SW3190501_Response to Comments_20190723

SAIMOS
EIJC,IIJEERfIJC,, LLC.
Response to Review Comments
Date 7/22/19
NCDEQ
512 North Salisbury Street
Raleigh, NC 27699
[phone]
Reference: UPS Statesville/ Iredell County
147 Parcel Dr.
Statesville, NC 28625
Stormwater Permit #SW3190501
Response to Request for Additional Information
Please accept the following responses to your correction letter dated: 7/15/19
Stormwater: Jim Farkas [phone] Jim. Farkas(a-)-ncdenr.gov
The Division of Energy, Mineral and Land Resources (DEMLR), received additional
information for the Stormwater Management Permit Application for the subject project
on June 28, 2019. A review of that information has determined that the application is
not complete. The following information is needed to continue the stormwater review:
1. Repeat Comment: Please show the drainage areas for the BMPs on the plans
(Section VI, 8, o). Each proposed SCM must have its own delineated drainage area
shown somewhere on the main set of plans. Usually this is shown on the proposed
drainage area sheet or on an ESC sheet. Exhibit PB in Appendix A of the Stormwater
Management Report does not include the off -site drainage area.
RESPONSE: Please refer to sheet C2.1 (Drainage Area Exhibit) for a delineation
of the areas going into the proposed SCM. Runoff from areas 3A, 3B, 4A, 4B, 5,
6A, 6B and 7 are being treated by the proposed SCM. Offsite drainage area was
added to Exhibit PB in Appendix A of the stormwater report.
2. Repeat Comment: Please provide official documents with name, title, and position
for those listed in Section 111 of the application (Section VI, 11). The provided Power of
Attorney expired in May 2019 and is no longer valid.
RESPONSE: The updated Power of Attorney was included with previous
submittal, please refer to page two of the document stating effective as of May
26, 2019 and will expire May 25, 2020. This is also included with this resubmittal.
3. Please QA/QC your design prior to the next submission. Some, but not all, of the
noted inconsistencies are listed below:
Page 1 of 4

SAIMOS
EIJC,IIJEERflJC;, LLC.
Response to Review Comments
a. The SCM design volumes shown on the Supplement-EZ Form do not
coincide with the Stormwater Management Report or the plans.
b. The Storm-EZ form shows different drainage area sizes than the rest of
the material.
c. The plans and Supplement-EZ Form show different depths of the shallow
water zone.
d. The planting zone areas from the Stormwater Wetland Supplemental
Form do not add up to the total surface area of the facility.
RESPONSE: Acknowledged. The plans have been QC'd. The numbers on the
Supplement-EZ Form now coincide with the Stormwater Management Report and
the plans. The Discrete NRCS Curve Number and the "Runoff Treatment"
method were used in -lieu of the Storm-EZ Form. Calculations are included in
Appendix A.
4. On the "Drainage Areas" sheet of the Supplement-EZ Form, the entire site does not
need to be included as a column. Each separate SCM should have its own column and
it should be filled out specifically for each SCM as each facility has a different drainage
area.
RESPONSE: Column for the "entire site" has been left blank. Column 1 was used
for the only SCM (i.e. wetland) proposed now.
5. The provided shallow water zone is too deep according to the plans. The maximum
depth of the shallow water zone is 9 inches (Stormwater Wetland MDC 8) and is
shown on the plans as 12 inches (From contour line 822 to 823). Adjusting the size of
the shallow water zones may impact the size of the non-forebay deep pools and the
planting quantities. Please revise.
RESPONSE: The shallow water zone has been revised to show depth of nine (9)
inches. Please refer to revised sheet LS-3.
6. Please ensure that the plants in the temporary inundation zone meet the minimum
spacing requirements (Stormwater Wetland MDC 14).
RESPONSE: Plants spacing was reduced from 4 feet to 2 feet to meet the
minimum spacing requirement. Please refer to Plant List Table on sheet LS-4.
7. The SCMs, as shown, are not providing enough treatment (General MDC 1). Since
this project is High Density, there are two methods to size/design the SCM. The first
method is called "Runoff Treatment" and basically requires that the SCM be sized to
treat the volume of runoff from all Built Upon Areas, BUA, during the design storm. The
exact wording can be found at the link at the end of this comment. This design volume
can be calculated using either the "Simple" method, or the "Discrete NRCS Curve
Number" method, both of which can be found at the following link:
https://files.nc.gov/ncdeq/Energy%20Mineral%20and%20Land%20Resources/Stormw
ate r/BMP%20Manual/B%20%2OStormwater%2OCalculations.pdf
The second method to size/design the SCM is called "Runoff Volume Match". This
requires the SCM to be designed in such a way that the annual runoff volume post -
construction is comparable to the annual runoff volume pre -construction. The exact
wording can be found at the link below. The Storm-EZ form is not required for
submission. You may include it if you like though.
https://files. nc. gov/ncdeq/Energy%20MineraI%20and%20Land%20Resources/Stormw
Page 2 of 4

