Forest, NC 27587
Cyndi Karoly. 401 OversightlExpress Review Permitting Unit
Patrick Paine, City of Raleigh, 222 West Hargett Street, POB 590, Raleigh, NC 27602
Nicole Thomson, SPEC, 11010 Raven Ridge, Road, Raleigh, NC 27614
ENVIRONMENTAL Fax :[phone] May 13 '09 10:33 P.07
wAp
?0
9Q h idml P. F"ley, Govamor
Q William C ROSS h., t3eo vwy
No& Carolina Dcpa umt of Fmirat=4 turd NshW Resouzvis
O ,? ?a Coleen A Sullins, Dbecw
Divisiovt of Water Quality
April 16, 2008
,CE1tt1' 7MD MAM #7006 0810 0002 6048 8060
R1E?TURN R ,C E PT REOUEt
Olde Towne, LLC
Attn: Mx. Rocky Keim
387 I&dina Road, Suite 600
Medina, Ohio 44236
Subject. NOnCE OF CONTINONG WOLATION and
l47E1V''r TO ENFORCE INJWCT.IW.Rj LIEF
NOV.2008-pC-0272
Olde Towne, LLC
35.74450N, -78.5561°W
Wetlands k4ndards
Removal oftiest Usage
Stormwater General ,Perrot (NCG010000) Condition
Wakc County
t ' Dear 1Vlr. Kelm:
On April 10, 2008, Lauren Cobb and Natalie Leary from the Raleigh Regional Office of the Division of
Water Quality (DWQ) conducted a site inspections for the but/project renown as Olde Towne as South
New Hope Road, Wake County, Ntxth Carolina. The sbumg on the site are an unnamed tnbutary (UT)
to Walnut Creek mrd a VF to Big Branch, both Class C NSW waters in the Neuse River Basin.
Accordingly, the following observations were noted during the DWQ inspection and f11e revim
X)WQ observations ding the April 10, 2008 site inspection show spproxbztely 850 square feet of
sediment deposition in'wtdmuh,.depths ranging firm approximately 2.18 inches, resulting from
construction activity, located north of sedi:alent basin #7 and P-1 Public Street "A" Crossing storm sewer,
This sediment deposition is in addition to what was noted in the first N'oticc of Violation (Nov) at other
loCIltiorts On the tract
DW'Q staff also observed and noted that the bank of the relocated stream continues to erode. The erosion
is reducing the distance between the stream and a stormwater pond placing the integrity of the pond wa11
in jeopardy of failure.
DWQ received a copy of a NOV issued by the City of Raleigh on Ap it 16, 2008. The NOV stated that
the subject site is in violation of failure to oWntain temporary and/or poimanent measures, faunae to.
provide protective erosion and sediment control measures and failure to provide adequate ground cover.
As a result of the site inspection and file review, the following violations, described below, are noted:
L Wetlands Standards
1[1. Removal of Beet Usage
North Carol(nn Division of Water Quality ital66 It40021 office 84d ke water Pmtection flow (919 791-420p Cali w Service
lntemet. h2o.ealt:s=-nc.ua 1628 Mail Savicc Cefltcr RAWAk NC 27699-1629 TAX (919) 571-+1718 1.877.b8 dUt
? ?9?1 dApOtaeniU?/A?Srmative AaGoa Enrpteyar- S119ti ttaeyelea/l Ot6 float Cooaumer Paper .
ENVIRONMENTAL Fax:[phone] May 13 '09 1034 P.08
Page 2
Wake T/oum, LLC
YY ?+ County a .

ill Stor mwater General Permit (NCGO10000)•Condidota Vul do' n
It m, L Wetlands S4pftds
The observed sediment deposition in wetlands is in violation of 15A NCAC 02B .0231(b) which reads as
follows;
(l) Liquids, fill or other solids or'dissolved gases may not be present in amounts which may cause
adverse impacts on existing wetland uses;
(S) Hydrological conditions necessary to support the biological and physical•chatacteristics naturally
present in wetlands shall be protected to prevent adverse impacts on:
(C) The chemical, nutrient and dissolved oxygen regimt of the wetland;
(D) The movement of aquatic &Ulm;
M Water levels or elevations. .
Item II. Removal of Best Usage
Relocation of the stream channel and degradation of the relocated stream charnel violates Removal of
Best Usage, specifically, ISA IXCAC 2B .0211(2) which requires that 'Mm waters shall be suitable for
aquatic life propagation and maintenance of biological integrity, wildlifo, saoondary recreation, and
agxiculture; sources of water pollution which precludo any of these uses on either a short-term or long-
tr.= basis."
