20181609 Ver 1_USACE request for more information_20181220

Strickland, Bev
From: Bailey, David E CIV USARMY CESAW (US) < [e-mail] >
Sent: Thursday, December 20, 2018 2:06 PM
To: Terry Shelton; Scott Ehrhardt; Barksdale, Leslie
Cc: Bill, Briana; Beverly O'Dell; Michael Dougherty; Homewood, Sue
Subject: [External] Request for Additional Information: City of Eden Waterline to SoVA Mega
Park; Rockingham Co.; SAW -2018-02188
External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
0
Thank you for your PCN and attached information, dated 11/21/2018, for the above referenced project. I have reviewed
the information and need clarification before proceeding with verifying the use of Nationwide Permit (NWP) 12
(http://www.saw.usace.army.miI/Portals/59/docs/regulatory/regdocs/NWP2012/NWP12 3-23.pdf). Please submit the
requested information below (via e-mail is fine) within 30 days of receipt of this Notification, otherwise we may deny
verification of the use of the Nationwide Permit or consider your application withdrawn and close the file:
1) Project plans require additional details:
a. Currently wetland areas are not clearly visible on the plan sheets. Add all wetland boundaries to the
plans and label them according to the delineation documentation provided by Dewberry on 8/24/2018. 1
recommend that a different color be used on the plan sheets for wetland lines (such as green?). Show
and label the wetland boundaries on the profile drawings as well;
b. Clearly label all streams on the plan sheets according to the delineation documentation provided by
Dewberry on 8/24/2018. 1 recommend that a different color be used on the plan sheets for stream lines
(such as blue?). Show and label the streams on the profile drawings as well;
c. Currently there is no way to match up itemized impacts listed in the PCN with the plans. As such, add
Impact Site labels to the plans, and add corresponding labels to Section D. of the PCN for clarity
purposes:
i. Impact Site 1: Wetlands WD and WE
ii. Impact Site 2: Stream SH;
iii. Impact Site 3: Wetlands WC (2 areas);
iv. Impact Site 4: Streams SF and SG, Wetland WB;
v. Impact Site 5: Stream SE;
vi. Impact Site 6: Streams SC and SD;
vii. Impact Site 7: Streams SA and SB, Wetland WA;
d. Specify whether the utility corridor would include a permanent maintenance easement where
vegetation would be maintained in an herbaceous state. If so, include zoomed -in details of each stream
and/or wetland crossing showing the footprint of the permanent maintenance and temporary
construction corridors. Such details must also show the extent of temporary impacts (streams and
wetlands) and extent of permanent maintenance impacts through wetland areas. Further, for each
applicable crossing, quantify the acreage of wetlands proposed to be converted from forested wetlands
and permanently maintained in an herbaceous state and add those as separate impacts in Section D of
the PCN;
2) Project plans indicate that stream crossings include discharging rip rap. If so, please confirm (including via
profile drawings) that any rip rap placed below the ordinary high water mark will be placed such that the top of
the rip rap will be no higher than the existing stream bed elevation (see NWP 12 Regional Condition 4.1.11).
Note that the "Rip -Sap Placement Detail" on Sheet C22 does not appear to comply with this Regional Condition.

