20201647 Ver 1_More Info Received_20210211

Strickland, Bev
From: Michael Brame <[e-mail]>
Sent: Thursday, February 11, 2021 1:57 PM
To: Homewood, Sue
Cc: [e-mail]
Subject: RE: [External] Pilot Project 5168.1_Hwy 61/70 Water & Sewer Improvements -Response
to Request for Additional Information_2.8.2021
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Good Afternoon Sue,
The utility crossings for each of the stream crossings is expected to take less than 7 days, even with rock
present. The stream crossings themselves will remain in place longer than this to facilitate work on the
tributary side of the streams but the trenches should be backfilled and stabilized within this period of time.
The contractor will be required to coordinate these crossings with the upcoming weather forecast and we'll
monitor progress through rock downstream of the crossings prior to making the crossings to have a
better understanding of how long pipelaying across the crossings will take. If the crossings are expected to
take longer than a week or if weather forecasts are a problem, then the contractor will provide alternative
crossing plans. The alternative crossing plans are likely to include some portion of splitting the crossing,
providing additional pumping capacity, or other means of bypassing the flows around the work area. Please
let me know if you require additional information in order to process the WQC. Thank -you.
Sincerely,
Michael T. Brame
336.708-4620 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
www.pilotenviro.com
mbrame(@r)ilotenviro.com
From: Homewood, Sue <[e-mail]>
Sent: Tuesday, February 9, 2021 8:35 PM
To: Michael Brame <[e-mail]>
Cc: [e-mail]
Subject: RE: [External] Pilot Project 5168.1_Hwy 61/70 Water & Sewer Improvements_Response to Request for
Additional Information 2.8.2021
Hi Michael,

I still have concerns about the crossings of Back Creek. Given how much rock there is which would likely slow down
excavation, and the size of the watershed, I'm concerned for how long the pump around will need to be in place. Can
you please provide more details of what is a reasonable expected length of time for the pump around to be in place for
each crossing of Back Creek.
Thanks
Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
Sue. [e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
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From: Michael Brame <[e-mail]>
Sent: Tuesday, February 9, 2021 9:45 AM
To: Homewood, Sue <[e-mail]>
Cc: [e-mail]
Subject: RE: [External] Pilot Project 5168.1_Hwy 61/70 Water & Sewer Improvements_Response to Request for
Additional Information 2.8.2021
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Good Morning Sue,
Sorry about that. Head is spinning these days. See responses below.
1. Please address NCWRC's comments/concerns emailed on January 11, 2021. The Habitat Assessment report that
was submitted as part of the USACE response should address the federally protected species. Directional drilling is not a
method that can be used due to the presence of bedrock. The open cut will temporarily have impacts to limited areas
within the streams. Following installation, the stream banks will be restored, armored and reseeded. Impacts to state
listed species habitat will be temporary. Best management practices will be used to keep sediment from entering the
jurisdictional features. Many of the best management practices are consistent with the NCWRC's recommendations. A
copy of the letter has been forwarded to the client and they are aware of the additional recommendations and will
consider and implement them where practical.
2. Please clarify how you propose to "work in the dry' to install the utility crossings under Back Creek. The
Division has concerns about installation of these crossings while protecting downstream water quality. The contractor
will install coffer dams upstream and downstream of utility crossing and provide bypass pumping as required on sheet
20. Dewatering operations that will be required between the cofferdams during the installation process are required to
be discharged into stone filter outlet to prevent unnecessary downstream sedimentation.
Sincerely,
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Michael T. Brame
336.708-4620 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
wwwa com
mbrame(@r)ilotenviro.com
From: Homewood, Sue <[e-mail]>
Sent: Monday, February 8, 2021 8:11 PM
To: Michael Brame <[e-mail]>
Subject: RE: [External] Pilot Project 5168.1_Hwy 61/70 Water & Sewer Improvements_Response to Request for
Additional Information 2.8.2021
Hi Michael,
Does this response address my 2 comments (see attached email) also?
Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
Sue. [e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
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From: Michael Brame <[e-mail]>
Sent: Monday, February 8, 2021 3:50 PM
To: David. [e-mail]; Homewood, Sue <[e-mail]>
Subject: [External] Pilot Project 5168.1_Hwy 61/70 Water & Sewer Improvements_Response to Request for Additional
Information 2.8.2021
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Dear David and Sue,
Attached is a complete set of updated Buffer Impact Drawings that includes the wetlands impacts along NC61 as
well as an updated Erosion Control Sheet (Sheet 20). The updated erosion control sheet now includes a stream
restoration detail and updated Temporary Stream Crossing Notes in addition to addressing the items below.
1) The review area for the Jurisdictional Determination for the project, dated 5/26/2020, did not cover the
proposed project area in the following locations: 1) the proposed corridor on Sheet 15 from approximately STA
9+00 to 13+81 and 2) the proposed waterline along NC Highway 61. Have these areas been
evaluated/delineated by a qualified environmental consultant? If so, please provide the appropriate