Item M. Sformwater General Permit MG010000) Condition Violatlop
The City of Raleigh issued an NOV for failure to maintain temporary and/or permanent measures, failure
to provide protective erosion and sediment control measures and failure to provide adequate ground
cover. This is in violation of the Stormwater General Permit (NC(3010000) Part 1;1, Section C. No. 1.
Proper Operation and Maintenance.
Requested Response
You are directed to respond to this letter in writing to DWQ at the address provided below within 1a
days of receipt, You see also encouraged to secure a consultant who specializes in stream and wetland
restoration to assist you with the devglopmeut and submittal of the following:
1. Doeu tation depicting all jurisdictional features (e.g. streams and wetlands). A description
and quantification of the impacts to ALL jurisdictional features and your plans to avoid further
stream, wetland, and buffer impacts on•tho sit*.
2. Wetland Restoration Plan (aedinwut impacts) - sedim=t impacts to tha weds on the site must
be removed. As a part of this plan, you should provide the 4moumt (depth) of material that has
been deposited in all the wetlands. This information should be depicted on a map you provide. It
is recommended that you use hand labor (buckets, shovels and wbeelbarmws) to remove
deposited sediment from the wetland. The sediment should be removed from, the wetland; tin
to lush ground and stabilized. Also, the plan must address the measures that will be used for,
temporwy stabilization/sediment control while this work is under way. If additional jmIsdictional
areas are identified as impacted in the process of completing Item #1, include thcse iA the
restoration plan.
3. Provide a solution to the eroding bank of the relocated stream in the vicinity of the stormwater
pond. Stabilize the stream"bw* to protect the stormwater pond
4. Bxplam in your response when you anticipate being in full compliance with the approved Erosion
and Sedimentation Contftl Plan.
ENVIRONMENTAL Fax:[phone] May 13 '09 1034 P.09
Page 3
Olde Towne, LLC
Wake Conroy
Include a detailed implementation schedule with dates explaining wlten the wetland restoration will
be accomplished. It is important that you adhere to this new plan once approved by DWQ. If you
mske any modii'ications to the approved plan, DWQ must approve them prior to impleMelltatlon.
1?1=11y, please explain how you propose to prevent these problems from reoccurring on future
projects.
Sub t nested Items To:
Natalie Landry
DWQ Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
Thank you for your attention to this matter. This office requires that the violations, as described above,
be proporly resolved. These violations and any future violations are subject to a civil penalty assessment
of up to $25,000.00 per day for each violation. This office is considering forwarding a civil penalty
recommendation for awessmmt consideration and proceedings with injunctive relief procedures through
the Attorneys Generals Office. Your response to this matter will be considered in this process. Please
respond within 15 days of receipt of this notice. Should you have any questions regarding these math,
please contact Natalie Landry at [phone].
Danny
gl upervisor
Surface Water Protection Section
cc: Raleigh RO - Water Quality
Raleigh RO - Land Quality
Joim Her?uessy,14PS Assistance and Compliance Oversight Unit
w9a Quality Central Files
Monte Mathews, USACOE, 3331 Heritage Trade Drive, Ste105, Wake Forest, NC 27587
Clmdi Karoly, 401 Oversisbt(Exprew Review pernut6ng Unit
Patrick Paine, City of Raleigh, 222 West Hargett Street, POB 590, Raleigh, NC 27642
Nicole Thomson, S&P-C. 11010 Ravers Ridge R,4 Raleigh, NC 27614
Mark Bertoncino, Olde Towne LLC, 5810 Cameo Glass Way, Raleigh, WC 27612
s' C r
ly,
? 'o S
ENVIRONMENTAL Fax:[phone] May. 13 '09 10:39 P.10
ExN V%+ C

February 10, 2009

"&1?? (/ U'lr?Yl
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Olde Towne Company, LLC Bradley Harrold, Agent
Property Owner Olde Towne Company, LLC
5810 Cameo Glass way 3323 Alamunee Drive
Raleigh, NC 27612 Raleigh, NC 27609
Rocky Xeim, Financially Responsible Party
Olde Towne Company, LLC
5810 Cameo aim Way
Raleigh, NC 27612
Reference: Notice of Violathm
Project Name: Olde Towne
Permit No.: LD-35033 & 23140
Transaction No.: 2]4550& 146389
ln'spection Date: 01/30/09
Dear Property Owner and I=inanelally Responsible Party:
