HomeMy WebLinkAbout20211619 Ver 1_ePCN Application_20211105DW R
mrlsloa of ware. Resources
Pre -Construction Notification (PCN) Form
For Nationwide Permits and Regional General Permits
(along with corresponding Water Quality Certifications)
June 1, 2021 Ver 4.1
Initial Review
Has this project met the requirements for acceptance in to the review process?*
Yes
No
Is this project a public transportation project?*
Yes No
Change only if needed.
BIMS # Assigned*
20211619
Is a payment required for this project?
No payment required
Fee received
Fee needed - send electronic notification
Reviewing Office*
Raleigh Regional Office - (919) 791-4200
Information for Initial Review
1a. Name of project:
Town of Clayton Neuse River WRF Outfall
la. Who is the Primary Contact?*
Troy Beasley
1 b. Primary Contact Email:
tbeasley@withersravenel.com
Date Submitted
11/5/2021
Nearest Body of Water
Neuse River (Stream Index: 27-(38.5)
Basin
Neuse
Water Classification
WS-IV:NSW
Site Coordinates
Latitude:
Longitude:
35.664713
-78.430684
A. Processing Information
County (or Counties) where the project is located:
Johnston
Is this a NCDMS Project
Yes No
Is this project a public transportation project?*
Yes No
Pre -Filing Meeting Information
Is this a courtesy copy notification?*
Yes No
Version# *
1
What amout is owed?*
$240.00
$570.00
Select Project Reviewer*
Colleen Cohn:eads\cmcohn
1c. Primary Contact Phone:*
(910)509-6512
ID#
Version
Pre -fling Meeting or Request Date
8/31 /2021
Attach documentation of Pre -Filing Meeting Request here:
Click the upload button or drag and drop files here to attach document
DWR Pre -Filing Meeting Request Form_2021-08-31.pdf
File type must be PDF
1a. Type(s) of approval sought from the Corps:
Section 404 Permit (wetlands, streams and waters, Clean Water Act)
Section 10 Permit (navigable waters, tidal waters, Rivers and Harbors Act)
Has this PCN previously been submitted?
Yes
No
1 b. What type(s) of permit(s) do you wish to seek authorization?
Nationwide Permit (NWP)
Regional General Permit (RGP)
Standard (IP)
1c. Has the NWP or GP number been verified by the Corps?
Yes No
Nationwide Permit (NWP) Number: 7 - Outfall Structures/ Intake
NWP Numbers (for multiple NWPS):
1d. Type(s) of approval sought from the DWR:
401 Water Quality Certification - Regular
Non-404 Jurisdictional General Permit
Individual 401 Water Quality Certification
le. Is this notification solely for the record because written approval is not required?
For the record only for DWR 401 Certification:
For the record only for Corps Permit:
1f. Is this an after -the -fact permit application?"
Yes No
1g. Is payment into a mitigation bank or in -lieu fee program proposed for mitigation of impacts?
Yes No
1g. Is payment into a mitigation bank or in -lieu fee program proposed for mitigation of impacts?
Yes No
1 h. Is the project located in any of NC's twenty coastal counties?
Yes No
1j. Is the project located in a designated trout watershed?
Yes No
B. Applicant Information
1d. Who is applying for the permit?
Owner Applicant (other than owner)
le. Is there an Agent/Consultant for this project?"
Yes No
2. Owner Information
2a. Name(s) on recorded deed:
Town of Clayton
2b. Deed book and page no.:
04697;0849
2c. Contact Person:
Rich Coppola
48.88KB
401 Water Quality Certification - Express
Riparian Buffer Authorization
Yes No
Yes No
2d.Address
Street Address
PO Box 879
Address Line 2
City
Clayton
Postal / Zip Code
27528
2e. Telephone Number:
(910)553-5002
2g. Email Address:*
rcappola@townofclaytonnc.org
4. Agent/Consultant (if applicable)
4a. Name:
Troy Beasley
4b. Business Name:
WithersRavenel
4c.Address
Street Address
219 Station Road
Address Line 2
Suite 101
City
Wilmington
Postal / Zip Code
28405
4d. Telephone Number:
(910)509-6512
4f. Email Address:
tbeasley@withersravenel.com
C. Project Information and Prior Project History
1. Project Information
1 b. Subdivision name:
(if appropriate)
1c. Nearest municipality / town:
Clayton
2. Proiect Identification
2a. Property Identification Number:
05H02199W
2c. Project Address
Street Address
East of the eastern terminus of Atwood Drive
Address Line 2
City
Clayton
Postal / Zip Code
27520
3. Surface Waters
3a. Name of the nearest body of water to proposed project:
Neuse River (Stream Index: 27-(38.5)
3b. Water Resources Classification of nearest receiving water:
WS-IV;NSW
3c. What river basin(s) is your project located in?*
Neuse
State / Province / Region
NC
Country
USA
2f. Fax Number:
State / Province / Region
NC
Country
USA
4e. Fax Number:
2b. Property size:
78.54
State / Province / Region
NC
Country
USA
3d. Please provide the 12-digit HUC in which the project is located.
030202011103
4. Project Description and History
4a. Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of this application: *
The project site consists primarily of undeveloped woodlands. The existing Neuse 2 pump station is located within the project site, which discharges treated effluent from the Little Creek
WRF into the Neuse River through an existing outfall into the Neuse River.
The general land use in the vicinity of the project consists of a mixture of agricultural, residential and commercial land uses.
4b. Have Corps permits or DWR certifications been obtained for this project (including all prior phases) in the past?
Yes No Unknown
4f. List the total estimated acreage of all existing wetlands on the property:
9.62 acres
4g. List the total estimated linear feet of all existing streams on the property:
2,180 If
4h. Explain the purpose of the proposed project:
The purpose of the proposed project is to construct a new 30" outfall for the new Neuse River WRF. The existing 24" outfall does not provide sufficient discharge capacity for a 6 MGD
facility and therefore the 30" outfall is needed for additional capacity. The existing 24" outfall will remain in operation, and the WRF will ouffall through both the 24" and 30" outfalls.
The Neuse River WRF will 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 useful life, expiration of its existing contract with the County, and known near term demands for wastewater treatment.
The Neuse River WRF will be a 6 MGD facility constructed at the current site of the Neuse 2 pump station that serves as the ouffall 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 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) 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 711/2022. 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 ofjobs 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.
41. Describe the overall project in detail, including indirect impacts and the type of equipment to be used:
The proposed 30" outfall has been designed to match the invert of the existing 24" ouffall and will be suspended in the water column below the normal surface water elevation of the Neuse
River (134.90'). The new outfall will not sit on the river bottom and therefore will not result in permanent impacts. The details of the ouffall design and construction can be found in the
attached Outfall Detail Plans.
The proposed 30" outfall will be supported by a concrete encasement constructed within the bank of the Neuse River, which will be armored with riprap to stabilize the bank and protect the
support structure from erosion. Refer to the attached Ouffall Detail Plans and Temporary Shoring Plan for detail on the construction of the 30" outfall, support structure and sheet pile coffer
dam, which have been attached to this application.
The proposed project also consists of construction of an overhead power line to provide electricity to the Neuse River WRF site, which will connect to the existing substation on the western
edge of the property. There will be a 30' overhead power easement established for the power line. The construction of the overhead power line will not result in impacts to Stream 3, as the
power poles will be located well away from the stream, and access across Stream 3 is not needed for construction of the overhead powerline.
The project will be constructed using traditional commercial construction equipment. In order to construct the new 30" outfall, concrete encasement and riprap protection of the river bank a
sheet pile coffer dam will be installed by driving interlocking sheet piles with a pile driving hammer. The construction area will then be dewatered by pumping the water out of the
construction area into the Neuse River. Once construction is complete, the water will be pumped back into the construction area and the sheet piles will be removed.
5. Jurisdictional Determinations
5a. Have the wetlands or streams been delineated on the property or proposed impact areas?*
Yes
No
Comments:
Chris Hopper with the USACE field verified the delineation on 7/22/2020 as documented in the
concurrence email dated 12/15/2020, which has been provided as an attachment
5b. If the Corps made a jurisdictional determination, what type of determination was made?*
Preliminary Approved Not Verified Unknown N/A
Corps AID Number:
SAW-2020-00777
5c. If 5a is yes, who delineated the jurisdictional areas?
Name (if known): Troy Beasley
Unknown
Agency/Consultant Company: WithersRavenel
Other:
5d. List the dates of the Corp jurisdiction determination or State determination if a determination was made by the Corps or DWR
Chris Hopper with the USACE field verified the delineation for the WRF site on 7/22/2020 as documented in the concurrence email dated 12/15/2020, which has been provided as an
attachment (AID: SAW-2020-00777).
NCDWR issued a Buffer Determination Letter (RRO #20-131) for the WRF site on 5/11/2020. A copy of the Buffer Determination Letter has been provided as an attachment.
6. Future Project Plans
6a. Is this a phased project?*
Yes No
Are any other NWP(s), regional general permit(s), or individual permits(s) used, or intended to be used, to authorize any part of the proposed project or related activity?
The sewer transmission lines that will flow to the proposed Neuse River WRF were previously permitted as a separate project (Little Creek Transmission Improvements) as the final design
of the WRF site was not complete at the time of submittal. The Little Creek Transmission Improvements project was issued a USACE NWP 58 (SAW-2020-00777) on 3/24/2021 and
NCDWR 401 WQC & Buffer Authorization (Proj #20201550) on 3/11/2021 for temporary wetland, temporary stream and temporary/permanent riparian buffer impacts for construction of the
new transmission line within the existing sewer easement.
D. Proposed Impacts Inventory
1. Impacts Summary
1a. Where are the impacts associated with your project? (check all that apply):
Wetlands Streams -tributaries Buffers
Open Waters Pond Construction
3. Stream Impacts
u
S1
3a. Reason for impact (?)
New WRF Ouffall
Construction
3b.lmpact type*
Temporary
3c. Type of impact*
Workpad/Causeway
3d. S. name*
Neuse River
3e. Stream Type*
(?)
Perennial
[3f. Type of
urisdiction*
Both
3gSwidth"
33
Average (feet)
3h. Impact
length*
30
(linear feet)
S2
Outfall Support Structure
fermanentA
Fill
Neuse River
Perennial
Both
h;;;J�:]_
3i. Total jurisdictional ditch impact in square feet:
0
3i. Total permanent stream impacts:
7
3i. Total stream and ditch impacts:
37
3i. Total temporary stream impacts:
30
3j. Comments:
The stream width and lengths listed in the impact table are the approximate dimensions of the impact area within the Neuse River, as the impact areas
only extend into a portion of the eastern side of the Neuse River.
The installation of the new 30" WRF outfall within the Neuse River will result in 0.02 acres of temporary impacts to the Neuse River for installation of the
sheetpile coffer dam and dewatering in order to allow installation of the outfall pipe to be conducted in the dry. Please note that the outfall pipe has been
designed to match the invert of the existing 24" outfall, and will be suspended in the water column below the normal surface water elevation of the
Neuse River (134.90'). The new outfall will not sit on the river bottom.
The outfall support structure consists of a concrete encasement constructed within the river bank and which is necessary to stabilize the new 30" outfall
in the water column and will result in 0.01 acres of permanent impact to the Neuse River. The proposed permanent impacts are necessary for the riprap
armoring of the bank stabilize the river bank and protect the support structure from erosion.
Refer to the attached Outfall Detail Plans and Temporary Shoring Plan for more details on construction of the 30" outfall, support structure and sheet pile
coffer dam, which have been attached to this application.
6. Buffer Impacts (for DWR)
6a. Project is in which protect basin(s)?
Check all that apply.
Neuse Tar -Pamlico
Catawba Randleman
Goose Creek Jordan Lake
Other
6b. Impact Type
B1 - WRF Outfall Construction - Allowable Upon
Authorization
6c. Per or Temp
f
6d. Stream name
Neuse River & Sams Branch
6e. Buffer mitigation required?
No
6C Zone 1 impact
2,647
6g. Zone 2 impact
2,454
B2 -Overhead Power Line Easement -Deemed
Allowable
P
1�
Stream 3
No
=::
ff
1,333
6h. Total buffer impacts:
Zone 1 Zone 2
Total Temporary impacts: 0.00 0.00
Zone 1 Zone 2
Total Permanent impacts: 5,094.00 3,787.00
Zone 1 Zone 2
Total combined buffer impacts: 5,094.00 3,787.00
61. Comments:
See PCN Cover Letter for additional information on proposed buffer impacts.
