20201736 Ver 1_More Info Received_20210216

From:Jon Swaim
To:Trone, Rick V
Cc:Dailey, Samantha J CIV USARMY CESAW (USA)
Subject:[External] RE: Elm City Wastewater Improvements request for additional information. DWR# 20201736
Date:Tuesday, February 16, 2021 8:58:30 AM
Attachments:image004.png
image001.png
SAW-2020-00208 Elm City Wastewater System Improvements NWP 12 Verification.pdf
03 G-003 OVERALL PLAN.pdf
Elm City WWTP Project - Parcel Map.pdf
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Hi Rick, Thanks for your comments. Please find our responses in red text below. I have attached the
NWP 12 verification form the Corps and two figures showing property boundaries of the Town
owned parcels.

Let me know if you have any questions or need additional information. Thank you,

Jon Swaim
Project Manager
McGill Associates, P.A.
1240 19th Street Lane NW, Hickory, NC 28601T 828.328.2024C [e-mail]
mcgillassociates.com

From: Trone, Rick V <[e-mail]>
Sent: Monday, February 15, 2021 2:50 PM
To: Jon Swaim <[e-mail]>
Cc: Dailey, Samantha J CIV USARMY CESAW (USA) <[e-mail]>
Subject: Elm City Wastewater Improvements request for additional information. DWR# 20201736

On November 11, 2020, the Division of Water Resources (Division) received your application
requesting a 401 Water Quality Certification from the Division for the subject project. The Division
has determined that your application is incomplete and cannot be processed. The application is on-
hold until all of the following information is received:

Please verify the US Army Corps of Engineers have authorized use of the Nationwide Permit
that is to be used for this project [15A NCAC 02H .0502(a)(7)]. See attached NWP 12
verification.
Please provide more details regarding avoidance and minimization of wetland impacts for this
project. [15A NCAC 02H .0506(b)(1)]
1. This Office believes that the proposed access road can be moved or reconfigured to
avoid or minimize impacts to wetlands. Please revise the plans to minimize the
impacts or provide a detailed explanation of why this plan for the activity cannot be
practically accomplished, reduced or reconfigured to better minimize disturbance to
wetlands. On the provided plans and diagrams, the road through wetlands appears to
be 30’ wide in one section and 16’ wide in another. Please explain why the entire
proposed road through wetlands cannot be reduced to 16’ (or less) in width through
wetlands, thereby reducing wetland impacts. The proposed access road elevation is
nearly at existing grade as it enters Wetland 1 from the south. As the road continues
to the north through Wetland 1, the existing ground elevation drops from
approximately 126’ to 122’ in the center of the wetland. The widening of the impact
area within Wetland 1 is due to the fill and 1.5:1 side slopes required to bring the road
up to the elevation which will allow for the 36” Class IV RCP culverts. The culvert size
was based on a 10-year storm event. Plan sheet C-203 shows the proposed grading
and profile elevations of the proposed road crossing. Our impact map was based on
these proposed grading limits.

2. This Office believes that the proposed access road can be moved to avoid wetland
and buffer impacts. Please revise the plans to avoid the impacts or provide detailed
explanation of why this plan for the activity cannot be accomplished by routing the
proposed road in an alternate location (e.g., dirt road south of site that connects HWY
301 and Homestead Road). The irrigation force main and access road are proposed to
be installed primarily within a relic road bed area that has been out of use for quite
some time. The former road location can be seen in Google maps -
https://goo.gl/maps/DAgWbjoZCTQZ6veW8. The proposed road is needed for
maintenance and emergency access. The Town of Elm City properties (existing WWTP
and proposed waste irrigation property) adjoin along the UT to Town Creek for
approximately 900 linear feet. A utility easement carrying the proposed sewer line
and road was not available through adjoining properties. As a result, this 900 ft area is
the only viable access from the existing WWTP property to the proposed irrigation
property to the north. See the attached parcel map and plan sheet G-003. McGill and
the Town chose this crossing location since it has the narrowest wetland width within
the 900 ft area, it is to the north and outside of a large open water area, and contains
the relic road bed. It is our opinion that this area will result in the least wetland and
buffer impacts available to the Town and has been designed to ensure unrestricted
transmission of water through the system.

Pursuant to Title 15A NCAC 02H .0502(e), the applicant shall furnish all of the above requested
information for the proper consideration of the application. Please respond in writing within 30
calendar days of receipt of this letter by sending one (1) copy of all of the above requested
information as a reply to this email or by submitting all of the above requested information through
this link: https://edocs.deq.nc.gov/Forms/Supplemental-Information-Form (note the DWR#
requested on the link is referenced above).

If all of the requested information is not received within 30 calendar days of receipt of this letter, the
Division will be unable to approve the application and it will be denied as incomplete. The denial of
this project will necessitate reapplication to the Division for approval, including a complete
application package and the appropriate fee.

Please be aware that you have no authorization under the Section 401 of the Clean Water Act for
this activity and any work done within waters of the state may be a violation of North Carolina
General Statutes and Administrative Code.

Thank you,

Rick Trone
401 & Buffer Permitting Branch
NCDEQ – Division of Water Resources

[phone] office
512 N. Salisbury Street, Suite 942-F, Raleigh, NC 27604
1617 Mail Service Center, Raleigh, NC 27699-1617

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