20201550 Ver 1_PCN Cover Letter_20210217

Strickland, Bev
From: Beasley, Troy <TBeasley@withersrave nel.com>
Sent: Wednesday, February 10, 2021 12:28 PM
To: Strickland, Bev
Subject: [External] FW: 401 PCN Application Submittal - Clayton Neuse River WRF-Little Creek
Gravity Sewer
Attachments: PCN Cover Letter.pdf
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Bev,
The PCN Cover Letter attached to the ePCN had some formatting issues, and also didn't list all of the
attachments. Could you please replace the PCN Cover Letter attached to the original submittal with the attached
version that has those errors corrected?
Thanks for your help!
Troy Beasley
,
Yaw Succew
219 Station Road, Suite 101 1 Wilmington, NC 28405
0ffice:910.256.9277 1 Direct:910.509.6512
Mobile: [phone]
tbeasley@withersravenel. com
CONFIDENTIALITY AND NONDISCLOSURE
From: [e-mail] <[e-mail]>
Sent: Wednesday, February 10, 2021 10:39 AM
To: Beasley, Troy <[e-mail]>
Subject: 401 PCN Application Submittal - Clayton Neuse River WRF-Little Creek Gravity Sewer
Your pre -construction notification application has been submitted to the North Carolina Division of Water
Resources - 401 Buffer Permitting Branch.
The time clock for the review process will not begin until after the initial review has been done and payment
received. If the application is incomplete a project manager will be contacting you to request more
information.

If you have any questions, or are experiencing any issues with the PCN online form, please contact Bev
Strickland at [e-mail].
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as responses aren't monitored.

40 WithersRavenel
NoOur Peopte. Your Success.
February 9, 2021
US Army Corps of Engineers
Raleigh Regulatory Field Office
Mr. Chris Hopper
3331 Heritage Trade Drive
Suite 105
Wake Forest, NC 27587
NC -Division of Water Resources
401 & Buffer Permitting Unit
Mr. Paul Wojoski
1617 Mail Service Center
Raleigh, NC 27699
Re: Town of Clayton - Neuse River WRF/Little Creek Transmission Improvements
NWP 12 PCN Submittal
Clayton, Johnston County
USACE AID: SAW-2020-00777
WR Project #02190247.00
Dear Mr. Hopper and Mr. Wojoski,
On behalf of the Town of Clayton, we are requesting authorization from the USACE to use NWP
12 for 213 If of temporary stream impacts and 0.082 ac of temporary wetland impacts for
construction of a new sewer force main and gravity sewer to provide conveyance of wastewater
to the new Neuse River Water Reclamation Facility (WRF). We are also requesting an NCDWR
Riparian Buffer Authorization for 7,707 sf of permanent riparian buffer impacts and 17,528 sf of
temporary riparian buffer impacts for construction of the proposed project.
The proposed project consists of the following:
Neuse River WRF - ±79-acres - No Impacts
WRF Access Road - ±10-acres - No Impacts
Little Creek Transmission Lines (new force main and gravity sewer) - ±13-acres - Wetland,
Stream and Riparian Buffer Impacts
The project is located in the Neuse River basin and onsite waters eventually drain to the Neuse
River (HUC: 03020201).
The new sewer force main portion of the project located south of US 70 Business drains to Little
Creek, which flows to Swift Creek and ultimately the Neuse River. The Water Quality
Classification for the Little Creek is C;NSW and the Stream Index Number is: 27-43-12.
The Neuse WRF and new gravity sewer portion of the project located north of US 70 Business
drains to a perennial stream locally known as Sam's Branch, which is a tributary to the Neuse River.
The Water Quality Classification for this section of the Neuse River is WS-IV; NSW and the Stream
Index Number is 27-(38.5).
Proposed Project
The purpose of the proposed project is to replace existing 4.9 MGD capacity provided by the aging
Little Creek Water Reclamation Facility (LCWRF) and prepare for known increasing near -term
demands with construction of the new Neuse River WRF which will provide 6-MGD capacity. This
project is needed because of the LCWRF's aging infrastructure which has exceeded expected
219 Station Road, Suite 1011 Wilmington, NC 28405
t: 910.256.9277 www.withersravenel.com I License No. C-0832
Asheville I Cary Greensboro I Pittsboro I Raleigh I Wilmington

Neuse River WRF - Little Creek Transmission Improvements 40 WitherSRavene l
Clayton, Johnston Co. ■o
Our People. Your Success.
useful life, expiration of its existing contract with the County, and known near term demands for
wastewater treatment.
