20190231 Ver 1_U-3467 Response to NCDWR - Union County September 10 2019_20190912

STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
Roy COOPER
GOVERNOR
September 10, 2019
N.C. Department of Environmental Quality
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699
ATTN: Ms. Amy Chapman
Transportation Permitting Branch Supervisor
Dear Madam:
JAMES H. TROGDON, III
SECRETARY
Subject: Response to NCDWR On Hold Letter dated August 13, 2019 for the extension
and relocation of NC 84 from NC 16 to SR 1008 (Waxhaw-Indian Trail Road) in
Union County. Federal Aid Project No. STP-1316(10), VMS 39019.1.1, Division
10, TIP No. U-3467.
Reference: 404/401 Individual Permit Application dated February 21, 2019
NCDWR On Hold Letter dated August 13, 2019
On August 13, 2019, NCDWR sent a letter placing the permit application for the above -referenced
project on hold, requesting avoidance and minimization of an open cut utility relocation impact to
West Fork Twelvemile Creek (Permit Site U 1).
NCDOT's Utilities Unit has identified the following avoidance and minimization measures that
led to the design shown in the permit application:
• The original location of these relocated utilities was slightly further south (see attached).
They were pulled in tighter to the north as much as possible to avoid impacts to the tributary
(Stream SB) coming into West Fork Twelvemile in that location.
• Pushing the utility relocation further away from the roadway and bridge was analyzed, but
it would still have to cross West Fork Twelvemile Creek at some point, and it would have
a much larger permanent utility easement (PUE) on Parcel 67 which is slated for
development.
Mailing Address: Telephone: [phone] Location:
NC DEPARTMENT OF TRANSPORTATION Fax: [phone] BIRCH RIDGE DRIVE
ENVIRONMENTAL ANALYSIS UNIT Customer Service: 1-877-368-4968 RALEIGH NC 27610
1598 MAIL SERVICE CENTER
RALEIGH NC 27699-1598 Website: www.ncdot.gov

• The proposed waterline is a 24" diameter pipe. If this was directionally drilled, a 30"
diameter high -density polyethylene (HDPE) pipe would be required. The bore pits
necessary for this size directional drill would impact nearby stream SB and possibly West
Fork Twelvemile Creek or the proposed bridge structure.
• Directional drill of the waterline would necessitate increasing the horizontal separation of
the water and sewer lines creating more PUE.
• The water and sewer lines are designed at the minimum allowable horizontal separation
allowed by NCDEQ in order to minimize disturbance at the stream crossing.
• Ensuring minimum slope requirements on a gravity sewer line using directional drilling is
difficult and unpredictable.
We believe, based on the above information, that the open cut utility relocation across West Fork
Twelvemile Creek (Permit Site U1) has been avoided and minimized to the maximum extent
practicable and the project can be removed from On Hold status and the processing of our
application can proceed.
Thank you for your assistance with this project. If you have any questions or need additional
information, please contact Erin Cheely at [e-mail] or [phone].
Sincerely,
for
Philip S. Harris III, P.E., C.P.M.
Environmental Analysis Unit Head
cc:
NCDOT Permit Application Standard Distribution List
U-3467 Response to NCDWR On Hold Letter Page 2 of 2

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