HomeMy WebLinkAbout20200376 Ver 1_Response to USACE More Info Request_20200325Strickland, Bev
From: Roden Reynolds, Bryan K CIV (US) < Bryan.K.RodenReynolds@usace.army.mil >
Sent: Wednesday, March 25, 2020 10:21 AM
To: Homewood, Sue
Subject: [External] FW: SAW-2020-00523_Broken Saddle (Notice of Incomplete Pre -
Construction Notification)
Attachments: SAW-2020-00523_Broken Saddle -Response to Notice of Incomplete Pre -Construction
Notification.pdf
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Thanks,
Bryan Roden -Reynolds, WPIT
Regulatory Project Manager
U.S. Army Corps of Engineers
Wilmington District
Charlotte Regulatory Field Office
8430 University Executive Park Drive
Charlotte, NC 28262
Office: (704)510-1440
From: Mark Senior <msenior@wkdickson.com>
Sent: Wednesday, March 25, 2020 10:15 AM
To: Roden Reynolds, Bryan K CIV (US) <Bryan.K.RodenReynolds@usace.army.mil>
Cc: Marc Horstman <mhorstman@wkdickson.com>; Wendi Hartup <WHartup@toknc.com>
Subject: [Non-DoD Source] RE: SAW-2020-00523_Broken Saddle (Notice of Incomplete Pre -Construction Notification)
Bryan; Thanks again for responding so quickly to our submittal and my call. Attached is a PDF package in response to
your comments. It includes a narrative response to each of your comments as well as a revised impact table. I've also
included a signed Agent Authorization form and a revised Impact Map exhibit. Both the impact table and Impact Map
have incorporated the riffles as permanent impacts and include the pipe replacement under Saddle Brook Lane as a
permanent impact.
Please let me know if you need any additional information.
Thanks, Mark Sr.
Mark T. Senior, PE
Senior Project Engineer
WK Dickson & Co., Inc.
720 Corporate Center Drive
Raleigh NC 27607
Office: 919-782-0495
Direct 919-256-5650
Email: msenior@wkdickson.com
Blockedwww.wkdickson.com
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From: Roden Reynolds, Bryan K CIV (US) <Bryan.K.Roden Reynolds@usace.army.mil>
Sent: Tuesday, March 24, 2020 2:45 PM
To: Mark Senior <msenior@wkdickson.com>
Subject: RE: SAW-2020-00523_Broken Saddle (Notice of Incomplete Pre -Construction Notification)
You are welcome to call my office any time. I will be working all week.
Thanks,
Bryan Roden -Reynolds, WPIT
Regulatory Project Manager
U.S. Army Corps of Engineers
Wilmington District
Charlotte Regulatory Field Office
8430 University Executive Park Drive
Charlotte, NC 28262
Office: (704)510-1440
From: Mark Senior <msenior@wkdickson.com>
Sent: Tuesday, March 24, 2020 2:27 PM
To: Roden Reynolds, Bryan K CIV (US) <Bryan.K.RodenReynolds@usace.army.mil>
Cc: Marc Horstman <mhorstman@wkdickson.com>
Subject: [Non-DoD Source] SAW-2020-00523_Broken Saddle (Notice of Incomplete Pre -Construction Notification)
Good afternoon Bryan. Thank you for the quick turnaround on this submittal. I have reviewed your comments and have
a few questions if you're available to talk. Should I call your work number or are you working remotely? When is a good
time to call?
Thanks, Mark Sr.