The proposed project consists of the following:
Neuse River WRF - Construction of the Neuse River WRF, which will be a 6 MGD facility
constructed at the current site of the pump station that serves as the outfall for the LCWRF
(Lat: 35.664901°N;-78.428642°W), which will be incrementally expanded to 10 MGD to
meet future needs. The LCWRF is being replaced for several reasons, including it being
located within the 100-year flood plain and subject to frequent flooding, it is currently at
maximum capacity and is beyond its life expectancy. The Little Creek WRF is prone to
flooding, and the construction of the Neuse River WRF outside of the 100-year floodplain
will increase the reliability of the Town's treatment capacity and improve provisions for
continuity of service during storm events. The construction of the Neuse River WRF will
not result in impacts to wetlands, streams, or riparian buffers. At this time, only the clearing
and preliminary grading of the WRF site is proposed and impacts will not be required. The
actual design, permitting and construction of the WRF (structures, buildings, piping,
utilities, stormwater management, etc.) will ultimately be determined by the design/build
contractor and therefore a design plan for the WRF is not provided. The WRF early grading
design and sediment & erosion control design is depicted in the construction drawings for
"Access Road/WRF Early Grading Contract" which are attached to this application. Please
note that the replacement/construction of the new outfall into the Neuse River is not part
of this application, as the final design of the outfall and dewatering plan are not complete.
The replacement/construction of the outfall will be permitted by the contractor upon
completion of design.
NRWRF Access Road - Construction of the access road for the Neuse River WRF. The
proposed access road will be located on the eastern side of the high voltage overhead
power line easement and will provide access from N. O'Neil Street (Lat: 35.669383°N;
Long:-78.441600°W) to the proposed Neuse River WRF. This alignment will provide direct
access to the Neuse River WRF and avoid the use of surrounding subdivision streets during
construction of the Neuse River WRF facility. The construction of the access road will not
require impacts to wetlands, streams, or riparian buffers. The construction drawings for
"Access Road/WRF Early Grading Contract" show the design for the access road.
• Little Creek Transmission Lines Improvements - The Little Creek transmission line
improvements consist of:
o Construction of a new pump station at the LCWRF and 4,595 If of 24" force main
beginning at the current Little Creek WRF (Lat: 35.641237°N; Lat:-78.463271°W)
and running east, ending approximately 130 If east of East Front Street (Lat:
35.643700°N; Long:-78.449439°W).
o Construction of 3,590 If of 24" gravity sewer, 1,067 If of 30" gravity sewer, 5,890
If of 36" gravity sewer, 805 If of gravity sewer and 800 If of 48" gravity sewer
beginning at the terminus of the proposed force main (Lat: 35.643700°N; Long: -
78.449439°W) and running northeast to the proposed Neuse River WRF (Lat:
35.663859°N; Lat:-78.426732°W).
The Town's existing wastewater treatment capacity is 4.9 MGD via its Little Creek WRF (2.5 MGD)
and wholesale contracts with Johnston County (County) for 1.4 MGD and the City of Raleigh (City)
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Neuse River WRF - Little Creek Transmission Improvements 40 WitherSRavene l
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Our People. Your Success.
for 1.0 MGD. The Town has an existing agreement with the County to provide 1.4 MGD of
pretreated industrial wastewater which will expire in 7/1/2022. The County has made the
decision to not accept any wastewater with characteristics exceeding domestic -strength limits
beginning beyond the expiration of the current contract. With the known increase in industrial
wastewater from existing industrial and commercial customers including Grifols and Novo Nordisk,
the Town must construct the proposed Neuse WRF to handle this demand or else these facilities
could potentially be forced to relocate, resulting in a significant economic impact to the Town and
County from loss of jobs and tax base.
Under the current agreement with the City, the Town conveys domestic -strength wastewater
from the northeastern side of Clayton using the Clayton to Raleigh Pump Station at the City's
NRWWTP. The City has indicated the current contract from 1.0 MGD maximum monthly capacity
could be extended from 2027 to 2032. However, the City is also experiencing growth and with
the growing demand from its customers, the City has indicated that it is not interested in
supporting economic development beyond its retail base in eastern Wake County by expanding
the current agreement with the Town after 2032. Therefore, to assure that the Town can provide
the needed wastewater treatment capacity beyond 2032, the Neuse River WRF is necessary.
The proposed pump station, force main and gravity sewer are necessary to convey wastewater
currently received at the LCWRF to the proposed Neuse River WRF. The proposed force main
line is necessary to transfer wastewater over the natural ridge at East Main Street and into the
proposed gravity sewer line.