Per the attached Compliance Inspection Report, an inspection of the above referenced site
revtalcd violations to Section 10-5007(x) of the Raleigh City Code! Chapter 5 which states 1hei:
"DUPin& the develaptnernt of a site, tiny person undertaking the land-disturbing
activity shall insmll and maintain all ?emporary and permanent erosion and
sedimentation control measures as required by the approved plan, any provision
of this chnpmr, the *t, or any order advpred p:jrsuanr to his chapter or the
Ornags • 222 WEST MIAPGETr STREET • POST OFFICE BOX 580 RALCIIIN. r toFTH GARCKJNA VG02
RtrVCLCO PAPER
ENVIRONMENTAL Fax:[phone] May 13 '09 1039 P.11
Notice of Violation
Permit No.: LD-35033 & 23140
1~ebmary 10, 2009
Page 2 of 3
The person responsible for the violation is defined endear Section 10-5003 as:
"(a) One developer or any other person who has or holds h 6se)f our as hav;'rig
financial ar operattonul control over the land disiurbing oclZily. or
(b) The landowner or person In possession or control of the land when lie has
dfrt'clly or this chapter, benefited from it or he b. failed to comply with any
of- provision the act, or orry order adopted pursuctnt ro this chapter
or the act that ithis chapter,
hmpales rr duty upon him.- "
7110 attached Compliance Inspection Report details the specific violations, the required remedies
and the time period in which remedies must be completed. 1 a"= to comply with this Notice
of Violabon and the indieatedremedies will r
civil esell yn civil penalties. The violator is subject to
penalties per day of continuing noncorppliance, - If the required Immediate Corrective
Actioas are not completed witixla the specified time, the specific civil penalties and daily
fines 'Will be assessed for each day of eontinning violation [Raleigh City Code, Section I 0--
5014(a)(1 1)). Nola-compliance could also result in One or more of the following
enforeenient actions.,
1. Denial_ofPerrmits anchor Ins miens -No permits shall be issued to airy person who
has failed, afRer notice, to rernedy any violation or to otherwise coin-ply with the
Raleigh City Code.
2. Criminal PMal ies - The violator could to guilty of a misdemeanor punishable by
imprisonment not to exceed 90 days or by a fine not to exceed $5,000, or both, in the
discretion of the court [Raleigh City Code, Section 10-5013(c)),
3. latlunctive Relief - Whenever the Raleigh City Council has reasonable cause to
believe that any person is violating any provision of the City Code or approved
erosion and sediment control plan, the City may institute a civil action for injunctive
relief to restrain the violation. The institution of the action for injunctive relief
would not relieve any party from any civil or criminal penalty described above
(Raleigh City Code, Section 10-5033(d)).
d ECI 11 -_5ubdivider's Forfeiture - Failure by the subdivider to correct any
violation shall result in forfeiture of any and all reimbursements stated in Section 10-
3022 of the Raleigh City Code.
ENVIRONMENTAL Fax:[phone] May 13 '09 10:40 P.12
Notice of Violation
Permit No.: LA-35033 & 23140
February 10, 2009
Page 3 of 3 ,
If you have questions concerning this Notice of Violation and associated Compliance Inspection
Report, or you prefer to propose alternatives m the required Immediate Corrective Ammons listed
on the attached Compliance lnspcotion Report', pleasc cotttaet me immediately. I can be reached
at [phone].
Sincerely,
Jeanette Powell, CPESC, CPSWQ
Stormwater Compliance & Inspections Program Supervisor
enclosure
cc:
Natalie Landry, DWQ
David Olenik, davidm1mik ct naponalcitv.com
Charles Buttle, char1e .butt! bnslci .coin
Nathan CWe, tdae.nsthan tai veriwn.net
Carl Dawson
Danny Bowden
Zayda Esquivel
Mark Senior
Ben Brown
Project File
ENVIRONMENTAL Fax:[phone] May 13 '09 1040 P.13
PROJECT 01de Towne
5205 Rock Query Rd •
PERMIT 4 LD- 35033 & 23140
TRANSACTION T# 214550 & 146389 '

COlVV>G.IANCE
xi?rsr»c?ox Chris Bridgers, CESSWI
_T
..,.?.,»
yW,•,~ INSPECTOR rai cs? ??o_n x s
[phone] 01130/09 11:00 AM
NOTICE OF V101LA'ION
The City of Raleigh, Stormwater Management Division has performed a stormwater permit compliance
inspection of this project and found the following violation(s) of the land disturbing permit,.associated
approved plans & specifications, and/or the Raleigh City Code. See Immediate Corrective Actions
listed below for required remedics.