E. Impact Justification and Mitigation
1. Avoidance and Minimization
1a. Specifically describe measures taken to avoid or minimize the proposed impacts in designing the project:
The Neuse River WRF facility has been designed to avoid impacts to wetlands and streams except for those impacts necessary for construction of the
new 30" outfall. The 30" outfall is necessary to provide additional discharge capacity needed for a 6 MGD facility. Since the WRF must discharge into the
Neuse River, impacts to the Neuse River could not be avoided entirely.
The new 30" outfall has been designed to minimize impacts within the Neuse River. Permanent impacts (0.01 acres) within the Neuse River are
necessary for the riprap armoring of the riverbank for stabilization and protection of the outfall support structure from erosion.
Buffer impacts have been minimized to only those necessary for construction of the 30" outfall (Allowable Upon Authorization) and the overhead power
line (Deemed Allowable). There are no stream impacts necessary for construction of the overhead power line.
In order to construct the new 30" outfall, concrete encasement and riprap protection of the river bank a sheet pile coffer dam will be installed by driving
interlocking sheet piles with a pile driving hammer. The construction area will then be dewatered by pumping the water out of the construction area into
the Neuse River. Once construction is complete, the water will be pumped back into the construction area and the sheet piles will be removed.
1 b. Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques:
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.
2. Compensatory Mitigation for Impacts to Waters of the U.S. or Waters of the State
2a. Does the project require Compensatory Mitigation for impacts to Waters of the U.S. or Waters of the State?
Yes No
2b. If this project DOES NOT require Compensatory Mitigation, explain why:
Proposed permanent impacts within the Neuse River are less than 0.01 acres and therefore the applicant is not proposing mitigation.
F. Stormwater Management and Diffuse Flow Plan (required by DWR)
1. Diffuse Flow Plan
1a. Does the project include or is it adjacent to protected riparian buffers identified within one of the NC Riparian Buffer Protection Rules?
Yes No
What type of SCM are you providing?
Level Spreader
Vegetated Conveyance (lower SHWT)
Wetland Swale (higher SHWT)
Other SCM that removes minimum 30 % nitrogen
Proposed project will not create concentrated stormwater flow through the buffer
2. Stormwater Management Plan
2a. Is this a NCDOT project subject to compliance with NCDOT's Individual NPDES permit NCS000250?
Yes No
2b. Does this project meet the requirements for low density projects as defined in 15A NCAC 02H .1003(2)?
Yes No
2c. Does this project have a stormwater management plan (SMP) reviewed and approved under a state stormwater program or state -approved local government stormwater program?
Yes No
N/A - project disturbs < 1 acre
2d. Which of the following stormwater management program(s) apply:
Local Government State
State Stormwater Programs
Phase II Coastal Counties
HWQ or ORW Other
Comments:
The stormwater management plan consists of one wet detention SCM which has been designed to remove a minimum of 30 % nitrogen, and therefore diffuse flow is not required. The
stormwater management plan will be reviewed and approved by the NCDEQ.
G. Supplementary Information
1. Environmental Documentation
la. Does the project involve an expenditure of public (federal/state/local) funds or the use of public (federal/state) land?*
Yes No
1 b. If you answered "yes" to the above, does the project require preparation of an environmental document pursuant to the requirements of the National or State (North Carolina)
Environmental Policy Act (NEPA/SEPA)?*
Yes No
1c. If you answered "yes" to the above, has the document review been finalized by the State Clearing House?*
Yes No
2. Violations (DWR Requirement)
2a. Is the site in violation of DWR Water Quality Certification Rules (15A NCAC 2H .0500), Isolated Wetland Rules (15A NCAC 2H .1300), or DWR Surface Water or Wetland Standards or
Riparian Buffer Rules (15A NCAC 2B .0200)? *
Yes No
3. Cumulative Impacts (DWR Requirement)
3a. Will this project result in additional development, which could impact nearby downstream water quality?*
Yes No
4. Sewage Disposal (DWR Requirement)
4a. Is sewage disposal required by DWR for this project?*
Yes No N/A
4b. Describe, in detail, the treatment methods and dispositions (non -discharge or discharge) of wastewater generated from the proposed project. If the wastewater will be treated at a
treatment plant, list the capacity available at that plant.
The proposed project consists of the construction of the new 30" outfall for the new Neuse River WRF. The Neuse River WRF will replace the existing
Little Creek WRF and will be the ultimate treatment for wastewater within the basin currently services by Little Creek WRF.
5. Endangered Species and Designated Critical Habitat (Corps Requirement)
5a. Will this project occur in or near an area with federally protected species or habitat?*
Yes No
5b. Have you checked with the USFWS concerning Endangered Species Act impacts?*
Yes No
5c. If yes, indicate the USFWS Field Office you have contacted.
Raleigh
5d. Is another Federal agency involved?*
Yes No
5e. Is this a DOT project located within Division's 1-8?
Yes No
5f. Will you cut any trees in order to conduct the work in waters of the U.S.?
Yes No
5g. Does this project involve bridge maintenance or removal?
Yes No
5h. Does this project involve the construction/installation of a wind turbines)?*
Yes No
Unknown
5i. Does this project involve (1) blasting, and/or (2) other percussive activities that will be conducted by machines, such as jackhammers, mechanized pile drivers, etc.?
Yes No
5j. What data sources did you use to determine whether your site would impact Endangered Species or Designated Critical Habitat?
During preparation of the EID for the Neuse WRF project, 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 during the EID preparation process, it was determined that the construction of the new outfall within the
Neuse River may affect but is not likely to adversely affect dwarf wedgemussel, Neuse River waterdog and Carolina madtom as noted in the attached
excerpt from the "Clayton WRF Capacity Expansion_ER-EID_CS370431-07_20201007" document (pages 7-40 & 741). Through consultation with
USFWS and NCWRC it was determined that surveys for Neuse River waterdog would be conducted. Additionally, a survey for dwarf wedgemussel and
Atlantic pigtoe within the WRF outfall construction 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.
As requested by USFWS and NCWRC, Three Oaks Engineering conducted the Neuse River waterdog (NRWD) surveys on March 9-12, 2021. Surveys
were conducted using a total of 20 traps, with 10 traps placed upstream of the outfall location and 10 traps placed below the outfall to span a stretch of
approximately 200 meters. The results of the NRWD survey were negative, as no NRWD were captured during the trapping efforts. Three Oaks
Engineering prepared an Aquatic Species Interim Survey Report: Neuse River Water Dog Trapping (dated 4/12/2021) documenting the results of their
trapping survey which was submitted the interim report to John Ellis with the USFWS and Gabriela Garrison with NCWRC via email on 5/23/2021 for
review and comment. Neither the USFWS nor NCWRC provided comments on the interim report. Copies of the Three Oaks Engineering email
submitting the interim report to the USFWS and NCWRC has been provided as an attachment to this application.
As requested by USFWS and NCWRC, Three Oaks Engineering conducted the surveys for dwarf wedgemussel and Atlantic pigtoe on 8/25/2021. The
mussel survey was conducted using glass bottom buckets in shallow areas and near banks, as well as scuba equipment for deeper sections. Tactile
methods were employed, particularly in banks under submerged root mats. The survey did not find any dwarf wedgemussel or Atlantic pigtoe. The
survey did identify the presence mussel species listed as threatened by the state, including triangle floater, eastern lampmussel and creeper.
The results of the mussel survey were combined with the results of the NRWD survey in the Aquatics Species Report prepared by Three Oaks
Engineering, dated 10/8/2021, which has been provided as an attachment to this application. The Aquatic Species Report was submitted to the USFWS
and NCWRC via email on 11/05/2021. A copy of the submittal email has been provided as an attachment to this report.
The surveys for NRWD, dwarf wedgemussel and Atlantic pigtoe were negative, which support the USFWS and NCWRC determination that the
construction of the proposed outfall may affect but is not likely to affect these federally listed species.
Prior to installation of the sheet pile cofferdam, Three Oaks Engineering will conduct a salvage and relocation operation within the outfall construction
area. These efforts will consist of location and collection of all mussels within the outfall construction area and relocating them nearby in the Neuse
River.
Therefore, the proposed project is not anticipated to have an adverse effect on federally listed species.
6. Essential Fish Habitat (Corps Requirement)
6a. Will this project occur in or near an area designated as an Essential Fish Habitat?*
Yes No
6b. What data sources did you use to determine whether your site would impact an Essential Fish Habitat? *
WR reviewed the NOAA Essential Fish Habitat online mapper, located at: http://www.habitat.noaa.gov/protection/efh/efhmapper/index.htmi. There are no
waters classified as EFH in Johnston County.
7. Historic or Prehistoric Cultural Resources (Corps Requirement)
7a. Will this project occur in or near an area that the state, federal or tribal governments have designated as having historic or cultural preservation status?*
Yes No
7b. What data sources did you use to determine whether your site would impact historic or archeological resources?*
WithersRavenel submitted a SHPO project review request in March 2020. SHPO issued a comment letter (ER 20-0630) dated 4/20/2020 specifying that
they were not aware of any historic resources that would be affected by the proposed project and therefore have no comment on the project. A copy of
the SHPO comment letter has been provided as an attachment.
8. Flood Zone Designation (Corps Requirement)
Be. Will this project occur in a FEMA-designated 100-year floodplain?*
Yes No
8b. If yes, explain how project meets FEMA requirements:
The proposed outfall construction will occur within the FEMA 100-year floodplain. The outfall will be installed below ground, and will not result affect the
FEMA 100-year floodplain.
8c. What source(s) did you use to make the floodplain determination?*
www.ncfloodmaps.com
Miscellaneous V
Please use the space below to attach all required documentation or any additional information you feel is helpful for application review. Documents should be combined into one file when
possible, with a Cover Letter, Table of Contents, and a Cover Sheet for each Section preferred.
Click the upload button or drag and drop files here to attach document
PCN Cover Letter-PCN Attachments -Impact Maps.pdf 25.91MB
File must be PDF or KMZ
Comments
Signature
By checking the box and signing below, I certify that:
• The project proponent hereby certifies that all information contained herein is true, accurate, and complete to the best of my knowledge and belief'; and
• The project proponent hereby requests that the certifying authority review and take action on this CWA 401 certification request within the applicable reasonable period of time.
• I have given true, accurate, and complete information on this form;
• I agree that submission of this PCN form is a "transaction" subject to Chapter 66, Article 40 of the NC General Statutes (the "Uniform Electronic Transactions Act");
• I agree to conduct this transaction by electronic means pursuant to Chapter 66, Article 40 of the NC General Statutes (the "Uniform Electronic Transactions Act");
• I understand that an electronic signature has the same legal effect and can be enforced in the same way as a written signature; AND
I intend to electronically sign and submit the PCN form.
Full Name:
Troy Beasley - WithersRavenel - Authorized Agent
Signature
�� Iy
Date
11 /5/2021
Contact Name* Lee White
Contact Email Address* Iwhite@gfnet.com
Project Owner* Town of Clayton NC
Project Name* Town of Clayton Water Reclamation Facility
Project County* Johnston
Owner Address:* Street Address
PO Box 879
Address Line 2
aty
State / Province / Pegion
Clayton
NC
Postal / Zip axle
Country
27528
USA
Is this a transportation project?* C Yes c: No
Type(s) of approval sought from the DWR:
F- 401 Water Quality Certification - F- 401 Water Quality Certification -
Regular Express
W Individual Permit F- Modification
F- Shoreline Stabilization
Does this project have an existing project ID#?*
C Yes c: No
Do you know the name of the staff member you would like to request a meeting with?
Colleen Cohn
Please give a brief project description below and include location information.*
1200 n oneil street ext cayton nc 27520
The Town of Clayton NC is in the design phase for construction a
new 6.5 million gallon per day wastewater treatment plant. They are
in posession of their NPDES Permit NC0025453. Discharge is in the
Neuse River.
By digitally signing below, I certify that I have read and understood that per the Federal Clean Water Act Section
401 Certification Rule the following statements:
This form completes the requirement of the Pre -Filing Meeting Request in the Clean Water Act Section 401 Certification
Rule.
1 understand by signing this form that I cannot submit my application until 30 calendar days after this pre -filing
meeting request.
I also understand that DWR is not required to respond or grant the meeting request.
Your project's thirty -day clock started upon receipt of this application. You will receive notification regarding meeting location
and time if a meeting is necessary. You will receive notification when the thirty -day clock has expired, and you can submit an
application.
Signature *
Cu u',t¢c
Submittal Date 8/31/2021
%■ WithersRavenel
.. our People. Your Success.
