20201077 Ver 1_USACE More Info Request_20201217

Strickland, Bev
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Thursday, December 17, 2020 12:45 PM
To: Jason Steele; [e-mail]
Cc: Homewood, Sue
Subject: [External] RE: Request for Additional Information - Registers Creek Pump Station and
Force Main, City of High Point, Guilford County; SAW-2020-00682
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Jason,
Thank you for your response to our request for additional information and your time on the phone on Tuesday. Your
responses to items 2 (for all proposed crossings except the Deep River crossing) and 3-5 of our request are satisfactory
and considered addressed for our purposes. Your responses to items 1 and 2 (the proposed Deep River crossing only)
prompted internal discussions with our District Office and Office of Counsel, leading to a more complete understanding
of our intent of Special Condition c of the Individual Permit issued by the Corps to Piedmont Triad Regional Water
Authority for the construction of Randleman Lake (SAW-1991-02669) on 4/6/2001.
Based on this discussion, the following portion of Special Condition c is to be interpreted strictly: "No development of
any type will be allowed in the buffer area except for construction of and access to boat launching ramps. All other
development such as boat access parking areas, day visitor picnic facilities, restrooms, and walking and/or bicycle trails
will be located outside the buffer area." As such, authorizing impacts for the proposed Deep River crossing (through the
200 ft buffer) for a new sewer forcemain would be prohibited. My apologies for portions of item 1 in the 9/15/2020
request for additional information that indicated otherwise.
Special Condition c does allow some flexibility for "maintenance or modification of existing utilities, which result in land
disturbance or cutting of trees or vegetation within the buffer." However, the proposed project appears to be a new
sewer line to increase the City of High Point's sewer service area rather than maintenance or modification of existing
utilities. If our understanding of the project purpose is incorrect, please describe any existing sewer utilities/ROW in the
proposed Deep River crossing area, and provide a justification of how the proposed project is maintenance or
modification of existing utilities for our evaluation.
Otherwise, redesign of the Deep River crossing to avoid Corps authorization requirements and impacts to the 200 ft
buffer would be required. Possible ways to accomplish this may include horizontal directional drilling or jack -and -bore
under the Deep River and 200 ft buffer, where the entry/exit pits and associated disturbance would be located outside
of the 200 ft buffer (generally shown in this location as land owned by Piedmont Triad Regional Water Authority). Other
possibilities may include attaching the forecemain to existing above -water structures such as the Kivett Drive NCDOT
bridge over the Deep River or re-routing the forcemain to the north of the 200 ft buffer (generally north of the Harvey
Road NCDOT bridge over the Deep River).
Please submit the requested information (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. In
the meantime, 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: [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: Jason Steele <[e-mail]>
Sent: Tuesday, December 1, 2020 9:32 AM
To: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Cc: Homewood, Sue <[e-mail]>
Subject: [Non-DoD Source] RE: Request for Additional Information - Registers Creek Pump Station and Force Main, City
of High Point, Guilford County; SAW-2020-00682
Hi Dave,
Please see our responses in blue below. Please let me know if you have any questions or require any additional
information.
Best Regards,
Jason Steele, PhD, PWS
Environmental Scientist
Freese and Nichols, Inc.
531 N. Liberty St.
Winston-Salem, NC 27101
[phone] (mobile)
www_frPP-P_rnm
1) The proposed project encroaches into a 200-foot buffer around Randleman Lake as required by an Individual
Permit issued by the Corps to Piedmont Triad Regional Water Authority (SAW-1991-02669, see attached) on
4/6/2001. Specifically, Special Condition c of this permit requires:
"As part of the project described in the EIS, the Permittee will acquire in fee simple or through conservation
easements a 200-foot wide horizontal buffer adjacent to and around the perimeter of the Randleman Lake. This
buffer will be maintained or developed as a forested preservation area. Existing fields and early successional

plant communities will be allowed to proceed through natural ecological succession ultimately to hardwood
forest. The buffer area will not be developed for silviculture, and no timber harvesting will be allowed except
where the forestry activities are necessary for the health and viability of the forest and are consistent with the
primary goal of watershed protection for the reservoir. No development of any type will be allowed in the buffer
area except for construction of and access to boat launching ramps. All other development such as boat access
parking areas, day visitor picnic facilities, restrooms, and walking and/or bicycle trails will be located outside the
buffer area. Any activities, including maintenance or modification of existing utilities, which result in land
disturbance or cutting of trees or vegetation within the buffer will require advance written approval from
USACE."
