20201217 Ver 1_More Info Received_42021112

Strickland, Bev
From: Burdette, Jennifer <[e-mail]>
Sent: Tuesday, December 8, 2020 5:10 PM
To: Goss, Stephanie
Subject: [External] FW: Request for Additional Information - Duke Energy - Project Walter,
Auburn Church Rd, Garner, Wake County; SAW-2018-01747
Attachments: 08_DKE18190_Project Walter _Wetland Impact Maps_11.19.20.pdf; DKE18190_Project
Walter-PCN Form REVISED 11-24-2020.pdf, DKE18190_Project Walter -Neu -Con SOA -
Meadow Spring_RES.pdf
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Hi Stephanie,
Thank you for the 401 approval for this project (DWR #20201217). I'm so sorry that we didn't copy you on this
additional information. We thought Rick would be handling this one. Please see the attached, revised PCN for a few
changes to the impacts.
Jennifer
Jennifer Burdette I Sr. Environmental Consultant, Water Resources
McAdams
2905 Meridian Parkway, Durham, NC 27713
office 919. 361. 5000 x137 I direct 919.287.0743 1 cell 919.422.3605 1 [e-mail]
www.mcadamsco.com I linkedin I twitter I instagram I join our team
!MMCADAMS
creating experiences through experience
From: Roth, Kelly <[e-mail]>
Sent: Tuesday, November 24, 2020 3:33 PM
To: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Cc: Trone, Rick V <[e-mail]>; David Starkel <[e-mail]>; Burdette, Jennifer
<[e-mail]>; [e-mail]
Subject: RE: Request for Additional Information - Duke Energy - Project Walter, Auburn Church Rd, Garner, Wake
County; SAW-2018-01747
David -
Thank you for your comments on the Project Walter PCN. We have made the revisions that you requested in your email
and that you discussed with Jennifer last week. Please see our responses to your comments in red below. Additionally,
the revised PCN form and impact maps, as well as a Statement of Availability from RES for the required wetland
mitigation credits are attached. Please let me know if you have any further questions or concerns.
Thank you,

Kelly Roth I Environmental Consultant II, Water Resources
McAdams
2905 Meridian Parkway, Durham, NC 27713
office 919. 361. 5000 x210 I direct 919. 287. 0716 1 [e-mail]
www.mcadamsco.com I linkedin I twitter I instagram I join our team
0 McADAMS
creating experiences through experience
From: Bailey, David E CIV USARMY CESAW (USA)<[e-mail]>
Sent: Thursday, November 12, 2020 12:33 PM
To: Roth, Kelly <[e-mail]>; [e-mail]
Cc: Trone, Rick V <[e-mail]>
Subject: Request for Additional Information - Duke Energy - Project Walter, Auburn Church Rd, Garner, Wake County;
SAW-2018-01747
0
Thank you for your PCN and attached information, dated 10/29/2020, for the above referenced project. I have reviewed
the information and need clarification before proceeding with verifying the use of Nationwide Permit (NWP) 39 and 12
(http://saw-reg.usace.army.mil/NWP2017/2017NWP39.pdf; http://saw-
reg.usace.army.mil/NWP2017/2017NWP12.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 Permits(s)
or consider your application withdrawn and close the file:
1) The shape/size of Wetland I as shown on the project plans does not match the shape/size of Wetland I on the
map included with the PJD issued for the main tract of this project on 6/12/2020. Please ensure that the project
plans show Wetland I as verified in the field by the Corps of Engineers on 3/20/2020, and make any revisions to
the PCN and plans as necessary;
The attached revised impact maps and PCN have been modified to reflect the size and shape of Wetland I as
verified by the USACE on 3/20/2020.
2) The North arrow on all Drawings (EX-1 through EX-6 ) incorrectly points to the East;
The north arrow direction has been corrected in the attached impact maps.
3) Proposed wetland impact W3 includes permanent fill in the top half of a small narrow wetland (Wetland 1).
Given the small size of the wetland in question, and the fact that the entire drainage area for the remainder of
the wetland would be rerouted due to grading in the upland portion of the site, the Corps would consider the
remainder of this wetland as an indirect impact. As such, the wetland loss due to direct and indirect impacts
would include the entirety of Wetland 1. Please update the PCN and plans accordingly;
The PCN and impact maps have been revised to reflect that all impacts to Wetland I are permanent impacts.
4) Items related to the proposed sewer line:
a. Impacts S1/W1 include a corridor approximately 60 feet wide, which does not comply with NWP 12
Regional Condition 4.1.3. Please redesign this crossing accordingly;
The attached impact maps and PCN have been revised to reflect a 40 ft wide corridor at the stream
crossi ng.
b. Could the sewer line be shifted slightly to avoid and minimize Wetland Impacts W1, W2, W4, and W5?
Please re -design the sewer line accordingly, or provide documentation that such avoidance and
minimization measures are not practicable (i.e. available and capable of being done after taking into
consideration cost, existing technology, and logistics in light of overall project purposes);
The sewer line cannot be shifted for several reasons. There are steep slopes existing directly adjacent to
many of these wetlands. Shifting the sewer to the west of the wetlands drastically increases the