November 5, 2021
US Army Corps of Engineers NC -Division of Water Resources
Raleigh Regulatory Field Office 401 & Buffer Permitting Unit
Mr. Chris Hopper Mr. Paul Wojoski
3331 Heritage Trade Drive 1617 Mail Service Center
Suite 105 Raleigh, NC 27699
Wake Forest, NC 27587
Re: Town of Clayton - Neuse River WRF Outfall
NWP 7/401 WQC/Buffer Authorization PCN Submittal
Clayton, Johnston County
USACE AID: SAW-2020-00777
NCDWR Proj #20201550
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
7 for 0.02 acres of temporary impact to the Neuse River and 0.01 acres of permanent impact to
the Neuse River for construction of the new 30" outfall for the Neuse River Water Reclamation
Facility (WRF). We are also requesting an NCDWR Riparian Buffer Authorization for 5,101 sf of
permanent riparian buffer impacts for construction of the Neuse River WRF outfall and 3,780 sf
of permanent riparian buffer impacts for construction of an overhead powerline to provide
electricity to the WRF.
The project is located in the Neuse River basin and drains to the Neuse River (HUC: 03020201).
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 construct a new 30" outfall for the new Neuse River
WRF. The existing 24" outfall does not provide sufficient discharge capacity for a 6 MGD facility
and therefore the 30" outfall is needed for additional capacity. The existing 24" outfall will remain
in operation, and the WRF will outfall through both the 24" and 30" outfalls.
The Neuse River WRF will 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 useful life,
expiration of its existing contract with the County, and known near term demands for wastewater
treatment.
The Neuse River WRF will be a 6 MGD facility constructed at the current site of the Neuse 2 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
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 Outfall 4: WitherSRavenel
Clayton, Johnston Co.
Our People. Your Success.
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 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)
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 30" outfall has been designed to match the invert of the existing 24" outfall and will
be suspended in the water column below the normal surface water elevation of the Neuse River
(134.90'). The new outfall will not sit on the river bottom and therefore will not result in permanent
impacts. The details of the outfall design and construction can be found in the attached Outfall
Detail Plans.
The proposed 30" outfall will be supported by a concrete encasement constructed within the bank
of the Neuse River, which will be armored with riprap to stabilize the bank and protect the support
structure from erosion. Refer to the attached Outfall Detail Plans and Temporary Shoring Plan for
detail on the construction of the 30" outfall, support structure and sheet pile coffer dam, which
have been attached to this application.
The proposed project also consists of construction of an overhead power line to provide electricity
to the Neuse River WRF site, which will connect to the existing substation on the western edge of
the property. There will be a 30' overhead power easement established for the power line. The
construction of the overhead power line will not result in impacts to Stream 3, as the power poles
will be located well away from the stream, and access across Stream 3 is not needed for
construction of the overhead powerline.
The project will be constructed using traditional commercial construction equipment. In order to
construct the new 30" outfall, concrete encasement and riprap protection of the river bank a sheet
pile coffer dam will be installed by driving interlocking sheet piles with a pile driving hammer. The
construction area will then be dewatered by pumping the water out of the construction area into
Page 2 of 7
Neuse River WRF Outfall 4: WitherSRavenel
Clayton, Johnston Co.
Our People. Your Success.
the Neuse River. Once construction is complete, the water will be pumped back into the
construction area and the sheet piles will be removed.
Project History
The Neuse River WRF project, which includes the WRF, transmission lines and access road,
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 project received a FONSI
from both the State Clearinghouse and NCDEQ-DWI. Copies of the FONSIs have been attached
to this application. A copy of the complete EID can be provided if requested.
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 not requesting issuance of the PJD for the Neuse WRF site in conjunction
with issuance of the NWP 58.
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.
The sewer transmission lines that will flow to the proposed Neuse River WRF were previously
permitted as a separate project (Little Creek Transmission Improvements) as the final design of the
WRF site was not complete at the time of submittal. The Little Creek Transmission Improvements
project was issued a USACE NWP 58 (SAW-2020-00777) on 3/24/2021 and NCDWR 401 WQC
& Buffer Authorization (Prof #20201550) on 3/11/2021 for temporary wetland, temporary stream
and temporary/permanent riparian buffer impacts for construction of the new transmission line
within the existing sewer easement.
Proposed Impacts
Construction of the proposed 30" outfall for the Neuse River WRF will result in 0.02 acres of
temporary impacts within the Neuse River (Impact S1). The temporary impacts are necessary for
installation of the sheet pile coffer dam and dewatering to allow construction of the outfall,
concrete encasement and riprap armoring to be completed in the dry.
The riprap armoring of the riverbank to protect the concrete encasement support structure from
erosion will result in 0.01 acres of permanent impacts within the Neuse River (Impact S2).
The construction of the new 30' outfall will result in 2,647 sq ft of Zone 1 buffer impacts and 2,454
sq ft of permanent Zone 2 buffer impacts (Impact 131). The proposed impacts are "Allowable Upon
Authorization" in the 2021 Neuse River Riparian Buffer Rules Table of Uses. It should be noted
that riparian buffers within the outfall alignment are currently maintained as mowed grass around
the existing Neuse 2 pump station and there is an existing greenway trail which will be removed
and replaced after construction is complete. The buffers within the outfall alignment will
continued to be maintained as mowed grass after construction is complete.
The construction of the overhead power line to provide electricity to the Neuse River WRF will
result in 2,447 sq ft of permanent Zone 1 buffer impacts and 1,333 sq ft of permanent Zone 2
buffer impacts (Impact 132). The overhead power line will be located within a 30' permanent
easement which will be mowed/maintained periodically in perpetuity. The proposed impacts are
"Deemed Allowable" in the 2021 Neuse River Riparian Buffer Rules Table of Uses.
Page 3 of 7
Neuse River WRF Outfall
Clayton, Johnston Co.
Avoidance and Minimization
r: WithersRavenel
Our People. Your Success.
The Neuse River WRF facility has been designed to avoid impacts to wetlands and streams except
for those impacts necessary for construction of the new 30" outfall. The 30" outfall is necessary
to provide additional discharge capacity needed for a 6 MGD facility. Since the WRF must
discharge into the Neuse River, impacts to the Neuse River could not be avoided entirely.
The new 30" outfall has been designed to minimize impacts within the Neuse River. Permanent
impacts (0.01 acres) within the Neuse River are necessary for the riprap armoring of the riverbank
for stabilization and protection of the outfall support structure from erosion.
Buffer impacts have been minimized to only those necessary for construction of the 30" outfall
(Allowable Upon Authorization) and the overhead power line (Deemed Allowable). There are no
stream impacts necessary for construction of the overhead power line.
In order to construct the new 30" outfall, concrete encasement and riprap protection of the river
bank a sheet pile coffer dam will be installed by driving interlocking sheet piles with a pile driving
hammer. The construction area will then be dewatered by pumping the water out of the
construction area into the Neuse River. Once construction is complete, the water will be pumped
back into the construction area and the sheet piles will be removed.
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.
Mitigation
The proposed permanent impacts to the Neuse River for installation of the riprap armoring are
0.01 acres, and therefore the applicant is not proposing stream mitigation.
All proposed riparian buffer impacts are classified as "Allowable Upon Authorization" and "Deemed
Allowable" and therefore buffer mitigation is not required.
Threatened & Endangered Species
During preparation of the EID for the Neuse WRF project, 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 during the EID preparation process, it was
determined that the construction of the new outfall within the Neuse River may affect but is not
likely to adversely affect dwarf wedgemussel, Neuse River waterdog and Carolina madtom as
noted in the attached excerpt from the "Clayton WRF Capacity Expansion_ER-EID_CS370431-
07_20201007" document (pages 7-42 & 7-44). Through consultation with USFWS and NCWRC it
was determined that surveys for Neuse River waterdog would be conducted. Additionally, a
survey for dwarf wedgemussel and Atlantic pigtoe within the WRF outfall construction 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.
Page 4 of 7
Neuse River WRF Outfall r: WithersRavenel
Clayton, Johnston Co.
Our People. Your Success.
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.
As requested by USFWS and NCWRC, Three Oaks Engineering conducted the Neuse River
waterdog (NRWD) surveys on March 9-12, 2021. Surveys were conducted using a total of 20
traps, with 10 traps placed upstream of the outfall location and 10 traps placed below the outfall
to span a stretch of approximately 200 meters. The results of the NRWD survey were negative,
as no NRWD were captured during the trapping efforts. Three Oaks Engineering prepared an
Aquatic Species Interim Survey Report: Neuse River Water Dog Trapping (dated 4/12/2021)
documenting the results of their trapping survey which was submitted the interim report to John
Ellis with the USFWS and Gabriela Garrison with NCWRC via email on 5/23/2021 for review and
comment. Neither the USFWS nor NCWRC provided comments on the interim report. Copies of
the Three Oaks Engineering email submitting the interim report to the USFWS and NCWRC has
been provided as an attachment to this application.
As requested by USFWS and NCWRC, Three Oaks Engineering conducted the surveys for dwarf
wedgemussel and Atlantic pigtoe on 8/25/2021. The mussel survey was conducted using glass
bottom buckets in shallow areas and near banks, as well as scuba equipment for deeper sections.
Tactile methods were employed, particularly in banks under submerged root mats. The survey did
not find any dwarf wedgemussel or Atlantic pigtoe. The survey did identify the presence mussel
species listed as threatened by the state, including triangle floater, eastern lampmussel and
creeper.
The results of the mussel survey were combined with the results of the NRWD survey in the
Aquatics Species Report prepared by Three Oaks Engineering, dated 10/8/2021, which has been
provided as an attachment to this application. The Aquatic Species Report was submitted to the
USFWS and NCWRC via email on 11/05/2021. A copy of the submittal email has been provided
as an attachment to this report.
The surveys for NRWD, dwarf wedgemussel and Atlantic pigtoe were negative, which support the
USFWS and NCWRC determination that the construction of the proposed outfall may affect but
is not likely to affect these federally listed species.
Prior to installation of the sheet pile cofferdam, Three Oaks Engineering will conduct a salvage and
relocation operation within the outfall construction area. These efforts will consist of location and
collection of all mussels within the outfall construction area and relocating them nearby in the
Neuse River.
Therefore, the proposed project is not anticipated to have an adverse effect on federally listed
species.
Cumulative Impact Analysis
Secondary cumulative 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.
Page 5 of 7
Neuse River WRF Outfall r: WithersRavenel
Clayton, Johnston Co.
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 NCDWR 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.
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
Page 6 of 7
Neuse River WRF Outfall r: WithersRavenel
Clayton, Johnston Co.
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.
Please feel free to call if you have questions or require additional information to complete your
review.
Sincerely,
WithersRavenel
Troy Beasley
Senior Environmental Scientist
Attachments:
• ePCN Form
• Agent Authorization
• Aerial Exhibit
• Approved Delineation Exhibit
• FEMA 100-Year Floodplain Exhibit
• USGS Quad Exhibits
• Johnston County Soil Survey Exhibit
• USACE Email Confirming Field Verification of Delineation (12/15/2020)
• NCDWR Buffer Determination Letter (11-05-2020)
• SHPO Comment Letter (04/20/2020)
• USFWS Email Comments for EID Review (10/27/2020)
• NCDWR Comment Letter for EID Review (10/08/2020)
• Excerpt from the "Clayton WRF Capacity Expansion_ER-EID_CS370431-07_20201007"
document (pages 7-42 & 7-44)
• State Clearinghouse FONSI (11/18/2020)
• NCDEQ-DWI FONSI (11/18/2020)
• Email submitting Aquatic Species Interim Survey Report: Neuse River Water Dog Trapping
(4/12/2021) to the USFWS & NCWRC on 05/23/2021
• Email Submitting Final Aquatic Species Survey Report to USFWS & NCWRC on
11/05/2021
• Three Oaks Engineering Aquatic Species Survey Report (10/8/21)
• Outfall Detail Plans
• Temporary Shoring Plan for Sheet Pile Cofferdam
• Impact Exhibits
Page 7 of 7
■■ WithersRavenel
1i. Our People. Your Success.
AGENT AUTHORIZATION
-40- WithersRavenel
.. Our People. Your Success.
AUTHORITY FOR APPOINTMENT OF AGENT
The undersigned Municipality Town of Clayton (Client) does hereby appoint WithersRavenel. Inc. as
his, her, or it's agent for the purpose of petitioning the appropriate local, state and federal
environmental regulatory agencies (US Army Corps of Engineers, NC Division of Water Quality, NC
Division of Coastal Management, local municipalities, etc.) for: a) review and approval of the
jurisdictional boundaries of onsite jurisdictional areas (wetlands, surface waters, riparian buffers, etc.)
and/or; b) preparation and submittal of appropriate environmental permit applications/requests forthe
following projects listed below located in Johnston County, NC:
• Clayton WWTP - Johnston Co. PIN:166900-96-3988, ±78.5-acre parcel, located east of
Atwood Drive
• Atwood Drive Access Road
• Pond Road Access Road
• Transmission Easement Access Road
• Northern Connector - North Access Road
• Northern Connector - South Access Road
• LCWRF Proposed Outfall Alignment
The Client does hereby authorize that said agent has the authority to do the following acts on behalf
of the owner:
(1) To submit appropriate requests/applications and the required supplemental
materials;
(2) To attend meetings to give representation on behalf of the Client.