12 FAILURE TO MAINTAIN TEMPORARY ANDIOR I'lR Y1ANL+'NT WABURES
[SECTION 10-5007(8)]. Civil penalty: $2,500.00 [Section 10-3014(a)(6))
? FAILURE TO PROVIDE PROTECTIVE EROSION & SEDIMENT CONTROL
MEASURE ISE' CrrON 1&5006(a)('? & SECTION 10.5009(a)]. AecrJerated erosion and/or
oil site sedimentation has resulted from leek of adequate protective measures. Civil Penalty:
$5,000.00 [Section 10-5014(s,)(3)]
FAILURE TO PROVIDE ADEQUATE, GROUND COVER [SECTION 10-SO'06(s,)(7) &
SECTION 10-5009(a)1. Accclerated erosion and/or off-site sedimentation has re$Wted fmm lack
of adequate ground cover.
Civil Penalty: $2,500.00 for sites over I acre [Section 10-5014(a)(9)]
? Civil Penalty: 51,200.00 for sites I acre or less iSectioia 10-5014(a)(9)]
ID FAILURE TO FOLLOW APPROVED EROSION AND 8RDIMIENTATION CONTROL
PLAN [SECTION 10-50111. Civil Penalty: $3,000.00 [Section 10-5014(a)(4)]
MOMIAMP In Orliaaa F" 1020
Rev 3; .Ian 7008
Page 14f l..
ENVIRONMENTAL Fax:[phone] May 13 '09 10:40 P.14
?DMTE COPIREGT'IV ACTIONS
I - • h%lutain temporary ezd/or permanent measures:
i. Maintain silt fence per approved plans and/or City of Meigh standards (Standard
Detail Drawing #0.02). At a minf cum, removal of sediment is required When
sediment has accumulated to a mwdmum depth of one Wf the height of the silt
fence. Silt fence repairs arc ueeded. at multiple locations around the perimeter and
buffered areas throughout the site,
H. Maintain Wet protection per approved plans and/or City of Raleigh standards
(Standard Detail Drawing #4033); Maisttenance should include removal of.
accumulated sediment. Sedi m=t needs to be removed from around the inlet
protection at multiple catch basins throughout Abase 13-25.. Additional #57 stone
is needed around the hardware cloth at multiple inlets, Sec Photograph 1 below,
in. Maintain sediment basins per the approved erosion and sediment control plan.
Ptestore skimmer at DP #6. See pbotograph 2 below,
2. Vegetative growth sufficient to restroin erasion has not been aohioved at mul4ple ureas throughout the
site. Under Section 10-5006(a)(3), any portion ofa site upon which further land disturbing activity is not
being undertaken within twenty-one (21) calendar days must be stabilized with ground cover sufficient to
restrain erosion
3. Install all temporary and/or permanent measures per the approved Erosion and Sediment
Control Plan.
4. See comments section below.
REITSPEM ON WML :OCCUR IN TEN (10) DAYS '
'=.PR4WE1 CT-'V? L SPLC'#` > -0
,. ,, :.. ,. , Ql !'1C ly[•CORECTIbN OF e1 .
V.1 -TIONS I Ill IlVJ?I?7, xlo; 001 C : AC ONS LISTED ABO'V ?
Failure to remedy the listed IkAedin Corr`ectiiv'e Aci oils '/,violgf on(4) pricy to rew9aofian will
result in penalties for a continuing violtitiom -.These 0;mWfies shop include an initial penalty as
;yell as retroactive and cumulative difly eta peilal es assessed from the date of this inspection
until the violation(s) are remedied and fonnd'to -he in to=?Onace [Raleigb City Code, Section 10-
CONVWXNTS:
1. If the site is to remah4 inactive for twelve mostias or longer, the temporary measures must.be
removed, the site stabill ud and the permit closed out. 4
WF'TEM?'- 45 °F Sunny
'PR03ECT STATUS; Site remains inactive, temporary and permanent measures are in need of maintenance.
OTHER ACTIONS:
S?»rmtcivlorlRSp?eiley,sFe,a;, ld3
• J?ri+r ?AtJB
PaYr:?I3
ENVIRONMENTAL Fax:[phone] May 13 '09 1040 P.15
1. do-site review of this report was X wes not performed.
2. Photo-documentation X was was not performed.
GENERAL ]N>?ORMATION:
Standard Detail Drawings pre available at www, ralsikh-m nrst under Publications, Public Works
• City of Rakish Municipal Code is available at
h?•! www unicade comlltesourceslC ieatCodo,?,' t Asp7c»?Jtttleigh&sid@33&+cid?4003
stcrie"rwtr fRSprcnwrs !•on? t p3
Jaw ?01W
Nest 100
PHDTOCRApu it Restore inlet protection at multiple cateb basins
throughout phase 13-M (photo typical of general site randidans).