Encroachments into PTRWA property as proposed by this project (see attached) do not appear to be in
compliance with this special condition, and aspects of this project that encroach into this buffer should be
redesigned to avoid encroachment or employ construction methodology that allows all existing forested
preservation areas to remain forested. Any encroachments into this buffer must be justified as unavoidable; in
this case, any such justifications must be accompanied by an acceptable buffer mitigation plan.
The impact sheets have been updated to reflect the known Randleman Lake Buffer (sheet S-4, Attachment 1 to this
email) and have also been checked against the most recent Randleman Buffer Rules (per Sue's email request). There will
be a permanent maintenance corridor through the Lake Buffer that we have assigned "allowable with mitigation". Based
upon the alignment of the forcemain, which was chosen due to the majority of the alignment running through
previously disturbed areas to reach the areas required to provide sewer access, the crossing of Deep River is
unavoidable. Much of the impacted Lake Buffer area is currently in a transitional state, with very few areas forested. We
are proposing to conduct construction activities consistent with present and on -going buffer activities, and to administer
an appropriate buffer mitigation plan in the form of buffer mitigation credits for the permanent maintenance corridor.
2) Per NWP 12 Regional Condition 4.1.1, utility line construction through jurisdictional waters must be
accomplished utilizing trenchless methods to the maximum extent practicable. Both Reddicks Creek and the
Deep River (see also item 1 above) are within water supply watersheds and warrant additional avoidance and
minimization of impacts to these resources. Please update the PCN and Plans to abide by this condition,
including stating the specific method of trenchless installation to be employed, entry/exit pits, etc. If such
techniques are not practicable for one or both crossings, please provide specific 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).
Deep River — our Geotechnical investigation noted the presence of multiple boulders in this area of the Deep River. Their
presence makes trenchless technologies very challenging and expensive. Similarly, if we were to try to avoid the
boulders we would need to put the line very deep — (a drawback of depth it can't be easily accessed for repairs —
if/when repairs might be needed), but the main drawback is this would require the use of Horizontal Directional Drill
technology. To get proper entry and exit angles we were looking at over 1200 linear feet of HDD — which would be a
significant cost adder.
For Reddick's Creek we are working in a constrained corridor and are trying to stay within the existing disturbed
corridors for the existing gravity sewer and existing force main. This approach limits our impacts to property owners and
the environment. Trenchlessly crossing this creek would require our new FM go deeper and for a greater distance as
cannot have any bends in the trenchless section. Typically we like to be 8 ft below the invert of the creek/stream/river
bed for Jack and Bores so the top of pipe would be at elevation 716, and the excavation would extend —713. This would
increase the amount of disturbed area and the required easement would need to be greater. The top of ground is about
733 on either end of where we would have a proposed bore (-157+85 to—158+70) —which would put the pipe at a
depth that is beyond the reach of the City's maintenance equipment. Not a show stopper as the pipe can handle the
overburden pressure at that depth but does mean the City would have to reach out to a contractor for any sort of
emergency repair.

Note: we would need 20 ft min from the stream invert for HDD to prevent frack out issues — but HDD is not a feasible
option here anyway.
Due to our proximity to the existing infrastructure and the depths of excavation required for a trenchless crossing we
would be excavating deeper than the existing FM and Gravity Sewer. This increases the risk potential of undermining
this infrastructure as both the FM and Gravity Sewer will need to remain in service while we are installing the new force
main. For these reasons we have proposed open -cut as the safest and least impactful method of crossing the creek.
3) References to stream and wetland crossing details do not seem to be accurate. Please compare references on
Sheets PP-1 through PP-13 and ER-2 through ER-8 with detail sheets and ensure that references/details are
correct.
References have been updated
4) All stream impacts are listed on the PCN as temporary, however the plans show that rip rap is proposed to be
placed along the banks and in the channel of most if not all crossings. Since the rip rap material would not be
removed these impacts are considered permanent, although we would not consider them a permanent loss of
waters and these amounts would not contribute to the Nationwide Permit impact limit thresholds.