(3) To authorize access to subject property for the purpose of environmental
review by appropriate regulatory agencies.
This authorization shall continue in effect until completion of the contracted task or termination by
the Client.
Agent's Name, Address & Telephone:
WithersRavenel. Inc.
115 MacKenan Drive
NC 27511
Tel. (919)-469-3340
Date: 04/22/2020
Signature of Client:
Richard D. Cappola Jr., PE - Public Services Director
Print) (Title)
(Signature)
PO Box 879
Mailing Address
Clayton, NC 27528
City State Zip
Phone: (919) 553-1530
Email: prj-NewWRF@townofclaytonnc.org
115 MacKenan Drive I Cary, NC 27511
t: 919.469.3340 1 f: 919.467.6008 1 www.withersravenel.com I License No. C-0832
Asheville I Cary I Greensboro I Pittsboro I Raleigh I Wilmington
::WithersRavenel
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USACE EMAIL CONFIRMING FIELD VERIFICATION
OF DELI N EATION FOR N EUSE RIVER WRF SITE
From: Hopper, Christopher D CIV (USA)
To: Ricci. Alvssa
Subject: RE: SAW-2020-00777 - Clayton WWTP
Date: Tuesday, December 15, 2020 10:31:18 AM
Attachments: SAW-2020-00777 Post -visit Delineation Exhibit.Ddf
Dear Alyssa,
Reference is made to ORM ID SAW-2020-00777, please reference this number on any
correspondence regarding this action.
On July 22, 2020, we met at the Town of Clayton's proposed Wastewater Treatment Plant in
Clayton, North Carolina to review the boundaries of the aquatic resources delineation you
submitted on April 27, 2020.
We have reviewed the information provided by you concerning the aquatic resources, and by
copy of this e-mail, are confirming that the aquatic resources delineation has been verified by
the Corps to be a sufficiently accurate and reliable representation of the location and extent of
aquatic resources within the identified review area. The location and extent of these aquatic
resources are shown on the delineation map, labeled Approved Wetland Delineation Exhibit
and dated July 24, 2020 (attached) without revisions.
Regulatory Guidance Letter (RGL) 16-01
hiWS7//usace.contentdm.ocic.org/utils/getfile/collection/p 1602 1 co119/id/l 256 provides
guidance for Jurisdictional Determinations (JD) and states "The Corps generally does not issue
a JD of any type where no JD has been requested". At this time we are only verifying the
delineation. This delineation may be relied upon for use in the permit evaluation process,
including determining compensatory mitigation. "This verification does not address nor
include any consideration for geographic jurisdiction on aquatic resources and shall not be
interpreted as such. This delineation verification is not an Approved Jurisdictional
Determination (AJD) and is not an appealable action under the Regulatory Program
Administrative Appeal Process (33 CFR Part 331). However, you may request an AJD, which
is an appealable action.
If you wish to receive a Preliminary Jurisdictional Determination (PJD), or an Approved
Jurisdictional Determination (AJD) please respond accordingly, otherwise nothing further is
required and we will not provide any additional documentation.
The delineation included herein has been conducted to identify the location and extent of the
aquatic resource boundaries and/or the jurisdictional status of aquatic resources for purposes
of the Clean Water Act for the particular site identified in this request. This delineation may
not be valid for the Wetland Conservation Provisions of the Food Security Act of 1985, as
amended. If you or your tenant are USDA program participants, or anticipate participation in
USDA programs, you should discuss the applicability of a certified wetland determination
with the local USDA service center, prior to starting work.
Christopher D. Hopper
Regulatory Specialist
U.S. Army Corps of Engineers
Regulatory Division
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
(919) 554-4884, Ext. 35
We would appreciate your feedback on how we are performing our duties. Our automated
Customer Service Survey can be accessed by copying and pasting the following link into your web
browser: 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: Ricci, Alyssa <aricci@withersravenel.com>
Sent: Monday, December 14, 2020 11:49 AM
To: Hopper, Christopher D CIV (USA) <Christopher.D.Hopper@usace.army.mil>
Subject: [Non-DoD Source] RE: SAW-2020-00777 - Clayton WWTP
Hey Chris,
Hope all is well. I was just checking on the progress of the concurrence email.
Thanks,
Alyssa
From: Hopper, Christopher D CIV (USA) <Christopher.D.HopperlcDusace.army.mil>
Sent: Thursday, September 24, 2020 1:53 PM
To: Ricci, Alyssa <aricciPwithersravenel.com>
Subject: RE: SAW-2020-00777 - Clayton WWTP
Alyssa:
I did prepare and send the concurrence email up the chain for review (the course we need to
approve boundaries was cancelled in late March, so I need other PMs to approve and sign first) after
our last exchange.
I've not yet heard back, but did rattle the chains earlier today. I'll stay on top of this and get you the
email as soon as possible.
Thanks for your patience!
Christopher D. Hopper
Regulatory Specialist
U.S. Army Corps of Engineers
Regulatory Division
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
(919) 554-4884, Ext. 35
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::WithersRavenel
Our People. Your Success.
NCDWR BUFFER DETERMINATION LETTER
FOR N EUSE RIVER WRF SITE
Rot COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Town of Clayton
CIO Richard Cappola, Public Services Director
PO Box 879
Clayton, North Carolina 27520
NORTH CAROLINA
Environmental Quality
May 11, 2020
Subject: Buffer Determination Letter
RRO #20-131
Johnston County
Determination Type:
Buffer
Intermittent/Perennial
® Neuse 05A NCAC 2B .0233}
El Tar -Pamlico (15A NCAC 213.0259)
❑ Intermittent/Perennial Determination (where local buffer
ordinances apply)
❑ Jordan (15A NCAC 26.0267)
(governmental and/or interjurisdictional
projects)
Project Name: Clayton WWTP
Address/Location: Johnston County PIN: 166900-96-3988
Stream(s): Un-named Tributaries to Neuse River
Determination Date: 05/04/2020
Staff: Erin/ Deck
Stream
Not
Subject
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Soil
USGS
Subject
Survey
To o
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X
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NBRRO # 20-
113
B
X
Approx:
Approx:
X
(S4)
35.665529,
35.66558,
-78.430358
-78.429443
X
Approx:
Approx.
35.665766,
35.665870,
-78.429049
78.428737
-P-t11r = P-pnemerautntermittentl,-erenniat
GPSpoints provided by iWithersravenel Staff
(1) E=Ephemera! I=fntermillent, P=Perennial, NP=Not Present, NA=Not applicable
(2) Refers to riparian buffer rules only. Stream, wetland, or pond impacts may stitl be subject to applicable water quality standards and
permitting requirements.
North Carolina Department of Env i ronmen ta I Quality ! Div, ision of Water Resources
Raleigh Regional Office 13600 Darrett Drive Ralrigh, North Carolina 27609
Clayton WWTP
Johnston County
05 44.'2024
Page 2 of 2
Explanation: The features(s) listed above has been located on the most recent published NRCS
Soil Survey of Johnston County, North Carolina and/or the most recent copy of the USGS
Topographic map at a 1:24,000 scale. Each feature that is checked "Not Subject" has been
determined to not be at least intermittent or is not present. Streams that are checked "Subject"
have been located on the property and possess characteristics that qualify it to be at least an
intermittent stream. There may be other features located on the property that do not show
up on the reaps referenced above but may be considered jurisdictional according to the US
Army Corps of Engineers.
This on -site determination shall expire five (5) years from the date of this letter.
Landowners or affected parties that dispute a determination made by the DWR may
request a determination by the Director. An appeal request must be made within sixty (60)
days of date of this letter. A request for a determination by the Director shall be referred
to the Director in writing. If sending via US Postal Service: c/o Paul Wojoski; D*W — 401 &
Buffer Permitting Unit; 1617Mail Service Center; Raleigh, NC 27699-1617. If sending via
delivery service (UPS, FedEx, etc.): Pats/ Wojo ski, Dk'R — 401 & Buffer Permitting Urrit; 512
N. Salisbury Street; Raleigh, NC 27604.
This determination is final and binding unless, as detailed above, an appeal is requested
within sixty (60) days.
This project may require a Section 404/401 Permit for the proposed activity. Any inquiries
should be directed to the US Army Corp of Engineers (Raleigh Regulatory Field Office) at
(919)-554-4884.
If you have questions regarding this determination, please feel free to contact Erin Deck at (919)
791-4200, or by email at ErirLDeck@ncdenr.gov
Sincerely,
t4Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
cs: RRO OWR File Copy
Alyssa Ricci via email: arieci@withersravenel.com
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::WithersRavenel
Our People. Your Success.
SHPO COMMENT LETTER
North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary Susi H. Hamilton
April 20, 2020
Troy Beasley
Withers Ravenel
219 Station Road, Suite 101
Wilmington, NC 27405
tb easla&withers rvenel. com
Office of Archives and History
Deputy Secretary Kevin Cherry
Re: Construct new wastewater treatment plant, Atwood Drive, PIN:166900-96-3988, Clayton, ER 20-0630
Dear Mr. Beasley:
Thank you for your letter of March 11, 2020, concerning the above project.
We have conducted a review of the project and are aware of no historic resources which would be affected by
the project. Therefore, we have no comment on the project as proposed.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR
Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579 or
environmental.review&ncdcr.gov. In all future communication concerning this project, please cite the above
referenced tracking number.
Sincerely,
LW,amona Bartos, Deputy
State Historic Preservation Officer
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-1617 Telephone/Fax: (919) 807-6570/807-6599
::WithersRavenel
Our People. Your Success.
USFWS EMAIL COMMENTS FOR EID REVIEW
Beasley, Troy
From: Ellis, John <john_ellis@fws.gov>
Sent: Tuesday, October 27, 2020 8:08 AM
To: Kubacki, Susan; Robinson, Jaime/CLT; Beasley, Troy; Mann, Leigh; Garrison, Gabriela
Subject: Clayton WRF
Susan,
I've been working with Jaime and Troy on the Clayton WRF. Based on the drafts of the documents I've
reviewed the Service could concur with their determinations for listed species. Should the project change, we
would ask them to contact us so we can reinitiate informal consultation.
Thanks
John
::WithersRavenel
Our People. Your Success.
NCDWR COMMENT LETTER FOR EI D REVIEW
NORTH CAROLINA WILDLIFE RESOURCES COMMISSION
Cameron Ingram, Executive Director
MEMORANDUM
TO: Jaime Robinson, Jacobs
FROM: Gabriela Garrison
Eastern Piedmont Coordinator`s"`"~
Habitat Conservation
DATE: October 8, 2020
SUBJECT: Comments for Environmental Review for the Town of Clayton, Wastewater Treatment
Capacity Expansion.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
document. Comments are provided in accordance with provisions of the Fish and Wildlife Coordination
Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e), North Carolina Environmental Policy Act (G.S.
113A-1 through 113A-10; 1 NCAC 25) and North Carolina General Statutes (G.S. 113-131 et seq.).
The Town of Clayton (Town) proposes to expand its wastewater treatment capacity, currently operating at
4.9 million gallons per day (MGD) via the Little Creek Water Reclamation Facility (LCWRF). A phased
approach to meet current and projected demands will occur, beginning with construction of a new 6.0
MGD water reclamation facility on a town -owned site adjacent to the Neuse River. There will be an
anticipated incremental expansion to 10 MGD to meet future needs. The Town's existing LCWRF will
be abandoned, and a pump station will be constructed at that site instead. Additionally, a transmission
main between the new WRF and abandoned LCWRF site will be constructed.
There are records for the following freshwater mussel species, downstream of the project site in the Neuse
River: the federal at -risk and state -endangered, green floater (Lasmigona subviridis); the federal species
of concern and state -threatened, triangle floater (Alasmidonta undulata) and Roanoke slabshell (Elliptio
roanokensis); and the state -threatened, eastern lampmussel (Lampsilis radiata). There are also records
for the federal at -risk and state -special concern, Neuse River waterdog (Necturus lewisi, NRWD), both
upstream and downstream of the proposed project site in the Neuse River.