Also, since discharged rip rap would not be removed, the lengths of stream subject to rip rap discharge must be
added to the PCN as permanent impacts;
3) Given the time past from the date of the USFWS Section 7 self -certification letter, as well as the known
occurrences of several aquatic species in Cascade Creek and the Dan River, we have initiated informal
consultation with the USFWS. Please note that the Corps cannot verify the use of a NWP until Section 7
consultation is complete;
4) Given that occurrences of Roanoke logperch are known is Cascade Creek, and occurrences of James spinymussel
are known just downstream in the Dan River, avoidance of impacts to Cascade Creek via HDD orjack and bore
methods seem reasonable. However, the plans note an alternative trenching method through Cascade Creek
and the PCN accounts for temporary impacts to Cascade Creek due to trenching. Please clear up this discrepancy
in the plans and PCN, such that the project would be compliant with NWP 12 Regional Condition 4.1.1. If the
Cascade Creek crossing would be installed via HDD, remove this impact from Section D of the PCN and add a
note on this page clearly indicating that the impact would be avoided in this manner;
5) Provide a plan including any pertinent detail sections for typical wetland impacts via trenching. Such plans
should including dewatering methods, lengths of time that trenches will be open in wetlands, and confirmation
that the top 6 to 12 inches of the trench will be backfilled with topsoil from the trench. Per NWP 12 Regional
Condition 4.1.9, provide a specific wetland restoration plan including how grade and contour will be re-
established, anti -compaction measures in soils subject to construction traffic and matting, stabilization methods,
and seeding/planting lists and specifications. Be sure to specify wetland restoration differences in temporary
and permanent easement areas. Such details should be provided as an addendum that can be referenced in
permit Special Conditions;
6) Plan sheet -specific comments:
a. Sheet C5: Wetland lines do not appear on the plan sheet (should be Wetlands WD and WE, per
comment 1)a above. The footprint of wetland areas proposed for impact (permanent maintenance as
well as temporary construction corridors) should be clearly shown on a zoom -in of the crossing (should
be labeled "Impact Site 1" per comment 1)c. above. The sheet references "Provide Stream Restoration
per Details"; however, this area includes wetlands rather than streams, and the plan sheet should
reference a Wetland Restoration plan (see comment 5 above);
b. Sheet C6: Clearly show and label Stream SH per comment 1)b above. The footprint of the stream
proposed for impact should be clearly shown on a zoom -in of the crossing (should be labeled "Impact
Site 2" per comment 1)c. above);
c. Sheet C7: Wetland lines do not appear on the plan sheet (should be Wetland WC [2 segments], per
comment 1)a above). The footprint of wetland areas proposed for impact (permanent maintenance as
well as temporary construction corridors) should be clearly shown on a zoom -in of the crossing (should
be labeled "Impact Site 3" per comment 1)c. above). The sheet should also reference a Wetland
Restoration plan (see comment 5 above);
d. Sheet C8: Clearly show and label Streams SF and SG per comment 1)b above. If applicable, the footprint
of the stream proposed for impact should be clearly shown on a zoom -in of the crossing. The plan sheet
shows both an HDD plan and an "Alternative Open -Cut Cascade" option. Please clear up this discrepancy
(per comment 4 above). Wetland lines do not clearly appear on the plan sheet (should be Wetland WB,
per comment 1)a above). The footprint of wetland areas proposed for impact (permanent maintenance
as well as temporary construction corridors) should be clearly shown on a zoom -in of the crossing. The
sheet should also reference a Wetland Restoration plan (see comment 5 above); Note that both the
stream and wetland crossing should be labeled "Impact Site 4" per comment 1)c. above;
e. Sheet C10: Clearly show and label Stream SE per comment 1)b above. The footprint of the stream
proposed for impact should be clearly shown on a zoom -in of the crossing (should be labeled "Impact
Site 5" per comment 1)c. above);
f. Sheet C14: Clearly show and label Streams SC and SD per comment 1)b above. The plan sheet indicates
that the waterline would be installed essentially within the bank of Stream SC. As such it is reasonable to
assume that the waterline would impact Stream SC itself. Provide information to justify that impacts to
Stream SC would be avoided with the current plan, or quantify proposed impacts and add to the
Fil

plan/profile sheets and PCN. The footprint of the streams proposed for impact should be clearly shown
on a zoom -in of the crossing (should be labeled "Impact Site 6" per comment 1)c. above);
Sheet C17: Clearly show and label Streams SA and SB per comment 1)b above. The footprint of the
streams proposed for impact should be clearly shown on a zoom -in of the crossing. Wetland lines do not
clearly appear on the plan sheet (should be Wetland WA, per comment 1)a above). The footprint of
wetland area proposed for impact (permanent maintenance as well as temporary construction
corridors) should be clearly shown on a zoom -in of the crossing. The sheet should also reference a
Wetland Restoration plan (see comment 5 above); Note that both the streams and wetland crossing
should be labeled "Impact Site 7" per comment 1)c. above.
Sincerely,
Dave Bailey
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE -SAW -RG -R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Phone: [phone], Ext. 30.
Fax: [phone]
Email: David. [e-mail]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: http://corpsmapu.usace.army.mil/cm_apex/f?p=136:4:0
Thank you for taking the time to visit this site and complete the survey.