The proposed project includes repurposing the existing treated water outfall and proposed gravity
sewer to convey all future raw water flows to the new Neuse River WRF. At the discharge of the
proposed force main to the proposed gravity sewer, there are two other pipes in the ground: one
gravity of the treated effluent for discharge to the Neuse River and one force main conveying raw
sewer to the existing Little Creek WRF. The existing treated water effluent will be repurposed to
convey raw sewage. The existing raw water force main is no longer in use and will be removed as
needed for the proposed project. Approximately 3,110 LF below the force main discharge, another
raw gravity sewer parallels the existing force main and treated effluent gravity sewer. This new
raw sewer line will be dug up and replaced, as is feasible to avoid additional stream impacts, with
a larger capacity line for approximately 5,972 LF. The last portion of the proposed sewer from the
transmission easement to the river will not replace the existing raw sewer but parallel it. This will
keep the proposed gravity sewer out of the floodplain and provide a bypass should repairs need
to be made in the existing sewer. It will be upsized to allow for additional raw water sewer
connections.
There is one gravity sewer that is currently discharging into the exiting Neuse 2 pump station next
to the Neuse River. This sewer will be rerouted to the influent pump station within the new Neuse
River WRF.
The project will be constructed using traditional commercial construction equipment and
trench/backfill construction.
Project History
The proposed project required approval by the NCDEQ-Division of Water Infrastructure (DWI)
for State Revolving Fund (SRF) funding. As part of the DWI application process, an Environmental
Impact Document (EID) was prepared by Jacobs and submitted for review and approval. The
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Neuse River WRF - Little Creek Transmission Improvements 140 withers Rave n e l
Clayton, Johnston Co. Rio Our People. Your Success.
project received a FONSI from both the State Clearinghouse and NCDEQ-DWI. Copies of the
FONSIs have been attached to this application, along with the EID.
The USACE field verified the delineation for the Neuse River WRF site on 7/22/2020 (AID: SAW-
2020-00777) as documented in the attached email from Chris Hopper with the USACE dated
12/15/2020. We are requesting issuance of a PJD for the Neuse WRF site in conjunction with
issuance of the NWP 12.
NCDWR issued a buffer determination letter for the Neuse River WRF site on 5/11/2020
(RRO#20-131) which has been attached to this application.
WithersRavenel completed a wetland/buffer delineation for the Neuse WRF Access Road
alignment and Little Creek transmission lines in March 2020. A Preliminary JD Exhibit and
wetland/upland data forms in support of the delineation have been attached to this application.
Please note that we are not requesting issuance of a PJD for this project.
All depicted streams within the Little Creek transmission line alignment were present in the field
and subjectivity to Neuse River Riparian Buffers is conceded and a formal buffer determination
from NCDWR was not requested.
There are no depicted streams within the Neuse WRF Access Road alignment and therefore a
formal buffer determination from NCDWR was not requested.
Proposed Impacts
Construction of the proposed sewer force main and gravity sewer lines will result in 213 If of
temporary stream impacts, 0.082 ac of temporary wetland impacts, 7,707 sf of permanent riparian
buffer impacts and 17,528 sf of temporary riparian buffer impacts.
The proposed 213 If of temporary stream impacts and 0.082 acres of temporary wetland impacts
are necessary for construction of the proposed sewer force main and gravity sewer lines. Impacts
to these features will occur within the existing cleared/maintained easement where possible, as
well as the additional 5 ft of new permanent easement to accommodate the gravity sewer line.
The project will result in 0.082 acres of permanent wetland conversion as a result of
mowing/maintenance of the permanent sewer easement in perpetuity which will permanent
convert forested wetlands to herbaceous wetlands.
The proposed 7,707 sf of permanent riparian buffer impacts will result from clearing of riparian
buffer within the additional 5 ft of new permanent easement which will be mowed/maintained in
perpetuity.
The proposed 17,528 sf of temporary riparian buffer impacts will result from the 10 ft temporary
construction easement necessary for access during construction.
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Neuse River WRF - Little Creek Transmission Improvements
Clayton, Johnston Co.
Avoidance and Minimization
4: WithersRavenel
Our People. Your Success.
Prior to site plan design, the applicant requested that a detailed wetland delineation be conducted
so that impacts to wetlands and "waters" could be minimized.
Proposed impacts have been minimized to only temporary impacts necessary for construction of
the new sewer force main and new gravity sewer to convey wastewater flow received at the
current LCWRF to the proposed Neuse River WRF.
Wetland, stream, and riparian buffer impacts have been minimized by utilizing the existing
cleared/maintained easement as much as possible. The proposed force main will be located
entirely within existing easement and roads. There are no proposed wetland or stream impacts
necessary for construction of the proposed force main, and only minimal riparian buffer impacts.
