20150151 Ver 2_NW33 correspondence_20201001

Strickland, Bev
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Thursday, October 1, 2020 4:05 PM
To: Cindy Lancaster; Homewood, Sue
Subject: [External] RE: Weird Question re: Revolution Mill
Attachments: 2017NWP33.pdf
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Hi Cindy, and thanks for the email. This is an unusual question, probably owing to the fact that most factory buildings
aren't built on pilings over large streams...
But, back to your question. I would not consider the proposed elevator support structure built onto the side of an
existing piling footer a discharge into waters of the US in this case; a good argument can be made that the proposed
activity is not a "fill", and it looks like the permanent feature would be constructed above the elevation of the Ordinary
High Water Mark.
You're right that the temporary construction access would require authorization from the Corps. However, this activity
should fit NWP 33 for "Temporary Construction, Access, and Dewatering" without requiring submittal of a PCN to the
Corps.
Please note, of course, that the activity would have to abide by the NWP 33 terms and conditions (attached). Please let
me know if you have any questions.
-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.
From: Cindy Lancaster <[e-mail]>
Sent: Thursday, October 1, 2020 3:35 PM
To: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>; Homewood, Sue

<[e-mail]>
Subject: [Non-DoD Source] Weird Question re: Revolution Mill
David/Sue —
I know there is an NWP that allows for maintenance of existing structures over a stream bed — but I want to check with
you on an aspect of the redevelopment plan for the Revolution Mill's "Mill House" building (see attached aerial view)
which may exceed the "maintenance" intent of the permit. The developers want to install an elevator in an atrium area
in the middle of the building that will be open to several floors. Adding the elevator will require installing structural
support under the building. I have attached a plan view to show the proposed location and a photo to describe as best I
can.
There will be some obvious temporary impacts to get equipment to the area, but they plan to put the new support
structure atop the existing footers such that there is no permanent contact with the ground/stream level. I think they
will tie-in the new support structure up at the footer level closest to the columns which would be about —3-4 feet above
the normal water level. If they work from the lower level, that is probably only —1-1/2 to 2 feet above the water
surface. I expect they will have to cross the stream with equipment, but they are very limited on what they can get
down under the building so it shouldn't be very big equipment.
The stream isn't very well defined under that building such that there are obvious banks or an OHWM. Would the
support structure possibly be considered a permanent impact and, if so, how should we proceed re: permitting? Would
the temporary impacts for construction fall within the NWP3 or do we need something else on that even if there are no
permanent impacts?
Feel free to give me a call if you have questions.
Thanks —
Cindy
Cynthia C. Lancaster, P.E., CFM
Project Manager / Water Resources Engineer
Office: [phone], Ext. 102
Mobile: [phone]
Email: CLancasteraKJBinc.com
LJBinc.com
We think bigger. 000
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