This has been noted. If you would like these areas changed to Permanent in the impact sheets we can do so.
5) Please submit additional details about the wetland restoration plan for the temporary wetland impact areas,
including confirmation that the top 6-12 inches of the trench will be backfilled with topsoil from the trench, and
including a re -vegetation plan using native wetland species per NWP 12 Regional Condition 4.1.9.
These updated details are included in the excerpt from the full plan set (attachment 2 to this email), Sheets ER-1 for
planting specs and ER-12 for temporary wetland crossing impacts. The full plan set has been made available to you via
FNI FTP (separate email) due to size (42MB).
From: Bailey, David E CIV USARMY CESAW (USA)<[e-mail]>
Sent: Tuesday, September 15, 2020 2:31 PM
To: [e-mail]; Jason Steele <[e-mail]>
Cc: Homewood, Sue <[e-mail]>
Subject: Request for Additional Information - Registers Creek Pump Station and Force Main, City of High Point, Guilford
County; SAW-2020-00682
External Email. Use caution when clicking links or opening attachments.
All,
Thank you for your PCN and attached information, dated 8/24/2020, 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://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
Permit or consider your application withdrawn and close the file:

1) The proposed project encroaches into a 200-foot buffer around Randleman Lake as required by an Individual
Permit issued by the Corps to Piedmont Triad Regional Water Authority (SAW-1991-02669, see attached) on
4/6/2001. Specifically, Special Condition c of this permit requires:
"As part of the project described in the EIS, the Permittee will acquire in fee simple or through conservation
easements a 200-foot wide horizontal buffer adjacent to and around the perimeter of the Randleman Lake. This
buffer will be maintained or developed as a forested preservation area. Existing fields and early successional
plant communities will be allowed to proceed through natural ecological succession ultimately to hardwood
forest. The buffer area will not be developed for silviculture, and no timber harvesting will be allowed except
where the forestry activities are necessary for the health and viability of the forest and are consistent with the
primary goal of watershed protection for the reservoir. No development of any type will be allowed in the buffer
area except for construction of and access to boat launching ramps. All other development such as boat access
parking areas, day visitor picnic facilities, restrooms, and walking and/or bicycle trails will be located outside the
buffer area. Any activities, including maintenance or modification of existing utilities, which result in land
disturbance or cutting of trees or vegetation within the buffer will require advance written approval from
USACE."
Encroachments into PTRWA property as proposed by this project (see attached) do not appear to be in
compliance with this special condition, and aspects of this project that encroach into this buffer should be
redesigned to avoid encroachment or employ construction methodology that allows all existing forested
preservation areas to remain forested. Any encroachments into this buffer must be justified as unavoidable; in
this case, any such justifications must be accompanied by an acceptable buffer mitigation plan.
2) Per NWP 12 Regional Condition 4.1.1, utility line construction through jurisdictional waters must be
accomplished utilizing trenchless methods to the maximum extent practicable. Both Reddicks Creek and the
Deep River (see also item 1 above) are within water supply watersheds and warrant additional avoidance and
minimization of impacts to these resources. Please update the PCN and Plans to abide by this condition,
including stating the specific method of trenchless installation to be employed, entry/exit pits, etc. If such
techniques are not practicable for one or both crossings, please provide specific 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).
3) References to stream and wetland crossing details do not seem to be accurate. Please compare references on
Sheets PP-1 through PP-13 and ER-2 through ER-8 with detail sheets and ensure that references/details are
correct.
4) All stream impacts are listed on the PCN as temporary, however the plans show that rip rap is proposed to be
placed along the banks and in the channel of most if not all crossings. Since the rip rap material would not be
removed these impacts are considered permanent, although we would not consider them a permanent loss of
waters and these amounts would not contribute to the Nationwide Permit impact limit thresholds.
5) Please submit additional details about the wetland restoration plan for the temporary wetland impact areas,
including confirmation that the top 6-12 inches of the trench will be backfilled with topsoil from the trench, and
including a re -vegetation plan using native wetland species per NWP 12 Regional Condition 4.1.9.
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: [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.