documentation. Note that the Corps may require a site visit to verify the delineation, and additional revisions
may be required on the PCN and plans based on the final Corps -verified boundaries of potential waters of the
US; Pilot personnel delineated the proposed waterline corridor. The attached exhibits depict the delineated
features and include updated impacts to the delineated features and associated buffers.
2) Please confirm that no permanent rip rap is proposed in stream channels below the Ordinary High Water Mark.
If otherwise, please correct the PCN and show on the plans. Any rip rap placed in the streambed must be keyed
in/depressed into the stream bed such that the top of the rip rap is no higher than the stream bed, and the
profile views should clearly show that;
No permanent rip rap is proposed in stream channels below the Ordinary High Water Mark. Temporary rip rap
placed in stream bed shall be removed by contractor following the temporary stream crossing, with permanent
rip rap for maintenance access to remain on banks and above the Ordinary High Water Mark.
3) Sheet 17 near STA 49+00 shows rip rap in the stream channel. Please confirm whether this is existing or
proposed rip rap;
The above referenced rip -rap is existing. Located in a ditch conveying stormwater runoff from a 15" RCP
leading to a 24" RCP culvert traveling under highway US 70.
4) Sheet 20, under "Temporary Stream Crossing Notes", item 7 references "restore stream banks in accordance
with details shown on Sheet 13." However, Sheet 13 does not appear to provide such detail. Please provide a
restoration plan for proposed temporary impacts to streams, ensuring that this plan complies with NWP 12
Regional Conditions 3.10 and 3.11;
Stream Restoration Detail has been added to Sheet 20 and Temporary Stream Crossing Notes have been
updated to reference correct detail.
5) Per NWP General Condition 18, and given recent USFWS concerns regarding suitable small whorled pogonia
habitat and the fact that the nearest known population of this species is less than 3 miles to the north, please
complete a pedestrian survey for this species within the Corps ESA action area during the appropriate field
survey season. In this case, the Corps ESA action area would be contained within a 100 foot radius of the extent
of each footprint of proposed impacts to waters of the US, including the currently proposed footprint and any
revised footprint if project plans are changed per the above items. Following the survey, please provide the
survey report to the Corps (copy also the USFWS) for review. Of course, if you do not believe that any suitable
habitat exists in the Action area for these species, please provide a more specific justification than what was
provided in the PCN so that the Corps could evaluate the potential for a No Effect determination. For reference,
habitat requirements for this species can be found on pages 23-29 of the species' Recovery Plan
(https://ecos.fws.gov/docs/recovery plan/921113b.pdf); Pilot returned to the site and completed a detailed
habitat assessment at the required locations. A copy of the report is attached.
6) Note that the owners of properties on Sheet 13 (specifically Ingle and Turner) have been working to resolve a
stream and buffer violation with NCDWR, and stream restoration has been proposed in this area that may
conflict with the proposed sewer installation project. It may be beneficial for the applicant and these property
owners to coordinate to avoid potential conflicts that may be detrimental to the success of both projects.
The town has communicated with the stream restoration agency regarding the location and timeline of all work
and it was determined that the area of concern is located within a section of Phase 2 of the proposed
project. Since this is a future Phase, there are no immediate concerns for conflict, but correspondence will
continue ensure future impacts are avoided.
Please let me know if you need additional information in order to process the JD.
Sincerely,
Michael Brame