1PHOTOGRAPH 1: Skimmer is not able to fuactloh properly stuck in the mud
At DP K
ENVIRONMENTAL
Exh?) bitD
Fax:[phone] May 13 '09 10:41 P.16
North Carolina Department of Environment and Natural Resources
0! "n'F9Pt? NP-DES Stormwater Discharge t
for Construction Activities
Cover Sheet for NCG010000 Last K"ed 10/20/2008
What is it?
Did you know?
In North Carolina,
excess stormwater
volumes and, Wax-
kets of sediment
covering aquatic
habitat cause more
streams in the state
to lose their ability
to support aquatic
life than any other
pollution problem].
rti„ t
.$i` r (r,.•?tk?zj
This is your Stormwater Permit. It is
separate from your Erosion and Sedi•
mentation Control (E&SC) Plan.
Your project is subject to this permit in
addition to tLe approved E&SC Plan
because all construction activities dis-
turbing 1 or more acree of land are sub-
iect to stormwater permitting reguire.,
meats under the National Pollutant Dis•
charge Elimination System (NPDES).
You have been given a copy of General
Permit No. NCGO10000 (attached) and
granted coverage under this General
Stormwater Permit,
Why is this permit required,
and why is it important?
Federal regulations adopted by the U.S.
Environmental Protection Agency (EPA)
and North Carolina Division of Water
Quality (DWQ) require an NPDES
permit for your project. The EPA has
delegated DWQ authority to administer
the NPDES program in North Carolina.
You must comply with the applicable
terms and conditions of this'Stormwater
Permit, and you are subject to enforce-
ment by the Division of Water Quality
for any violations.
In just one rain
event, poor
erosion & sedi-
ment control
practices can
contribute
nearly a ton of
sediment per Saftwabfihedceehdwm-
aofv to a 6"M of a eauavetlen alm
streams. That can cause long term
devastation to receiving waters!
So remember, compliance with this per.
mit helps protect our lakes, 'streams, riv-
ers, and coastal waters,
'From,f'vl/xlaWA%7vn• from rarlokt;Iana UM is me
tlpOrNtmeBivaausm (Line, D=W E. et a1.) a a
DWQ staff COmommication whh iiathm Aow tfie
study.
What does this permit require me to do?
You should read and become familiar es
with the provisions and cogditions of
this permit, Here are highlights:
You umuet implement the Erosion and
Sedimentation Control Plan approved
for your project by the N.C. Division of
Land Resources MR) or by an ap-
proved local program. Adherence to
tit E&SC Plan is an enforceable
component of the Stormwater Permit,
'From the PmAJ*oh C'm»fisa wo&r Quarity
Augp-w and hwaimd W imnI.iaYmu 7nte.
gated 30s(b) and 303(4) Report).
• You must inspect all erosion and
sedimentation control facilities at
least once a week. If you dia.
charge to certain impaired waters,
you must inspect these facilities
twioe a week (see permit). Im-
paired waters on the latest EPA
approved 303(d) list as a result of
construction•related parameters
can be found here:
httri:11h2o enr.statejLqnnlcnf
mnstxuflion.303d
You must inspect all E&SC fadh-
ties within 24 hourA sft*r 4kuy
storm 4vemt greater than a half
inch (during a 24-hr period).
• You must observe runoff at your
stormwater oudalls just as often as
above for characteri$tica listed in
the permit (clarity, solids, etc.).
You must keen. records of these
You must provide the operation aid
maintenance (O&M) necessary to
maintain optimal perfoAnancs of
Stormwater oonirde• This means
tale oorrcctivo action if E&SC
facilit d, &M not opoxat3ng ps`4pP;lyi
ENVI RONMENTRL Fax:[phone] May 13 '09 10:43 P.17
PAGE 2 NPDES STORMWATER DISCHARGE PERMIT COVER SHEET FOR NCGOI0000
What does this permit require me to do? (cont.)
O&M includes things like: herbicides, pesticides, and ferdliz.
? Regularly cleaning out sedi- erg.
mentation basins You must properly dispose of
? Stabilizing eroded banks or demolition debris and other build-
spillway structures ing material
? Repairing/clearing out inlets • You must properly manage dia-
and outlets
? pose, of litter and sanitary waste.
Repairing piping, seepage, me-
chanical damage
? Repairing silt fence damage
Sift Iwke maintenance
Take compliance seriously? Projects

Regular inspections are a chance to
OEM= that violate Stormwater l?errmit con.
ditions and/or have unauthorized
check impacts to nearby waters. If

you observe eienificant Amounts of

You must prevent stormwater con-
water quality impacts are subject to
:limes. Civil penalties•of up to
sediment in the stream, notify tamination from equipment used $25,000.00 per day for each viola.
the DWQ regional office within during construction. This includes tion may be assessed.