From: Roden Reynolds, Bryan K CIV (US) <Bryan.K.Roden Reynolds@usace.army.mil>
Sent: Tuesday, March 24, 2020 8:17 AM
To: Marc Horstman <mhorstman@wkdickson.com>
Cc: whartup@toknc.com; Sue Homewood <sue.homewood@ncdenr.gov>
Subject: SAW-2020-00523_Broken Saddle (Notice of Incomplete Pre -Construction Notification)
Importance: High
Mr. Hortsman,
On March 16, 2020, we received the Pre -Construction Notification you submitted on behalf of the Town of Kernersville
on a property located in Forsyth County, North Carolina. I have completed my initial review of the report and I have
determined that it is incomplete. The following information is necessary before I will issue a determination:
a. The PCN did not contain a signed Agent Authorization Form between the applicant (i.e., Wendi Hartup of the
Town of Kernersville) and the consultant (i.e., March Horstman of WK Dickson). Therefore, please provide a
signed Agent Authorization form between applicant and consultant;
b. In the PCN, Section D(3) Stream Impacts and the Figure labeled "Impact Map" depicts the proposed impacts
for the project. However, there are discrepancies between these two sources. Please clarify and accurately
represent the proposed impacts. Below is the impacts as described in the PCN;
Proposed Impact
Reason for Impact
Impact Type
(Permanent or
Temporary)
Table in PCN
(Section D)
Impact Map
S1
Bank stabilization
Permanent/Temporary
10 linear feet
(Permanent)
10 linear feet
(Temporary)
S2
Bank stabilization
Permanent
70 linear feet
65 linear feet
S3
Riffle grade control
Temporary
10 linear feet
10 linear feet
S4
Bank Stabilization
Permanent/Temporary
9 linear feet
(Permanent)
9 linear feet
(Temporary)
S5
Culvert extension
Permanent
40 linear feet
35 linear feet
S6
Riffle grade control
Temporary
10 linear feet
65 linear feet
PROPOSED PERMANET IMPACTS
129 LINEAR FEET
100 LINEAR FEET
PROPOSED TEMPORARY IMPACTS
20 LINEAR
FEET
94 LINEAR FEET
TOTAL STREAM IMPACTS
1 149 LINEAR FEET
194 LINEAR FEET
c. The riffle grade control proposed at Broken Saddle Lane is proposed as 10 linear feet of temporary impacts.
Please describe the type of riffle grade control that will be placed as proposed and to why it is considered a
temporary impact and not a permanent impact. Please note all temporary stream impacts will need to be
restored to pre-existing conditions after the completion of construction. Therefore, these temporary grade
controls will need to be removed to comply with any issued permit. Riffle grade controls proposed as
temporary installments will likely cause more adverse effects to the stream channel because of installation
and removal;
d. The riffle grade control proposed on Marylebone Drive is proposed as a buried riffle complex. However, as
stated in Additional Information Request "b", there are discrepancies in length of impact and duration of
impact (i.e., temporary or permanent). If the activity is a buried riffle, then the Corps would consider this
impact as permanent, as it would not be removed after the completion of construction;
e. The Broken Saddle portion of the project, proposes to replace an existing culvert with an appropriately sized
culvert in the same footprint of the existing culvert. This culvert replacement (i.e., 60 linear feet of
permanent stream impacts) needs to be depicted in the table in Section D(3) and the figure labeled "Impact
Map" Therefore, please revise these sections accordingly;
f. The PCN states the culvert at Marylebone Drive is adequately sized for the Town's design storm. The PCN
lacked enough detail to determine the size of the existing culvert under Marylebone Drive. Therefore, please
provide the current size of this existing culvert. In addition, if this culvert is a different size than the culvert
to be replaced and installed under Broken Saddle Lane, please provide explanation as to why culverts in
series on the same stream channel and in the same watershed would be required and designed to have two
different sizes.
g. The Corps is unsure/confused as to why a PCN was submitted and requested for a Nationwide Permit 3.
Nationwide Permit 3 notification requirements, on page 2 of Nationwide Permit 3, state "for activities
authorized by paragraph (b) of the NWP, the permittee must submit a PCN. Activities under paragraph (b)
refer to the removal of accumulated sediments and debris outside the immediate vicinity of existing
structures. However, the activities as proposed in the PCN are more related to activities described in
paragraph (a) of NWP 3 (i.e., repair, rehabilitation, or replacement of any previously authorized structure or
fill and includes minor deviations in authorized structures and any minimum stream channel work necessary
for the repair). Once all the additional information requested in "a-f" is received, the Corps will be able to
make a determination if the proposed project qualifies for a non -reporting Nationwide Permit 3. If a non -
reporting Nationwide Permit 3 would cover these proposed activities, then the Corps will issue an non -
reporting email to the applicant rather than reviewing the PCN, which was not needed, and issuing a formal
verification letter. If the additional information provided does not meet the conditions in paragraph (a) of
NWP 3, then the Corps will likely issue a formal verification letter for the proposed project.
Please provide the information requested above in ONE consolidated response within 30-days of the date of this
correspondence. If you do not respond within 30-days, the request will be administratively canceled. Please contact me
via telephone or e-mail if you have any questions.