required excavation depth and makes constructability challenging and costly. Shifting the sewer line to
the east of the wetlands would increase impacts to riparian buffers. Additionally, we have located the
sewer alignment to avoid existing and future transmission towers, keep manholes out of the
transmission easements, and avoid impacts to riparian buffers to the extent practicable.
c. It appears that new manholes are proposed to be placed within Wetlands W4 and W6. Please re -design
the sewer line to relocate these manholes outside of wetlands, or provide documentation that such
avoidance and minimization measures are not practicable. Even if the preceding is satisfied, such
impacts are considered permanent discharges of fill material and permanent losses of waters of the US.
Given that NWP 12 cannot be used to authorize permanent above -grade fill for utility lines, NWP 18
would be required to authorize them. These impacts must also be itemized separately on the PCN form;
The attached impact maps have been revised to relocate all manholes outside of Wetlands W4 and W6.
d. Will the entirety of the sewer corridor through wetlands be permanently maintained, or only a portion
of it? If the latter is true, please itemize the permanent conversion corridor out from the temporary
construction corridor on the PCN. Also note, per NWP General Condition 23(i), "Where certain functions
and services of waters of the United States are permanently adversely affected by a regulated activity,
such as discharges of dredged or fill material into waters of the United States that will convert a forested
or scrub -shrub wetland to a herbaceous wetland in a permanently maintained utility line right-of-
way, mitigation may be required to reduce the adverse environmental effects of the activity to the no
more than minimal level." Based on my site visits on 3/20/2020 and 7/15/2020, the wetlands proposed
for impact are all either scrub -shrub or forested (even in the existing powerline corridor).
The entire 40 ft wide corridor will be permanently maintained.
e. Based on my site visit on 7/15/2020, Wetland Impacts W5 and W6 would occur in relatively narrow
shallow wetlands along their long axis rather than crossing them perpendicularly. This situation would
make restoration of these features to their original grade and contour less likely or at least more
challenging. As such, if item 4)b above can be satisfied, how would the applicant ensure that these
wetlands would be returned to original grade and contour?
Because the sewer line cannot be shifted to avoid these impacts, as stated under item 4)b, these
impacts will remain as permanent conversion impacts and the following language has been added to the
plans to direct the contractor in properly restoring these areas to their original grade and contour: "Prior
to any disturbance, contractor shall survey and record limits and grades of wetland areas to be
temporarily impacted. Contractor shall strip the top 12" of topsoil from wetland areas and stockpile for
re -use. Segregate wetland topsoil from topsoil stripped from non -wetland areas. Upon completion of
work within wetland areas, contractor shall re -stake previously surveyed wetland limits and return areas
to existing grades. Contractor shall respread wetland topsoil within staked limits and seed with a
wetland mix (ERNMX-306 or equal)."
5) Please note that, if cumulative permanent wetland impacts for this project (including all permanent fill and
permanent loss of function noted in items 3 and 4d above) exceed the 0.1 acre threshold per NWP General
Condition 23c, compensatory mitigation will be required. If this is the case after the above items have been
addressed, please submit a compensatory mitigation plan. The mitigation rule generally prescribes purchasing
wetland credits first through a mitigation bank with wetland credits available in this 8-digit HUC (03020201), or
second through the NC Division of Mitigation Services; please provide a mitigation acceptance letter from your
proposed compensatory mitigation provider. Typically, compensatory mitigation is required at a 2:1 credit to
impact ratio for permanent loss of function and 1:1 for partial loss of function, unless otherwise justified based
on evaluation of aquatic function.
Wetland impacts W1, W2, W5, W6 and W7 are permanent conversion impacts for the installation of the sanitary
sewer in forested and scrub -shrub wetlands that will be permanently converted to herbaceous wetlands. A 1:1
mitigation ratio is proposed for these wetlands because they will result in a partial loss of function. W4 is a
permanent grading impact. A mitigation ratio of 2:1 is proposed for this impact because it will result in a
permanent loss of function. A total of 0.346 wetland mitigation credits will be required to compensate for 0.309
ac. of total wetland impacts. A Statement of Availability from RES for the required wetland credits is attached.
Please let me know if you have any questions.

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]
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