24 hours and provide written no. preventing spill$ of oil, fuels, 0001-
tice within 5 days (See Part II, Sec- anw, hydraulic fluids, W.
tion E of the Permit). Please copy You must follow fadaral guidelines
correspondence to DLR. and label restrictions when using
What do 1 need to Who inspects me form inspection as well.. These

keep on site?
for what? inspections may be routine in na-
ture, or t'he result ofpviblic com-
plaints or problems reported by
Copy ofthe approved E&SC DWQ coordinates with the Division DLR.
Plan, including any revisions of Land Resources' Land Quality ?NC DLR (or a delegated local pro-
A rain gauge Section to ensure compliance with gram) will inspect the site for
Records of rainfall amounts NC Rules and Regulations regard. compliance with your approved
and dates ing construction activities and their E&SC Plan.
? Records of E&SC facility/Best impact on water quality. That ? NC DWQ investigates complaints
Management Practice (BMP) means your operation is subject to and inspects for adverse impacts
inspections enforcement by both Divisions. to water quality and stream stan-
? Records of stormwater dis. dard violations (suc. as sediment
charge out£all and stream in. In general, DLR staff will be in. in the stream).
spections/observations. (See spectiug your site on a regular ba- ? NC DWQ may inspect the site for
attached example log sheet). sis. However, DWQ staff may per. compliance with this Stormwater
Permit.
Do I need to file a Who can help me with questions?
Notice of Inten t (Nt'?1)?
Questions about Stormwater Permit re quirements can be ad.
ii
No. Once your dressed to the Division of Water Quality Regional Offices:
gV roved. you are automatically
covered under NCO010000, and you ville a (gam) 296-4500 Washin
gton Office........
do not need to file an NOI for a Cer. Fayrtwv& Office...... [phone] •Wgwhoon Office........ [phone]
tificate of Coverage (000) from
DWQ. However, if you do not wish MoorcriMe Office......
[phone]
Winston-Salem Office.... (336) 7714000
to be covered by this General Rakish Off= ...••.••.. (919) 7914200 Central Office [phone]
Permit, you must apply to DWQ for
an individual NPDES Storsuwater
Permit. or more kfamation about tbz Progame of the Division of Wata (2uality?s
Sta mwater FamIMS Unit, see ow home page at
?? ??1LZO.CIrY.3TOtC.7?C.W Jsr<Jrromlwatchaxi

ENVIRONMENTAL Fax : [phone] May 13 '09 10:44 P.18

STATE OF NORTfi CAROLINA,
COUNTY OF.WAKE
IN. THE MATTER OF ) .
OLDE TOWNS COMPANY', LLC )
FOR VIOLATIONS OF '
15A NCAC 2B 0211(2)
NORTH CAROLINA DEPARTNT OF'
ENVIRONMENT AND NATURAL'
RESOURCES
CASE NO. PC-2008-0048 - • • .
P'MINGS AND DECISION
AND ASSESSIVlENT OF
CIVIL PENALTIES
.Water Quality Certification, Condition of
DWQ # 06-0447 Revised-2
I SA, NCAC 2B.0231 (a) and (b)(1) and (5) )
15A NCAC 2B.0211 (3) (f) )
Actitg pursuant to Nortb Carolina General statues (hereby known as G.S.)143-215.fA, I, Joan
Hennessy, of the Division of Water Quality (hereby 1a10wn as DWQ), make the following,
I. • FINDING OF FACT '
A: 01de-Towt o Company, LLC is the owner of record-of the following parcels in •
what is known as O1de Towne, .1732064655, 1732062346, 1722849976,
.1722845383,1722937105,1722939573,1732032738,1732133268,1732150043,,
473225$970,1732253288t 1732344507,1732346981,1732355214,.1732451391,
1732358928,173237203 1, and 1732372599, tilde Towne is located east of New
Hope Road, north of Rock Qu=y,Road and west of Baswell Roan Wake County,
North Carolina.
13.. Old. Towne Company, LLC is a company QrPnized and existing under the laws
of the State of North Carolina,
C. A Pre-Construction Notification .4pplicatioa (Hereby known as PM was
submitted to Division of Water Quality (hereby known, as D WQ) on Marcia 17, .
2006. The, respcctivc 401 water Quality CerrUlImtion DWQ # 06-0447 Revised-2 .
(00374 and 00402) with,A,dditional. Conditions was issued to Olde Torre
Canapany, LLC on January 8, 2007.