CA1Zkros
EIJC,IIJCfP,1IJG, LLC.
Response to Review Comments
ate r/BMP%20Manual/A-
1%20%20Runoff%20Treatment%20and%20Volume%20Match. pdf
RESPONSE: Treatment volume calculations were now done using the Discrete
NRCS Curve Number and the "Runoff Treatment" method in -lieu of the Storm-EZ
Form. Calculations are included in Appendix A of the Stormwater Management
Report.
8. Please show the SCM maintenance access on the plans (General MDC 8).
RESPONSE: Please refer to sheet C2.1 for proposed maintenance access
delineation.
9. Provide a permeant recorded easement for the SMCs (General MDC 9). The
easement should include the entire SMC systems (SMC, forebay, riser, side slopes,
outlet, dam embankment, emergency spillway, and any other associated features) and
the maintenance access.
RESPONSE: Please refer to sheet C2.1 for proposed permanent easement
delineation. A permanent recorded easement for the SCM and maintenance
access will be provided prior Certificate of Occupancy.
10. Provide pdfs of all revisions, 2 hardcopies of revised plan sheets, and 1 hardcopy
of other documents. Pdfs must be uploaded using the form at:
https://edocs.deg.nc.gov/Forms/SW Project Submittal
RESPONSE: Please refer to enclosed pdf copies for all revisions (within 147 P
Drive), two hardcopies of revised plans and one hard copy of the Stormwater
Management Report. Pdf's were also uploaded using the form from the website.
While it is not required, it is recommended that:
- The off -site drainage from upstream properties be diverted around the BMPs
since the applicant cannot maintain control over the development of property
that they do not own (Repeat Comment).
- Deep zone plantings are not required. If you are providing deep zone plants,
ensure that no plants are planted in the deep zone directly adjacent to the riser
structure as to prevent clogging.
Please note that this request for additional information is in response to a preliminary
review. The requested information should be received by this Office prior to
August 15, 2019, or the application will be returned as incomplete. The return of a
project will necessitate resubmittal of all required items, including the application fee.
Please reference the State assigned project number SW3190501 on all
correspondence.
If you need additional time to submit the information, please submit your request for a
time extension to the Division at the contact below. The request must indicate the date
by which you expect to submit the required information. The Division is allowed 90
days from the receipt of a completed application to issue the permit.
Page 3 of 4

CA1zkros
EIJC,IIJCfP'1IJG, LLC.
Response to Review Comments
The construction of any impervious surfaces, other than a construction entrance under
an approved Sedimentation Erosion Control Plan, is a violation of NCGS 143-215.1
and is subject to enforcement action pursuant to NCGS 143-215.6A.
If you have any questions concerning this matter please feel free to contact me at
Jim. Farkas(d)-ncdenr.gov or [phone].
Sincerely,
BARRIOS ENGINEERING, LLC
Page 4 of 4