Personnel from NCWRC have virtually met with consultants representing the Town to give technical
guidance, including the following recommendations, intended to minimize impacts to aquatic and
terrestrial wildlife resources:
1. If mussel surveys in the Neuse River are not conducted to determine species presence, a
salvage and relocation effort by an accredited consultant should be conducted at the proposed
project site on the Neuse River. If NRWD surveys are conducted, the following parameters
should be followed:
Mailing Address: N.C. Wildlife Resources Commission • 1701 Mail Service Center • Raleigh, NC 27699-1701
Telephone: (919) 707-0010 • ncwildlife.org
Page 2
October 8, 2020
Town of Clayton Wastewater Treatment Capacity Expansion
o Trapping should occur in the cooler months of the year when NRWD are most
active.
o If water quality is clear, snorkeling may occur to locate target species through
cobbling and/or searching leaf litter.
o Minnow trapping with bait (chicken livers) in the winter months is a suitable
method. There should be at least ten traps per site — one site upstream of outfall
and one site below outfall for a total of 20 traps. Traps are 10 meters apart from
each other, so they would span a stretch of 200 meters.
If NRWD surveys are not conducted, and species presence is assumed, stringent best
management practices for sediment and erosion control should be implemented to prevent
potential impact, as this species is very sensitive to siltation. In addition, all sediment and
erosion control measures should be checked after significant rain events to ensure they are
still functional.
The National Marine Fisheries Service should be consulted regarding potential moratoria and
impacts related to anadromous fish.
2. Maintain a minimum 100-foot undisturbed, native, forested buffer along perennial streams,
and a minimum 50-foot buffer along intermittent streams and wetlands. Maintaining
undisturbed, forested buffers along these areas will minimize impacts to aquatic and
terrestrial wildlife resources. Wide riparian buffers are helpful in maintaining stream bank
stability. In addition, these buffers provide a travel corridor for wildlife species. Lay down
and staging areas should be located outside wetland areas and at least 100 feet from stream
banks.
3. Measures to avoid or minimize impacts to wetlands should be implemented. In addition to
providing wildlife habitat, wetland areas perform important functions of flood control and
water quality protection. If necessary, crossings should only be at the narrowest point of
wetland areas. In all forested wetlands, clearing should be done by hand.
4. Where applicable, the directional bore (locating utilities beneath the riverbed and avoiding
impacts to the stream and buffer) stream crossing method should be used for utility crossings.
The open cut stream crossing method should only be used when water level is low and stream
flow is minimal. Stream crossings should be near perpendicular (750 to 1050) to stream flow.
Avoid the removal of large trees at the edges of construction corridors. Disturbed areas
should be re -seeded with seed mixtures that are beneficial to wildlife. Avoid fescue -based
mixtures and Sericea lespedeza, as both are invasive, difficult to eradicate and provide little
benefit to wildlife. Native, annual small grains appropriate for the season are preferred and
recommended. Pollinator mixes are commercially available and provide forage and shelter
for numerous species of bees, butterflies, moths and birds. Where feasible, use woody debris
and logs from cleared areas to establish brush piles adjacent to the cleared right-of-way to
improve habitat. If planting native seed mixes is not an option, allowing the corridor area to
re -vegetate into a brush/scrub habitat would maximize benefits to wildlife. For areas adjacent
to residential areas, a native shrub/grass option may also be beneficial.
o Manage non-native, invasive species by pretreating the project sites prior to
construction, preventing spread during construction, and controlling non-native,
invasive species after construction is complete.
Page 3
October 8, 2020
Town of Clayton Wastewater Treatment Capacity Expansion
Minimize corridor maintenance and prohibit mowing between April 1 and October 1 to
minimize impacts to nesting wildlife. Create a maintenance schedule that incorporates only a
portion of the area (one third of the area, for example) each year instead of the entire project
area every 3 to 4 years. Pesticides (including insecticides and herbicides) should not be used
for maintenance of right-of-ways within 100 feet of perennial streams and 50 feet of
intermittent streams, or within floodplains and wetlands associated with these streams.
Sediment and erosion control measures should be installed prior to any land -disturbing
activity. The use of biodegradable and wildlife -friendly sediment and erosion control devices
is strongly recommended. Silt fencing, fiber rolls and/or other products should have loose -
weave netting that is made of natural fiber materials with movable joints between the vertical
and horizontal twines. Silt fencing and similar products that have been reinforced with
plastic or metal mesh should be avoided as they impede the movement of terrestrial wildlife
species. Excessive silt and sediment loads can have detrimental effects on aquatic resources
including destruction of spawning habitat, suffocation of eggs and clogging of gills.
The NCWRC encourages the applicant to consider additional measures to protect aquatic and terrestrial
wildlife species in developing landscapes. The NCWRC's Guidance Memorandum to Address and
Mitigate Secondary and Cumulative Impacts to Aquatic and Terrestrial Wildlife Resources and Water
Quality (August 2002; http://www.ncwildlife.org/Portals/0/Conserving/documents/2002_
GuidanceMemorandumforSecondaryandCumulativeImpacts.pdf) details measures to minimize secondary
and cumulative impacts to aquatic and terrestrial wildlife resources; in addition, the Green Growth
Toolbox (hops://www.ncwildlife.org/Conservin /g Programs/Green-Growth-Toolbox) provides
information on nature -friendly planning that discusses how to address growth while concurrently
conserving priority terrestrial and aquatic habitat.
Thank you for the opportunity to review and comment on this project. If I can be of further assistance,
please contact me at (910) 409-7350 or gabriela.garrison&ncwildlife.org.
cc: Troy Beasley, Withers Ravenel
John Ellis, USFWS
::WithersRavenel
Our People. Your Success.
EXCERPT FROM "CLAYTON WRF CAPACITY
EXPANSION ER-EID" (PAGES 7-42 - 7-44)
SECTION 7 - ENVIRONMENTAL IMPACT DOCUMENT
7.2.1.5 Aquatic Resources
Aquatic resources will not be directly affected by construction at the proposed WRF site. The proposed
facility footprint avoids aquatic resources on the site.
No significant direct, permanent impacts to aquatic resources are expected with expansion of the outfall
to the Neuse River. Construction associated with the outfall upgrade will temporarily impact and
displace aquatic resources at the existing outfall location. Cofferdams will be used during construction
and are likely to be in place for approximately 3 weeks. The impacted area will cover approximately
2,500 ft2. The impacted area leaves approximately two-thirds of the river width unimpeded so that
passage of flow and movement of wildlife, including migration of species such as the sturgeon, are not
impacted for the brief construction window. Prior to installation of the cofferdam system, a mussel
survey will be performed within the planned construction area (Figure 7-10). Any mussels will be
relocated upstream of the outfall area in the Neuse River reach adjacent to the WRF site. This will avoid
a potential take of a protected species, and relocation upstream will avoid any temporary impacts from
turbidity associated with construction.
During installation of the cofferdam system, turbidity in the area will rise, although the net effect of the
cofferdam is expected to be a reduction in turbidity in the river during construction. The addition of a
parallel outfall structure will extend into the river the same distance, approximately 10 feet from the
bank as the current structure.
During operations, the proposed WRF will discharge treated effluent as specified in the draft NPDES
permit, protective of aquatic resources and DO (Appendix K). Disinfection will be achieved by UV, avoiding
the discharge of chlorine residuals into the Neuse River and the potential for chlorine -related impacts.
A field assessment was not performed for the Neuse River; data reviews and inquiries were used, and
details are included in Appendix K.
NCWRC records for mussel surveys in the area are included in Appendix K. Additionally, the creeper is
known to occur within a 1-mile radius of the project site. The habitats of some of these freshwater
bivalve species are limited enough to warrant state status. Given that these species are currently living
in the vicinity of the operating LCWRF outfall into the Neuse River, impacts to freshwater bivalves are
not expected with continued, increased discharge of improved quality effluent compared to what is
currently discharged. The instream waste concentration of effluent in the Neuse River is not significantly
increasing. Discussion of measures to limit sediment loading into the Neuse River, and therefore limit
the potential for impacts to aquatic habitat, is included in Section 7.2.1.3.
During field surveys, no habitat for the listed aquatic species was identified as present in perennial
streams, including Sam's Branch, within the WRF parcel. Potential habitat for species proposed for
listing, the Neuse River waterdog and Carolina madtom, may be present in the Neuse River and the
lower reaches of Sam's Branch. Impacts to aquatic habitat will be minimized through the strengthening
of ESC measures. After any rough grading, reseeding will be expected to occur within 7 days. After
installation of linear infrastructure, restabilization will be expected to occur within 7 days. In addition,
The Town is committed to increasing the frequency of its inspections of ESC measures, such as silt
fences and basins, to promote proper maintenance. Table 7-16 summarizes present habitat and
biological opinions for listed aquatic species (WithersRavenel, 2020a) (Appendix Q. Appendix K provides
details about coordination with USFWS and NCWRC.
7-42
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SECTION 7 — ENVIRONMENTAL IMPACT DOCUMENT
Table 7-16. Proposed Water Reclamation Facility USFWS Biological Opinion for Federally Listed Aquatic -Wildlife and
Plant Species for Johnston County, North Carolina
Common Name
Scientific Name
Federal Status
Habitat Present
Biological Opinion
USFWS Federally Listed Species for the County
Dwarf wedgemussel
Alasmidonto heterodon
E
Yes
Not likely to be affected
Tar River spinymussel
Parvaspina steinstansona
E
No
No effect
Yellow lance
Elliptio lanceolato
T
No
No effect
USFWS Proposed Federally Listed Species for the County
Atlantic pigtoe
Fusconaia masoni
PT
No
No effect
Neuse River waterdog
Necturus lewisi
PT
Yes
Not likely to be affected
Carolina madtom
Noturus fuiosus
PE
Yes
Not likely to be affected
Source: WithersRavenel, 2020a; Coordination with USFWS and NCWRC included in Appendix K
PE = proposed endangered
PT = proposed threatened
No aquatic resources are present within the transmission easement access road alignment. Therefore,
no aquatic species will be impacted by the planned access road to the proposed WRF.
No aquatic resources are present within the LCWRF site. Therefore, no aquatic species will be impacted
by the decommissioning activities at the LCWRF site and conversion to a pump station.
Aquatic resources may be directly and permanently affected by construction of the associated
LC Transmission Main. With 10 perennial and 6 intermittent stream crossings expected, aquatic habitat
within the easement crossings will be temporarily directly impacted. Many of the crossings will be within
existing, maintained easements, limiting additional impact at these locations. Environmental permitting
will be conducted, and general regional conditions followed to limit and mitigate impacts.
WithersRavenel conducted pedestrian surveys on March 26 and June 2, 2020, to identify potential
habitat for federally listed species within or immediately adjacent to the LC Transmission Main
alignment. Habitat was identified in larger perennial streams along the transmission alignment for the
following species:
• Dwarf wedgemussel
• Tar River spinymussel
• Yellow lance
• Atlantic pigtoe
• Neuse River waterdog
Surveys were not conducted to identify a presence of these species. The biological opinion was that
traditional open -cut construction activities may affect the Dwarf wedgemussel and Atlantic pigtoe; and
may affect, but are not likely to adversely affect, Tar River spinymussel, Yellow lance, and Neuse River
waterdog. To avoid these direct impacts to Stream 3, locally known as Sam's Branch, the Town will use
trenchless technologies where feasible at the crossings shown on Figure 7-6. Table 7-17 summarizes
present habitat and biological opinions for listed aquatic species at the crossing locations identified on
Figure 7-6. These crossings are farther upstream than the reach nearest the confluence with the Neuse
River where agencies suspect habitat may be present (WithersRavenel, 2020b) (Appendixes K and Q.
7-44
::WithersRavenel
Our People. Your Success.
STATE CLEARINGHOUSE FONSI
ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S. REGAN
Secretary
Kim H. Colson
Director November 18, 2020
Mr. Rich Cappola, PE, Director of Public Services
Town of Clayton
Post Office Box 879
Clayton, NC 27528
SUBJECT: Finding of No Significant Impact
Town of Clayton
Water Reclamation Facility Capacity
Expansion
Project No.: CS370431-07
Dear Mr. Cappola:
This is to inform you that the Finding of No Significant Impact (FONSI) and the
Environmental Assessment have been submitted to the State Clearinghouse. The documents will be
advertised for thirty (30) calendar days in the N.C. Environmental Bulletin. Advertising the FONSI
is required prior to a local unit of government receiving financial support from the State Revolving
Loan program. You will be informed of any significant comment or public objection when the
advertisement period is completed.
A copy of the documents is transmitted for your record. The documents should be made
available to the public.
If there are any questions, please contact me at (919) 707-9175.
SCK
Attachment (all cc's)
Sincerely,
Jon R!sg�aard,Chjef
State Revolving Fund Section
Division of Water Infrastructure
NORTHCAROUNAD_E Q�I
Department of Environmental Quality
North Carolina Department of Environmental Quality I Division of Water Infrastructure
512 N. Salisbury Street 1 1633 Mail Service Center I Raleigh, North Carolina 27699-1633
919.707.9160
Mr. Rich Cappola, PE, Director of Public Services
Town of Clayton
Water Reclamation Facility Capacity Expansion
Project No. CS370560-18
November 18, 2020
cc: Philip Ogden, P.E., CH2M HILL North Carolina, Inc.