The proposed gravity sewer will be located within the existing easement where possible.
However, there is an existing reuse line and gravity sewer line currently in the easement. In order
to meet separation requirements from the existing lines, an additional 5 ft of permanent easement
must be acquired and cleared.
During construction, installation of the sewer line at the stream crossings will be conducted in the
dry using either a bypass pump around option or bypass swale option to bypass stream flow
around the construction areas (see Sheet 116 of Impact Maps). It will be up to the discretion of
the contractor on which method is the best option for each crossing.
All temporarily impacted streams will be restored to preconstruction grades and the banks
stabilized with biodegradable matting. No matting will be placed on the stream beds. The banks
will be seeded with a riparian seed mix to provide temporary stabilization until natural regeneration
of vegetation in the vicinity permanently stabilizes the banks.
Temporarily impacted wetlands within the permanent easement will be restored to natural grade
and seeded with a wetland seed mix to stabilize these areas. The wetlands within the permanent
easement will be mowed/maintained in perpetuity permanently converting these areas to
herbaceous wetlands.
Temporarily impacted wetlands within the 10 ft temporary access easement will be restored to
natural grade and seeded with a wetland seed mix. These areas will not be maintained and will be
allowed to return to forested wetlands.
Temporarily impacted riparian buffers within the 10 ft temporary construction easement will be
restored to natural grade and seeded with a riparian seed mix to restore the riparian buffer, which
will be enhanced by natural revegetation of surrounding vegetation.
Access during construction will occur from uplands where possible and will be restricted to the
project corridor as defined within the impact exhibits. Silt fencing will be installed around all
disturbed areas to prevent loss of sediment into adjacent waters.
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Neuse River WRF - Little Creek Transmission Improvements
Clayton, Johnston Co.
Mitigation
4: WithersRavenel
Our People. Your Success.
All proposed wetland and stream impacts are temporary and therefore mitigation is not proposed.
Additionally, "permanent wetland conversion" impacts are less than 0.10 acres and therefore
mitigation is not proposed.
All proposed riparian buffer impacts are classified as "Allowable Upon Authorization" except for
Impact B21B. Impact B21B is a non -perpendicular sewer crossing resulting from the additional 5
ft of new permanent easement, which will impact 944 sf within Zone 1. Mitigation is required at
a 3:1 ratio for Zone 1 impacts, resulting the requirement of 2,832 sf of riparian buffer mitigation.
The applicant proposes to provide the 2,832 sf of riparian buffer mitigation through purchase of
riparian buffer credits from EBX in one of their various mitigation banks. The Statement of
Availability from EBX for the buffer mitigation has been attached to this application.
Threatened & Endangered Species
During preparation of the EID, Jacobs and WithersRavenel consulted with the USFWS and
NCWRC for determination of the proposed project's potential effects on listed threatened and
endangered species, as well as species proposed for listing under the Endangered Species Act.
Through consultation with USFWS and NCWRC, it was determined that construction of the
proposed Neuse River WRF, access road Little Creek transmission lines would have "No Effect"
on bald eagle, red -cockaded woodpecker and Michaux's sumac. Additionally, it was determined
that the construction of the proposed Access Road and Little Creek Transmission Line would have
"No Affect" on dwarf wedgemussel, Tar River spinymussel, yellow lance, Atlantic pigtoe, Neuse
River waterdog or Carolina madtom as noted on pages 7-40 & 7-41 in the attached "Clayton WRF
Capacity Expansion-ER-EID-CS370431-07-20201007" document.
It was determined that the construction of the new outfall within the Neuse River, which is not
part of the proposed project under this application, may affect but is not likely to adversely affect
dwarf wedgemussel, Neuse River waterdog and Carolina madtom as noted on pages 7-40 & 7-41
in the attached "Clayton WRF Capacity Expansion-ER-EID-CS370431-07-20201007" document.
Through consultation with USFWS and NCWRC it was determined that surveys for Neuse River
waterdog would be conducted and has begun. Additionally, a survey for mussels within the WRF
outfall project area and salvage and relocation if necessary, would be completed prior initiation of
construction of the outfall in the Neuse River.
During the Division of Water Infrastructure's review of the EID, John Ellis with USFWS stated in
an email dated 10/27/2020 that the USFWS concurs with the effect determinations specified in
the EID. The USFWS email has been provided as an attachment to this application.
NCWRC issued a comment letter dated 10/8/2020 during the Division of Water Infrastructure's
review of the EID with their recommendations for the project. All NCWRC's recommendations
were incorporated in the proposed project. NCWRC's comment letter has been provided as an
attachment to this application.