Amount A roved nits Plan on o?
4041Wetland 0,7901 acres of wetland (0.4752 acres I'CN page 4 of 1
permanent impacts, 0.3149 acres temporary
cts .
Stream 592 linear feet stream (3o01inear feet PCN page 5 of 1
errnaaent, 292 Ii near feet t=Dorarv' imnnnrc)
1
2

ENVIRONMENTAL Fax:[phone] May 13 '09 10:44 P.19
Oldo Towne C=pmWy, Ub
Wikc Cowky
Page Z
D. On February 29, 2008, DWQ staff observed impacts to an unnamed tributary to
Walnut Crock in Olde Towne from the unauthorized excavation, mechanized
grading and placement of earthen fill. The stream impacts were quantified to be
340 linear feet (680 square feet) by Soil and Environmental Consultants, PA in an
after-the-fact PCN application submitted to DWQ on June 6, 2008.
E. Title 15A North Carolina Administrative Code (hereby ]mown as NCAC)'2B
.0211(2) requires that " The waters shall be suitable for aquatic life propagation
and maintenance of biological integrity, wildlife, secondary recreation, and
agriculture; sources of water pollution which preclude any of these uses on either
a short-term or long-term basis shall be considered 6 be violating a water quality
standard." .
F_ On February 29, 2009 and April 10, 2008, DWQ staff observed sediment
deposition impacts in wetlands ranging from 2 30 inches. Additioually, on
February 29, 2008 DWQ observed sediment deposition impact to a pond located
in the watershed of an unnamed tributary to Big Branch. The wetland impacts
were quantified to be 0.92 awes (39,876 square feet)'and the pond impacts were
quantified to be 0.11 acres (4,780 square feet) by Soil and Environmental
Consultants, PA in a report submitted to DWQ, on April 15, 2008, titled "Revised
Sediment Impact Delineation Report, Clean-up, and Stabilization Plan":
G_ Additional Condition No. 2 of 401 'W'ater Quality Certification DWQ # 06-0447-
Revised-2 states that "No Waste, Spoil, Solids, or Fill of Any Kind. No waste,
spoil, solids, or fill of any kind shall occur in wetlands,. waters, or riparian areas
beyond the footprint of the impacts depicted in the Pre-Construction Notification.
All construction activities, including the design, installation, operation, and
.maintenance of sediment and erosion control Best Management Practices, shall be
performed so that no violations of state water quality standards, statutes, or rules
occur."
H. 'The water quality standards for wetlands, as found in Title 15A NCAC 213
.0231(a). are designed to protect, preserve, restore and enhauco the quality and
.uses of wetlands and other waters of the state influenced by wetlands.
1. Title 15A NCAC 2B..0231(b) (1) requires "Liquids, till or other solids or
dissolver) gases may not be present in amounts which may cause adverse impacts.
on existing wetland uses;"
?. Title 15A NCAC 2B .0231(b) (5) requires "Hydrological conditions necessary to
support the biological and physical characteristics naturally present in wetlands
shall be protected to prevent adverse impacts on. C. The chemical, nutrient and
dissolved oxygen regime of the wetland; D. The movement of aquatic fauma;. and
F..Watex levels or elevations.
ENVIRONMENTAL Fax:[phone] May 13 '09 1044 P.20
Olde Towne CDm my, U.C
..?'. cooumlyy
K. Title 15A NCAC 2B .0211.(3)f requires that "Oils; deleterious substances;
colored or other wastes: only such amounts as shall not render the waters
injurious to public health, secondary recreation or to aquatic life and wildlife or
'adversely affect the palatability of fish, aesthetic quality or impair the waters for
:t any designated uses;".
L. The impacts occurred to wetlands, Class WL waters, an unnamed tributary that
drains to Walnut Creek, Class C Nutrient Sensitive Waters within.the Neuse River
Basin, and a pond located within, an unnamed tributary to Big Branch, class c
Nutrient Sensitive Waters within the Neuse River Basin.
Ni. The cost to the State of the enforcement procedures in this matter totaled 56.4.84.
Based upon the above.Finding of Fact, I make the following:
II. CONCLUSION OF LAW
A. Olde Towne Company, LLC is a "person" within the meaning of G.S. 143--
. 215.6A pursuant to G.S. 143-212 (4).
B. The wetlands, unnamed tributary that drains to Walnut Creek, and the pond
located within are unnamed tributary to Big Branch located at the site, constitute
waters of the' State within the meaning of G.S. 143-212 (6).