Anita E. Robertson, P. E.
Ken Pohlig, P.E.
Mark Hubbard, P.E.
Jennifer Haynie
DWQ - RRO
File (CWSRF ER/EID)
NORTHCAROUNAD_E Q��
Department of Environmental quality
North Carolina Department of Environmental Quality I Division of Water Infrastructure
512 N. Salisbury Street 1 1633 Mail Service Center I Raleigh, North Carolina 27699-1633
919.707.9160
::WithersRavenel
Our People. Your Success.
NCDEQ-DWI FONSI
FINDING OF NO SIGNIFICANT IMPACT
AND ENVIRONMENTAL ASSESSMENT
TOWN OF CLAYTON
WATER RECLAMATION FACILITY CAPACITY EXPANSION
RESPONSIBLE AGENCY: NORTH CAROLINA DEPARTMENT OF
ENVIRONMENTAL QUALITY
CONTACT: JON RISGAARD, SECTION CHIEF
STATE REVOLVING FUND SECTION
DIVISION OF WATER INFRASTRUCTURE
1633 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1633
(919) 707-9175
November 18, 2020
(This page intentionally left blank.)
FINDING OF NO SIGNIFICANT IMPACT
Article I, Chapter 113A of the North Carolina General Statutes requires an action to be subject to
the requirements of the North Carolina Environmental Policy Act (NCEPA) if it involves the
expenditure of public funds and if a potential impact is anticipated to the environment. The
project has been evaluated for compliance with the NCEPA and is determined to be a major
agency action, which will affect the environment.
Project Applicant: Town of Clayton, North Carolina
Project Description: The proposed project will expand the Town of Clayton's
wastewater treatment capacity in phases up to 10 MGD with the
following components: (1) a 6 million gallon per day (MGD)
five -stage biological nutrient removal water reclamation facility
(WRF) at the site of the Town's Neuse River pump station; (2)
conversion of the existing Little Creek WRF to a pump station
and forcemain to convey raw wastewater to the proposed WRF
site; (3) expansion of the existing East Clayton Industrial Area
(ECIA) pump station and construction of a new forcemain to
convey flows from the ECIA to the proposed WRF site; (4)
expansion of the existing Neuse River outfall; and (5)
construction of an access road from O'Neil Street to the proposed
WRF site with a parallel water main along the existing utility
transmission easement. The new WRF will initially operate at 6
MGD and will be expanded in phases to the full 10 MGD. The
Little Creek pump station will include pumps sized to meet the
initial peak and average daily flow requirement for 6 MGD and is
designed for expansion to accommodate future flows. The
forcemain will be sized for the full 10 MGD treatment capacity.
The Finding of No Significant Impact applies to the full
expansion to 10 MGD.
Project Number: CS370431-07
Project Cost: $153,000,000
Clean Water State $30,000,000 (Note that the Town has been awarded $30 million
Revolving Loan Fund: in CWSRF loans at this time and intends to apply for an
additional $60 million in future funding rounds)
Local Funds: $63,000,000 in operating revenue, bonds, and low -interest loans
The review process indicated that significant adverse environmental impacts should not occur if
mitigative measures are implemented, and an environmental impact statement will not be
required. The decision was based on information in the Engineering Report/Environmental
Information Document (ER/EID) submitted by the applicant and reviews by governmental
agencies. The attached Environmental Assessment (EA), prepared by the Division based on the
ER/EID, supports this action and outlines mitigative measures that must be followed. This
Finding of No Significant Impact (FONSI) completes the environmental review record, which is
available for inspection at the State Clearinghouse.
No administrative action will be taken on the proposed project for at least 30 days after
notification that the FONSI has been published in the North Carolina Environmental Bulletin.
Sincerely,
?',z- /6�
Jon Risgaard, Section Chief
State Revolving Fund Section
Division of Water Infrastructure
ENVIRONMENTAL ASSESSMENT
A. Proposed Facilities and Actions
The proposed project will expand the Town of Clayton's wastewater treatment capacity in
phases to 10 MGD with the following components: (1) a 6 million gallon per day (MGD) five -
stage biological nutrient removal (BNR) water reclamation facility (WRF) at the site of the
Town's Neuse River pump station; (2) conversion of the existing Little Creek WRF to a pump
station and forcemain to convey raw wastewater to the proposed WRF site; (3) expansion of the
existing East Clayton Industrial Area (ECIA) pump station and construction of a new forcemain
to convey flows from the ECIA to the proposed WRF site; (4) expansion of the existing Neuse
River outfall; and (5) construction of an access road from O'Neil Street to the proposed WRF
site with a parallel water main along the existing utility transmission easement. The new WRF
will include an influent pump station, odor control, headworks for screening and grit removal,
flow equalization, five -stage BNR for nitrogen and phosphorus, supplemental carbon for
enhanced nitrogen removal, supplemental metal salts for backup and polishing of phosphorus
removal, cloth media (disc) tertiary filtration, UV disinfection, and cascade re -aeration. The new
WRF will initially operate at 6 MGD and will be expanded in phases to the full 10 MGD. The
Little Creek pump station will include pumps sized to meet the initial peak and average daily
flow requirement for 6 MGD and is designed for expansion to accommodate future flows. The
forcemain will be sized for the full 10 MGD treatment capacity. Solids treatment at the new
WRF will include thickening with rotary drum thickeners, 30-day aerated sludge holding, and
dewatering with screw press with solids to be disposed through contract composting and/or
landfill. This environmental assessment evaluates the environmental impacts associated with the
full expansion to 10 MGD.
FundingStatus: tatus: The estimated total cost for the project is $153,000,000. The Town is applying
for a Clean Water State Revolving Fund (CWSRF) loan of $30,000,000 and intends to apply for
an additional $60,000,000 in future CWSRF funding rounds. The remaining project costs will be
funded through a combination of local bonds, low -interest loans, and operating revenues.
B. Existing Environment
Topography and Soils. Clayton is the Piedmont Physiographic Province, with topography
gradually sloping toward the Coastal Plain and floodplains along streams. Elevations in the study
are range from 130 to 370 feet above mean sea level, with a range from 140 to 220 feet above
mean sea level at the proposed WRF site.
The dominant soil types in the project area are Wedowee sandy loam, Pacolet loam, Norfolk
loamy sand, and Cecil loam. Typical soils in floodplains and adjacent to streams are Wehadkee
and Chewacla. Soils throughout the project area have been impacted by development, grading
activities, and other soil disturbances.
Surface Water. The project area is located in the Upper Neuse River Subbasin (HUC 03020201).
Surface waters in project area include the Neuse River and Little Creek. Reaches of the Neuse
River in the project area are designated as Water Supply -IV and Water Supply-V and classified
as nutrient sensitive waters. Some portions of the Neuse River in the study area are impaired for
copper and zinc. Little Creek is classified as Class C and nutrient sensitive waters, with some
portions impaired for benthos.
Water Supply. The Town of Clayton purchases drinking water from Johnston County, which
draws water from the Neuse River.
C. Existing Wastewater Facilities
The Town provides wastewater conveyance and treatment services to residential users within
town limits and its extra -territorial jurisdiction as well as several industrial and commercial
customers. The Town owns and operates the 2.5 MGD Little Creek WRF, which discharges to
the Neuse River under NPDES Permit NC0025453. The Little Creek WRF was constructed in
the 1950s as a trickling filter plant and has undergone major upgrades and modifications since
then. In 1990, the plant was converted to an oxidation ditch facility, and a second oxidation ditch
was added in the mid-1990s. In the mid-2000s, anaerobic and anoxic zones were added. The
current biological treatment process includes two oxidation ditches with additional anaerobic and
anoxic ones for biological nutrient removal. Many of the processes at the WRF are in good
condition, but much of the mechanical and electrical equipment is approaching the end of its
useful life. Although the plant is permitted at 2.5 MGD, current operation is limited to
approximately 2 MGD due to treatment limitations and total nitrogen restrictions.
The Town has an additional 2.4 MGD in treatment capacity through regional partnerships: 1.4
MGD through the City of Raleigh's Neuse River Wastewater Treatment Plant (WWTP) and 1.0
MGD through Johnston County's WWTP. The Town has a pump station at the ECIA that to
conveys most of the flow from the ECIA to the County's WWTP, with the remainder going to
the Little Creek WRF. The Town sends a portion of its flow to Raleigh through the Neuse 2
pump station. These partnerships, combined with the Little Creek WRF, give the Town a total of
4.9 MGD in treatment capacity. In 2028, the Town's average daily flow was 3.2 MGD.
The Town's collection system includes almost 160 miles of gravity sewer lines and forcemains
and 28 pump stations with capacities ranging from 40 to 2,100 gallons per minute. Most of the
pump stations are in moderate to very good condition. The Town is working to replace older pipe
sections in the collection system as funding allows.
D. Need for Proposed Facilities and Actions
The Town's wastewater flow from residential, industrial, and commercial customers has been
growing. New housing units are being built to support the growing population, and facilities in
the ECIA are expanding. The Town is nearing 89 percent of its available capacity, with an
increase in flow from an ECIA facility expected in 2023 that will push the Town's wastewater
treatment demands close to the current capacity of 4.9 MGD before 2025. In addition, the Little
Creek WRFs' infrastructure is aging and susceptible to flooding. Historically, the Town has
utilized regional partnerships to delay major capital investments, but Johnston County and City
of Raleigh have indicated their intent to increase fees to treat the Town's wastewater, and the
County will no longer accept wastewater with characteristics exceeding domestic -strength limits
after 2023. The Town's contract with Raleigh expires in 2027. The Town anticipates higher -
strength wastewater from ECIA as well as more concentrated wastewater from residential users.
Without these partnerships, the Town will lose approximately 2.4 MGD of treatment capacity.
To address the growing residential, industrial, commercial demand for wastewater treatment and
the increasing costs and limitations associated with regional partnerships, the Town has
concluded that constructing a new WRF with a phased approach is the best solution to address
the Town's future wastewater needs. The proposed project will provide 6 MGD of initial
treatment capacity to meet the Town's short-term wastewater treatment needs, and will be
constructed to allow for incremental expansion up to 10 MGD to meet longer -term needs within
the planning period.
E. Alternatives Analysis
Alternative 1 — No -Action: This alternative would rely on existing treatment systems,
infrastructure, and regional interconnections with no significant increase in capacity. This
alternative was rejected because it does not meet the Town's need for increased wastewater
treatment capacity.
Alternative 2 — Construction of a new WRF and continued use of a surface water discharge:
Under this alternative, the Town would (1) build a new 6 MGD WRF with potential for future
expansion to 10 MGD with two sites being considered: the Neuse 2 Pump Station site
(Alternative 2a) and the ECIA Pretreatment Facility site (Alternative 2b); (2) continued operation
of the Little Creek WRF at 2 MGD until the new facility is online; (3) decommissioning that
facility and converting the site use to a new pump station to convey 3 MGD average daily flow;
(4) continued reliance on regional contracts through 2023; (5) retention of regional contracts as
backup after 2023 with minimization of flow to the County and Raleigh; (6) expansion of the
Little Creek WRF surface water discharge to the Neuse River at the Neuse 2 Pump Station site;
and (7) planning for future incremental expansion of the new facility to 10 MGD as flows
increase.
Alternative 2a Neuse 2 Pump Station Site: This site alternative would utilize a Town -owned
parcel, the Neuse 2 Pump Station site. The new facility would utilize five -stage BNR for
nitrogen and phosphorus, supplemental carbon for enhanced nitrogen removal, supplemental
metal salts for backup and polishing of phosphorus removal, cloth media (disc) tertiary filtration,
UV disinfection, and cascade re -aeration. Solids treatment at the new WRF will include
thickening with rotary drum thickeners, 30-day aerated sludge holding, and dewatering with
screw press. Use of this site would require construction of an access road and expanding the
existing outfall. The site is sufficiently sized to allow for construction of the WRF while
maintaining stream and property buffers and avoiding the floodplain along the Neuse River. The
public greenway infrastructure would remain available to the community. Connecting
infrastructure would be required. The site is centrally located to Town operations and expected
areas of development. Potential impacts to the Neuse River from an increased discharge would
be offset by purchase of nitrogen credits. The location, site size, and ability to minimize
environmental impacts make this site more desirable than the Alternative 2b site.