Cumulative Impact Analysis
Secondary impacts to wetlands, groundwater, and water resources are not expected as a result of
the 6-MGD WRF capacity expansion because the expansion is supporting existing and near -term
development already in progress rather than stimulating new development with its associated
impacts.
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Neuse River WRF - Little Creek Transmission Improvements 40 WitherSRavene l
Clayton, Johnston Co. ■o
Our People. Your Success.
Cumulative impacts to wetlands, groundwater, and water resources as a result of the proposed
project are not expected to be significant because of water supply watershed protections; Neuse
River watershed stream buffer requirements; and other plans, ordinances, and regulatory
requirements designed to minimize and mitigate those impacts. The NPDES permitting process
accounts for the potential for cumulative impacts to a waterway from the project and other
dischargers.
The potential for secondary impacts to wetlands and streams in the study area will be limited by
the continued implementation of stormwater management and programs, such as the protection
of stream buffers. Increases in both the quality and quantity of stormwater runoff as a result of
development and the addition of impervious area can alter the natural hydrology of an area. As
imperviousness increases, the more impacted surface waters become from contaminants,
increased runoff, flooding potential, and associated stream channel changes. The cumulative
effects of stormwater runoff are evident in the frequent correlation between the location of a
stream and its water quality, where urban streams overall have poorer water quality than rural
streams.
Final development plans must be approved by the Town. USACE and state permitting are also
required for fill-in wetlands or streams. Wetlands adjacent to streams are also protected, in part,
by stream buffer rules and limits on floodplain development. These buffers and wetlands provide
important filtering of runoff, helping to limit SCIs from development to water resources.
Implementation and enforcement of these programs will prevent significant SCIs to wetlands and
water resources in the study area.
The Town's LCWRF currently discharges into the Neuse River. While additional treated effluent
will be discharged, the location is not changing. During the major NPDES permit modification
request process, water quality modeling of the Neuse River was conducted to confirm that this
expanded discharge would not cumulatively impact the Neuse River. Modeling was conducted far
downstream of the outfall location and considered other discharges, including the JCRWWTP, to
consider cumulative impacts. DO levels in the river are projected to be protected. In addition, the
Neuse River watershed has a nitrogen credit trading program to limit nutrient loading into the river
and reduce cumulative impacts to the Neuse River estuary. The Town has purchased the
equivalent of 6 MGD of nitrogen credits. With the granting of speculative limits, the modified
NPDES permit, and the purchase of additional nitrogen credits, SCIs to the Neuse River are not
expected (Appendix B).
Land use activities and growth in the study area could impact groundwater quality by introducing
toxic contaminants into or onto the soil, where they could seep into the water table. Such pollution
can contaminate drinking water wells for communities and individual homes, making them
unsuitable for potable water use. Potential sources of groundwater contamination include:
• Solid waste disposal sites
• Storage or use of hazardous substances
• Poorly designed or maintained septic systems
• Accidental spills
• Leaking underground storage tanks
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Neuse River WRF - Little Creek Transmission Improvements 140 withers Rave n e l
Clayton, Johnston Co. Rio Our People. Your Success.
These potential SCIs resulting from land use activities would likely not be significantly different
from the No Action alternative. Overall, SCIs associated with increases in capacity beyond 6 MGD
are not expected to be significant.
The current request is for 213 If of temporary stream impacts, 0.082 ac of temporary wetland
impacts, 7,707 sf of permanent riparian buffer impacts and 17,528 sf of temporary riparian buffer
impacts (see the attached maps and PCN for details).
Please feel free to call if you have questions or require additional information.
Sincerely,
WithersRavenel
Troy Beasley
Senior Environmental Scientist
Attachments:
• PCN Form
• Agent Authorization
• Figure 1 - Overall Aerial Exhibit
• Figure 2 - Aerial-Topo Exhibit
• Figure 3 - Wetland/Stream/Buffer Location Exhibits
• Figure 4 - USGS Location Exhibit
• Figure 5 - USGS Quad Exhibit
• Figure 6 - Johnston County Soil Survey
• USACE Email Confirming Field Verification of Delineation for Neuse River WRF site
• NCDWR Buffer Determination Letter for Neuse River WRF Site
• Preliminary JD Exhibit and Wetland/Upland Data Forms for Little Creek Transmission Lines
• SHPO Comment Letters
• USFWS Email Comments for EID Review
• NCDWR Comment Letter for EID Review
• State Clearinghouse FONSI
• NCDEQ-DWI FONSI
• Cumulative Impacts Analysis
• Engineering Report/Environmental Impact Document
• Neuse River WRF and Access Road Construction Drawings
• Wetland/Stream/Riparian Buffer Impact Exhibits
Page 8 of 8