C. OIde Towne Company, LLC violated Title' 15A NCAC 2B .0211(2) by impacts
to 340 linear feet of an unnamed tributary from excavation, mechanized grading
and placement of earthen fill.
D. The 401 Wafer Qi ahty Certification, DWQ,N 06-0447-Revised-2 was issued in
accordance with Title 15A•NCAC 2H.0500.
B. Olde Towne Company, LLC violated Additional Condition No. 2 of Water.
Quality Certification DWQ # 06-0447-R0ised-2 General Certification by impacts
to wetlauds and a pond from sediment deposition, and a stream from fill beyond
the footprint of the Olde Towne Company, LLC impacts depicted in the Pre-
Construction Notification
F. Olde Towne ComPSAY, LLC violated Title ISA NCAC 219.0231 (a) and (b)(1)
9md (5) by impacts to 0.92 acres (39,876 square feet) of wetlands from sediment
deposition.
G. Olde Towne Company, LLC violated Title 15A NCAC 2B.0211 (3)(f) by
impacts to 0.11 acres (4,780 square feet) of pond from sediment deposition.
ENVIRONMENTAL Fax:[phone] May 13 '09 10:45 P.21
olde Towne C.o"y, LLC
Wake county
Pare 4
14, 01de Towne, LLC may be assessed civil penalties is this matter pursuant to G.S.
143-215.6A (a)(1), which provides that a civil penalty of not more than twenty-
five thousand dollars ($25,000) per violation per day may be assessed against a
person who violates any classification, standard, limitation, or management
practice established pursuant to G.S.143-214.1, 143-214.2, or 143-215.
1. Olde Towne Company, LLC may be assessed civil penalties in this matter
pursuant to G.S. 143-215.6A (a)(2), which provides that a civil penalty of not
more than twenty-five thousand dollars ($25,000) per violation per day maybe
assessed against a person who is required but fails to apply for or to secure a
permit required by G.S.143.215.1, or who violates or fails to act in a=rdauee •
with the terms, conditions, or requirements of such permit or any other permit or
certification issued pursuant to authority conferred by this part
3. Olde Towne Company, LLC may be'assessed civil penalties pursuant to Gr.S.143-
215.6A (a)(6) which provides that a civil penalty of not more than twenty-five
thousand dollars ($25,000.00) per violation may be assessed against a person who
v'iolates a rule of the Commission implementing this Part, Fart 2A of this Article,
. or G.S. 143-35?(lr)
X. The State's enforcement cost in this matter may be assessed against 01de Towne
Company, LLC pursuant to G.S. 143.215.3 (a)(9) and G.S. 143B-282.1(b)(8).
L. Sohn Hennessy of the Division of Water Quality, pursuant to delegation provided
'by the Secretary of the Department of Envvironment and Natural Resources and
the Dim aor of the Division of Water Quality, has the authority to assess civil
penalties in this matter.
Based upon the above Findings of Fact and Conclusions of Law, i make the following:
Ill, DECISION
Accordingly, Olde Towne Company, LLC is hereby assessed a civil penalty of
for one (1) violation of Title 15A NCAC 2B.0211 (2) by impacts
to 340 linear feet of an unnamed tributary from excavation,
mechanized grading and placement of earthen fill
S WO O ? for one (1) violation} of Additional Condition No. 2 of Water
Quality CerdfieatioA DWQ # 06-0447-Revised-2 General
Certification by impacts to wetlands and a pond from sediment
ENVIRONMENTAL Fax:[phone] May 13 '09 1046 P.22
olda Towne Com? Y
' ' Yasc 3
deposition, and a stream from fill beyond the footprint of the
impacts depicted in the pre-Construction Notification
$ ?0 for one (1) violation of Title 15A N'CAC 2B .0231(a) and (b)(1)
and (5) by impacts to 0.92 acres (39,876 square feet) of wetlands
from sediment deposition
? , o vo for ozie (1) violation of Title 15A NCAC 2B .0211(3)(1) by
impacts to 0,11 acres (4,780 square feet) of pond from sediment
deposition
$ a o o TOTAL CrVTL PENALTY, authorized by G.S. 143-215,6A '.
564.84 Enforcement -Cost
$ TOTAL AMOUNT DUE
As required by G.S.143-215.6A(c), in detamdning the amount of penalty, I considered the
factors set out in Gr.S.1.43B-2'82.1(b), which arc;
(1) The degree and extent of harm to the natural resources of the State, to the public health,
or to private property resulting from the violations;
(2) . The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were cominitted willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over
which the Environmental Management Cossion has regulatory authority; and
(8) The cost to the State of the enforcement procedures
J
Dag
fir.
J Hennessy
'vision of Water Quality
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