Alternative 2b ECIA Pretreatment Facility: This site alternative would construct the new WRF
adjacent to the R. Steven Biggs Regional Pretreatment Facility with conveyance system work
required to connect existing sewer infrastructure to the new WRF. The treatment process would
be similar to Alternative 2a except that diffused aeration would be used rather than cascade
aeration due to limited elevation changes at the site. This alternative would expand and use the
existing Neuse River outfall. The site is located near industrial and commercial customers but
not in an area expected to see significant residential growth and development. The site is
currently intended for future expansion of the pretreatment facility. Building at this site would
require using the athletic field adjacent to the pretreatment facility and may require additional
land acquisition. The site is unlikely to be large enough to accommodate future facility
expansions, and wetlands bordering the site would likely lead to greater environmental impacts
compared to the Alternative 2a site. For these reasons, Alternative 2b is rejected in favor of
Alternative 2a.
Alternative 2, using site Alternative 2a, meets the Town's needs for long-term resiliency,
expanded treatment capacity, control of treatment costs, and adaptability and phasing for longer
term needs and is the preferred alternative.
Alternative 3 — Expansion of Little Creek WRF and continued use of surface water discharge:
This alternative would rehabilitate the existing Little Creek WRF and expand its capacity to 6
MGD while adding biological nutrient removal to comply with Neuse River discharge limits.
Expansion of the existing Neuse River outfall capacity would be accomplished with a parallel
outfall. Additional infrastructure upgrades would be required, including the discharge forcemain,
pump station, gravity line to discharge location, and Neuse River discharge. Much of the growth
in the Town is projected to be on the Neuse River side rather than the Little Creek side, so a
significant expansion of the Neuse River 2 Pump Station would be required to send flow back
across town. The existing facility is on a steeply graded parcel with limited available space for
expansion without significant site work. The site is also partially located in the floodplain and
not well -suited for treatment infrastructure due to flooding risk. The site would likely involve
greater impacts to streams and buffers compared to the preferred alternative, and the permitting
process for work in the floodplain would pose a significant schedule risk. The complexity of
continuing to operate the existing plant during the expansion would present management
challenges. Site constraints limit the ability to provide cost-effective nitrogen removal with a
future expansion to meet longer term needs. These challenges make this alternative less desirable
than the preferred alternative, so it was rejected.
Alternative 4 — Continued use of Little Creek WRF and maximizing regional connections to
existing wastewater treatment: Under this alternative, the Town would expand existing contracts
with the County and the City of Raleigh while maintaining operation of the Little Creek WRF
with improvements to nitrogen removal to allow the WRF to operate at the permitted capacity of
2.5 MGD. This alternative would likely require construction of additional conveyance
infrastructure to the County or City's treatment facilities. Although this alternative is technically
feasible, the Town has not been able to reach cost-effective agreements with the County or City
E
that will provide the needed treatment capacity at a reasonable cost. This alternative also leaves
the Town vulnerable to flood impacts and reliability concerns associated with the Little Creek
WRF. For these reasons, this alternative was rejected.
Alternative 5 — Construction of a new WRF and use of land application: Similar to Alternative 2,
this alternative would build a new 6 MGD WRF with plans for future expansion to 10 MGD. For
purposes of analysis, the Neuse 2 Pump Station site was considered because the Town already
owns this land. This option would abandon the effluent discharge at the Neuse River and divert
effluent to suitable locations for spray irrigation. The alternative would include construction of
transmission infrastructure to convey effluent to land application site(s). Approximately 1,300
acres would be needed for land application. An advantage of this alternative is that nutrient
removal requirements for land application are less stringent than surface discharge to the Neuse
River, so certain elements of the WRF can be eliminated, including tertiary treatment, and
purchase of nitrogen credits would be reduced or eliminated. Environmental impacts would be
lower than the preferred alternative because of elimination of the surface water discharge, but
spray operation would have to be monitored to ensure that run-off does not impact surface
waters. Disadvantages of this alternative are increased pumping to convey effluent to land
application sites, higher O&M costs to operate spray fields, and feasibility is questionable due to
the high cost and limited availability of suitable land within ten miles of the proposed WRF site.
This alternative was rejected because these disadvantages outweigh the possible benefits of this
alternative.
Alternative 6 — Construction of a new WRF and implementation of larger -scale wastewater
reuse: Similar to Alternative 2, this alternative would build a new 6 MGD WRF with plans for
future expansion to 10 MGD. For purposes of analysis, the Neuse 2 Pump Station site was
considered because the Town already owns this land. The Town has a limited reuse program
available that provides a small amount of reuse water to a local golf course on a seasonal basis.
Two additional golf courses were identified with a total estimated demand of 0.15 MGD. The
Town reached out to industrial customers to investigate the possibility of interest in purchasing
reuse water, but these customers already have environmental sustainability programs in place to
conserve water use and, as a result, the amount of water purchased is minimal and leaves little
opportunity for purchase of reuse water. The limited potential demand for reuse water is not
enough for this alternative to be feasible. If feasible, this alternative would reduce environmental
impacts by eliminating a surface discharge; however, due to limited potential for large-scale
reuse of wastewater, this alternative was rejected because it is not a viable solution to the Town's
wastewater needs.
Alternative 7 — Construction of a new WRF with alternative secondary treatment process: This
alternative would construct a new 6 MGD WRF similar to Alternative 2 but using 4-stage BNR
with metal salt addition. Heavy metal salts would precipitate phosphorus to facilitate removal
during secondary treatment. This alternative would produce similar effluent as the preferred
alternative and slightly lower capital costs; however, this alternative was rejected because
chemicals used for phosphorus removal have the potential to vary in price, leading to uncertainty
of operational cost. The slightly higher capital cost for biological phosphorus removal is offset
by the potential for higher operating costs. In addition, there is an environmental benefit to
5
biological phosphorus removal compared to increased chemical use and delivery truck traffic
associated with chemical phosphorus removal.
Alternative 8 — Construction of a new WRF with alternative biosolids treatment str9M: This
alternative would construct a 6 MGD WRF similar to Alternative 2 but using a physical -
chemical thermal hydrolysis process (Lystek THP®) to produce Class a biosolids. Under this
alternative, the Town would contract with Lystek for management and disposal of biosolids. The
solids treatment process would use the same thickening and dewatering equipment as Alternative
2 and adds Lystek THP® reactors to produce biosolids that can be sold as fertilizer. This
alternative has similar environmental impacts as the preferred alternative and similar long-term
benefit but slightly higher initial costs. This alternative was rejected due to the higher cost, but
the Town could add this biosolids process in the future if desired.
Alternative 9 — Combination of Alternatives: The Town considered whether some combination
of alternatives might meet the project purpose and needs. A possible combination considered was
continuing operating the Little Creek WRF at current capacity and constructing a smaller 4 MGD
WRF at a second site. This combination would have a lower capital cost but would still require
investment in the Little Creek WRF to rehabilitate or replace aging equipment and maintain
operational functionality of this plant. Operational costs for two plants would be higher than one
plant. This combination was rejected because it does not offer any cost -savings or operation
efficiency compared to the preferred alternative.
Another combination that was considered was land applying effluent during the dry season and
discharging via the Little Creek WRF outfall during the wet season. This option would require a
large area for the land application at very high cost. The alternative would also still require
additional treatment to improve effluent quality for surface water discharge. This combination
was also rejected as it offers no cost or operational benefits compared to the preferred alternative.
Finally, a combination of land application and large-scale reuse (Alternatives 5 and 6) was
briefly considered but was rejected because the combination would be no more feasible than
either alternative implemented independently.
Alternative 10 — Decentralized System: This alternative would transition from the Town's
current strategy of collect wastewater at centralized points for transmission to the Little Creek
WRF and regional partners for treatment to a decentralized system. A decentralized approach
would not be efficient or effective for the Town. This alternative was deemed infeasible and
rej ected.
Alternative 11 — Optimum operation of existing facilities: This alternative would involve
optimizing operation of the Little Creek WRF. Normal maintenance at this facility is becoming
costly, and this alternative would require investment to replace or rehabilitate existing
infrastructure. Even with these investments, this alternative would not meet the Town's needs for
additional capacity and improved treatment to meet Neuse River discharge limits; therefore, this
alternative was rejected.
M
F. Environmental Consequences and Mitigative Measures
Topography and Soils: Construction activities will have some permanent impacts to topography
and soils for grading and fill, but these impacts are not expected to be significant. Approximately
42 acres will be disturbed for installation of linear infrastructure, and the WRF site will require
grading of approximately 25 acres. Grading and fill will occur at the upland areas of the project
site to avoid disturbance of the Neuse River floodplain, stream buffers, and wetlands. Soil loss
during construction will be minimized by following a DEQ-approved Erosion and Sedimentation
Control Plan. The Little Creek WRF site will be returned to existing grade and stabilized after
demolition. Installation of the transmission main and the Neuse River outfall will have temporary
impacts on floodplains. A Floodplain Development Permit will be obtained from the Town of
Clayton for this work. Secondary and cumulative impacts (SCI) are not expected to be
significant. The proposed expansion supports growth and development that is already in progress
rather than stimulating new development. Impacts from development and construction will be
mitigated through the Town's erosion and sedimentation control program, federal and local
floodplain development requirements, Neuse River watershed stream buffer rules, Johnston
County's stormwater management program, and the Town's stormwater design manual.
Land Use: Impacts to land use are not expected to be significant. The site to be used for the
proposed WRF already includes a pump station, but more of the site will be cleared to for the
WRF. Most of the access road and transmission main will be constructed within existing utility
easements. The Little Creek Pump Station will be constructed at the Little Creek WRF site. SCI
are not expected to be significant and will be mitigated through the Town's 2040 Comprehensive
Plan, Uniform Development Code, General Design Guidelines, and zoning processes. These
programs work together to plan for growth while maintaining open space and natural areas.
Wetlands: Significant impacts to wetlands are not anticipated. Impacts at the proposed WRF site
will avoid impacts to wetlands by doing most construction in the center portion of the site away
from wetlands, implementing an erosion and sedimentation control plan, maintaining a buffer
around the construction site to prevent soil from settling in wetlands, and maintaining the site's
existing natural forested buffers to minimize impacts from stormwater runoff. No wetlands are
present along the access road alignment or near the Little Creek pump station site. Five wetland
areas are located along the transmission route in an existing sewer easement that has been
maintained as herbaceous wetlands through regular mowing and maintenance. Wetland soils be
returned to these areas after construction to support wetland restoration, and all required permits
will be obtained. SCI related to future growth and development will be minimized through water
supply watershed protections, the Neuse River watershed stream buffer requirements, Johnston
County's stormwater management program, the Town's stormwater design manual, and
permitting programs.
Important Farmlands: Significant impacts to important farmlands are not anticipated.
Construction of the WRF, access road, and transmission lines will impact soils classified as
prime farmland and farmland of statewide importance but these lands are not in agricultural use.
SCI on farmlands are not expected to be significant and will be mitigated through the Town's
2040 Comprehensive Plan, Uniform Development Code, General Design Guidelines, and zoning
7
processes. These program work together to plan for growth while protecting agriculture in the
Town and County.
Public Lands and Scenic, Recreational, and State Natural Areas: Significant impacts to public
lands, scenic, recreational, or state natural areas are not expected. The Sam's Branch and Neuse
River greenways are adjacent to the WRF site and will be temporarily closed during
construction, but the greenways will be restored to existing conditions and reopened. Forested
buffers will limit visual and noise impacts from operation of the WRF. SCI are not expected to
be significant and will be mitigated through the Town's 2040 Comprehensive Plan, Uniform
Development Code, General Design Guidelines, and zoning processes. These program work
together to plan for growth while maintaining open space and natural areas.
Cultural Resources: Impacts to cultural and historic resources are not anticipated. The North
Carolina State Historic Preservation Office (SHPO) is not aware of any historic resources that
will be impacted by the project September 22, 2020, ER 20-1074). The Town's downtown
historic district will not be impacted by the project. SCI are not expected to be significant and
will be mitigated through the Town's 2040 Comprehensive Plan, Uniform Development Code,
General Design Guidelines, and zoning processes. The Town's historic downtown area is listed
on the National Register of Historic Places and protected through the Town's Downtown Master
Plan. Any large development activities will require investigation for potential historic value.
Air Quality: No significant impacts to air quality are anticipated. Construction may temporarily
impact air quality. Dust suppression will be used to minimize these impacts. Odor control is
proposed for the new WRF. An air quality permit will be obtained for the generator for the
propose WRF. Truck traffic to and from the site during operations is not expected to have a
significant impact on local air quality. SCI are not expected to be significant. Growth will follow
the Town's 2040 Comprehensive Plan, and the town has attracted industries that are not large air
polluters. Joint planning efforts have resulted in the County's Comprehensive Transportation
Plan to support development while limiting transportation -related SCI through careful planning.