Thanks,
Bryan Roden -Reynolds, WPIT
Regulatory Project Manager
U.S. Army Corps of Engineers
Wilmington District
Charlotte Regulatory Field Office
8430 University Executive Park Drive
Charlotte, NC 28262
Office: (704)510-1440
Mark T. Senior, PE
Senior Project Engineer
WK Dickson & Co., Inc.
720 Corporate Center Drive
Raleigh NC 27607
Office: 919-782-0495
Direct 919-256-5650
Email: msenior@wkdickson.com
BlockedBlockedwww.wkdickson.com
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SAW-2020-00523 Broken Saddle (Notice of Incomplete Pre -Construction Notification)
Response to comments:
Following are responses to comments received on March 24,2020 regarding the above project.
a. A signed agent authorization form has been included
b. The table of proposed stream impacts (below) has been revised along with the Impact Map Exhibit so
both agree with the latest designs and include the riffles as permanent impacts
Proposed
Impact
Reason for Impact
Impact
Type
Length of
Impact
S1
grading to install new headwall
Temporary
10 linear feet
S2
install plunge pool, riffle, & boulder toe
Permanent
65 linear feet
S3
grading to slope back eroding channel banks
Temporary
10 linear feet
S4
grading to install new headwall
Temporary
9 linear feet
S5
35' culvert extension & construct 10' riffle
Permanent
45 linear feet
S6
grading & boulder toe to stabilize eroding banks
Temporary
55 linear feet
S7
replace existing 24" pipe with 48" pipe
Permanent
60 linear feet
PROPOSED PERMANENT IMPACTS
170 LINEAR
FEET
PROPOSED TEMPORARY IMPACTS
84 LINEAR
FEET
TOTAL STREAM IMPACTS
254 LINEAR
FEET
c. The proposed riffle grade control at Broken Saddle Lane is to be left in place and has been included in
the permanent impacts noted under S2
d. The proposed riffle at Marylebone Drive is to be left in place and has been included in the permanent
impacts noted under S5
e. The replacement of 60 linear feet of 24" culvert under Saddle Brook Lane with 60 linear feet of 48"
culvert has been added as a permanent impact in the table under S7
f. The existing culvert under Marylebone Drive is 60 inches which is larger than the proposed 48-inch
culvert to be installed under Saddle Brook Lane. The downstream culvert is larger because it serves a
much larger drainage area.
g. All of the proposed impacts associated with this project would fall under paragraph (a) of Nationwide
Permit 3 so no PCN may be required.
��ERS �ji Curtis Swisher, Town Manager
TOWN OF KERNERSVILLE n--I\An itk� n;—t—
��� . co� 509 Michael St Telephone (336) 996-6916
Kernersville, NC 27285
STREET CULVERT CROSSINGS:
Broken Saddle Ln
Marylebone Dr
Property Owner: Town of Kernersville
Property Owner Address: PO Box 728, Kernersville, NC 27285
The undersigned, registered property owners of the above noted property, do hereby authorize
Mark Senior of WK Dickson & Co., Inc. to act on our behalf and take all actions necessary for the
processing, issuance and acceptance of this permit or certification and any and all standard and
special conditions attached.
Property Owner's Addresses that will have easements:
0 Corjon Rd
0 Broken Saddle Ln
307 Broken Saddle Ln
332 Marylebone Dr
337 Marylebone Dr
341 Marylebone Dr
We hereby certify the above information submitted in this application is true and accurate to
the best of our knowledge.
Aut o ized Signature
Date: -9'7'A/
Impact S1 - 10 LF
Temporary
Impact S7 - 60 LF
Permanent
Impact S2 - 65 LF ,
Permanent '
r
Impact S3 - 10 LF�
\ Temporary
try-� • � n F•
Impac
Temp
I VA
r.
v�
Legend rermanent
Stream Centerline
Existing Culverts
Impact
0 Permanent
0 Temporary "Source. Esri, DigifaIII Glob', GeoEye, Earths4ar Geographies, C E /Airbus D',
USDA, USGS, AeroGRID, IGIV, and tNhe GIN- User Communit,
NhWK Impact Map 60 30 0 60
N
WDICKSON F Broken Saddle Lane Feet
community infrastructure consultants s 1 inch = 60 feet
Culvert Replacement Project