Noise Levels: No significant permanent noise impacts are anticipated. Construction activities
will cause temporary increase in noise, but operation of the WRF will not change overall ambient
noise level in the area. The surrounding area includes industrial activities. The forested buffer
between the WRF and the public greenways will minimize noise for greenway users. will be
limited to normal daytime working hours. SCI are not expected to be significant. Growth will
follow the Town's 2040 Comprehensive Plan, which includes guidelines for noise control with
site planning. Joint planning efforts have resulted in the County's Comprehensive Transportation
Plan to support development while limiting transportation -related SCI through careful planning.
Water Resources: No significant impacts to water resources are anticipated. During construction
of the WRF, the sediment and erosion control plan and a stormwater management plan will be
implemented to minimize impacts from soil and pollution discharge into surface waters. The
proposed WRF will include flow equalization to limit potential for untreated discharge to the
Neuse River. Discharge into the Neuse River will increase from the permitted flow of 2.5 MGD
to 6 MGD initially, with future discharge of 10 MGD planned. Potential water quality impacts
have been evaluated for determination of permit limits for the expansion with modeling
conducted to determine treatment approaches needed to address seasonal variations of dissolved
oxygen and other parameters. The facility will be designed to reliably meet permit limits. The
Town will achieve the total nitrogen limit through treatment technologies and nitrogen credit
purchases, and nitrogen offset credits have been purchased to meet nutrient requirements of the
Neuse & Tar -Pamlico Nutrient Strategy Rules. Compliance with permit limits will protect water
quality in the Neuse River. A cofferdam system will be used for construction of the outfall to
minimize increases in turbidity. The additional effluent flow into the Neuse River will have an
increase of approximately three percent during low flows and is not a measurable increase during
normal and higher flows. This flow is not expected to lead to bank erosion or change the
hydrology of the river downstream of the outfall. Installation of the transmission main will
include crossings of ten perennial streams and six intermittent streams. Construction will likely
be open -cut but measures will be taken to reduce impacts with trenchless technology used where
feasible, and appropriate permits will be obtained. SCI related to future growth and development
will be minimized through water supply watershed protections, the Neuse River watershed
stream buffer requirements, stormwater management programs, and permitting programs.
Forest Resources: Significant impacts to forest resources are not expected. Approximately 24
acres of forest will be cleared for the WRF, and approximately 2.3 acres will be cleared for the
access road. SCI are not expected to be significant and will be mitigated through the Town's
2040 Comprehensive Plan, Uniform Development Code, General Design Guidelines, and zoning
processes. These program work together to plan for growth while maintaining forested and
natural areas.
Shellfish or Fish and Their Habitats: Significant impacts to shellfish, fish, and their habitats are
not expected. Compliance with the permit limits will protect aquatic life in the Neuse River. Soil
and erosion control measures and best management practices will minimize construction
impacts. Suitable habitat for the following protected species may be present: Dwarf
wedgemussel (Alasmidonta heterodon), Tar River spinymussel (Parvaspina steinstansana),
Yellow lance (Elliptio lanceolate), Atlantic pigtoe (Fusconaia masoni), Neuse River waterdog
(Necturus lewisi), and Carolina madtom (Noturus fuiosus). The biological determination
concluded that the project is not likely to adversely affect these species, and the U.S. Fish &
Wildlife Service concurs with the determination (email October 27, 2020). SCI related to future
growth and development will be minimized through water supply watershed protections, the
Neuse River watershed stream buffer requirements, stormwater management programs, and
permitting programs.
Wildlife and Natural Vegetation: No significant impacts to wildlife and natural vegetation are
expected. Construction activities may result in temporary impacts, and some permanent loss of
habitat may occur, but wildlife are expected to relocate to adjacent area with minimal effects.
Potential habitat for Michaux's sumac (Rhus michauxii) was identified, but a survey was
conducted during the growing season with no occurrences located. The Bald Eagle (Haliaeetus
laucocephalus) and Red -Cockaded Woodpecker (Picoides borealis) have been identified within
a mile of the project but are not expected to be impacted. The U.S. Fish & Wildlife Service
concurs with the determination of "no effect'' for these wildlife species. The town plans to create
a corridor of native vegetation along the greenway by reseeding after construction with a native
6
seed mix and will modify mowing protocol to avoid mowing during the flowering spring and
summer seasons to promote pollination, natural reseeding and long-term viability of this area.
Introduction of Toxic Substances: The project is not expected to introduce toxic substances into
the environment. During construction, best practices and regular offsite maintenance will be used
to minimize the risk of leaks or malfunctions from construction equipment. Construction wastes
are not expected to be toxic, and no hazardous wastes will be generated by operation of the
WRF. SCI are not expected to be significant and will be mitigated through the Town's 2040
Comprehensive Plan, Uniform Development Code, General Design Guidelines, and zoning
processes. These program work together to plan for growth while maintaining open space and
natural areas.
The U.S. Fish and Wildlife Service reviewed the proposed project and concurred with the
Town's determinations for listed species (October 27, 2020). The North Carolina Wildlife
Resources Commission, Natural Heritage Program, and DWR Raleigh Regional Office do not
object to the proposed project. The U.S. Army Corps of Engineers was consulted and did not
object to the project. The North Carolina Department of Natural and Cultural Resources is aware
of no historic resources that would be affected by the project (September 22, 2020, ER 20-1074).
G. Public Participation, Sources Consulted
The Town held a public meeting on November 16, 2020 and made the engineering
report/environmental information document available for review by the public through the
Town's website. The meeting included a presentation about the project and an opportunity for
public comment, with two comment received:
Comment: A representative from Gifols Therapeutics expressed support for the project
and noted that Grifols is undergoing expansion and will need additional wastewater
treatment capacity from the Town.
Response: Comment noted.
Comment: A resident expressed support for the WRF overall but concern about cost and
rate impacts to current residents. The resident asked if developers were contributing
project funding and recommended developers pay into a system development program to
reduce burden on existing residents
Response: The Town will consider the comment and noted that the Town must treat
ratepayers fairly.
The current user charge for a typical residential customer is $83.58 per month for water and
sewer service combined, based on consumption of 5,000 gallons per month. The proposed
project will increase the bill by $46.09 (approximately 55%), for a future combined bill of
$129.67 in FY 2025. The Town plans to implement rate increases over the next five years.
Sources consulted about this project for information or concurrence included:
10
1) Town of Clayton
2) City of Raleigh
3) Johnston County
4) North Carolina Department of Environmental Quality
-Wildlife Resources Commission
-Natural Heritage Program
-DEQ Raleigh Regional Office
-Division of Air Quality
-Division of Water Resources
-Division of Forest Resources
-Division of Environmental Assistance and Customer Service
-Division of Waste Management
5) North Carolina Department of Natural and Cultural Resources
6) North Carolina State Clearinghouse
7) North Carolina Department of Public Safety
8) U.S. Fish and Wildlife Service
9) U.S. Army Corps of Engineers
11
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::WithersRavenel
Our People. Your Success.
5/23/2021 EMAIL SUBMITTING AQUATIC
SPECIES INTERIM SURVEY REPORT:
N EUSE RIVER WATER DOG TRAPPING
TO USFWS AND NCWRC
Beasley, Troy
From: Tom Dickinson <tom.dickinson@threeoaksengineering.com>
Sent: Sunday, May 23, 2021 9:55 PM
To: Ellis, John; Garrison, Gabriela
Cc: Beasley, Troy
Subject: RE: Clayton WRF Expansion Neuse River Waterdog Surveys -Interim Report
Attachments: Clayton WRF Interim Survey Report-Neuse River Waterdog Trapping.pdf
John and Gabriela,
We wanted to provide our interim results for the Neuse River Waterdog Trapping efforts we conducted this past winter
for the project. Please find attached the draft report for review. As noted, no individuals were captured during the
protocol, and upcoming additional visual survey efforts will supplement the trapping surveys.
We are planning to conduct the targeted mussel survey effort in the short term as low flows have returned to the
Neuse. We will let you know of any updates in that regard. If we can provide any additional details at this time, please
let me know.
Thanks,
Tom Dickinson
Three Oaks Engineering
324 Blackwell Street, Suite 1200
Durham, NC 27701
919 417 2099
�1HEf#iyc.
IV;IV
From: Tom Dickinson
Sent: Tuesday, February 16, 2021 3:55 PM
To: Ellis, John <john_ellis@fws.gov>; Garrison, Gabriela <gabriela.garrison@ncwildlife.org>
Cc: Beasley, Troy <TBeasley@withersravenel.com>
Subject: Clayton WRF Expansion Neuse River Waterdog Surveys
John and Gabriela,
We wanted to send you an update on our planned efforts for the Town of Clayton Neuse River Water Reclamation
Facility Outfall Expansion project Neuse River Waterdog surveys. We originally intended to conduct the work in recent
weeks but with persistent rains and high flows we have pushed out those plans. We are hopeful that the preferred
moderate flows will align with the winter trapping that we generally conclude by mid -March, however, the current lake
levels in Falls and forecast indicate ongoing high levels are likely for this section of the Neuse. We have had success
capturing the species at higher flows so while the conditions are not ideal, we are planning to get the trapping in before
the end of this winter season. We believe the trapping data coupled with visual surveys conducted as part of the mussel
survey and relocation effort will allow for an adequate evaluation of NRWD presence at the site.
Thanks,
Tom Dickinson
Three Oaks Engineering
324 Blackwell Street, Suite 1200
Durham, NC 27701
919 417 2099
_��61NEiR1y�T
::WithersRavenel
Our People. Your Success.
11/5/2021 EMAIL SUBMITTING FINAL
AQUATIC SPECIES SURVEY REPORT
Beasley, Troy
From: Tom Dickinson <tom.dickinson@threeoaksengineering.com>
Sent: Friday, November 5, 2021 9:28 AM
To: Ellis, John; Garrison, Gabriela
Cc: Beasley, Troy
Subject: Clayton WRF Expansion Neuse River Aquatic Species Survey Report
Attachments: Clayton WRF Aquatic Species Survey Report.pdf
John and Gabriela,
We wanted to provide our results for the targeted mussel and Neuse River Waterdog Trapping efforts we conducted for
the project. Please find attached the report for review. As noted, no federal target species were found, however, we
did locate a fairly diverse assemblage of mussels (n=8) including some state listed species. The Town has committed to a
mussel relocation prior to instream construction to offset impacts to the mussel fauna present, currently planned for
summer 2022.
If we can provide any additional details at this time, please let me know.
Thanks,
Tom Dickinson
Three Oaks Engineering
324 Blackwell Street, Suite 1200
Durham, NC 27701
919 417 2099
::WithersRavenel
Our People. Your Success.
THREE OAKS ENGINEERING AQUATIC
SPECIES SURVEY REPORT (10/8/2021)
Aquatic Species Survey Report
Clayton Water Reclamation Facility
Johnston County, North Carolina
Neuse River Downstream of Project Area During Mussel Survey Efforts
Prepared For:
October 8, 2021
Prepared by:
324 Blackwell Street, Suite 1200
Durham, NC 27701
Table of Contents
1.0 Introduction..........................................................................................................................
1
2.0 Target Protected and Proposed Species Descriptions..........................................................
2
2.1 Dwarf Wedgemussel (Alasmidonta heterodon)...............................................................
2
2.1.1. Species Characteristics..............................................................................................
2
2.1.2. Distribution and Habitat Requirements....................................................................
2
2.1.3. Threats to Species.....................................................................................................
3
2.2 Atlantic Pigtoe (Fusconaia masoni).................................................................................
5
2.2.1. Species Characteristics..............................................................................................
5
2.2.2. Distribution and Habitat Requirements....................................................................
5
2.2.3. Threats to Species.....................................................................................................
6
2.2.4. Designated Critical Habitat.......................................................................................
6
2.3 Neuse River Waterdog (Necturus lewisi).........................................................................
8
2.3.1. Species Characteristics..............................................................................................
8
2.3.2. Distribution and Habitat Requirements....................................................................
8
2.3.3. Threats to Species.....................................................................................................
9
2.3.4. Designated Critical Habitat.......................................................................................
9
3.0 Survey Efforts....................................................................................................................
10
3.1 Conditions of Reach Evaluated: Neuse River................................................................
10
3.2 Survey Methodology......................................................................................................
11
3.2.1. Freshwater Mussels.................................................................................................
11
3.2.2. Neuse River Waterdog............................................................................................
11
4.0 Results................................................................................................................................12
4.1 Freshwater Mussels........................................................................................................
12
4.2 Neuse River Waterdog...................................................................................................
12
5.0 Mussel Species Found........................................................................................................
13
5.1 Triangle Floater (Alasmidonta undulata).......................................................................
13
5.2 Eastern Elliptio (Elliptio complanata)...........................................................................
13
5.3 Carolina Slabshell (Elliptio congaraea).........................................................................
14
5.4 Roanoke Slabshell (Elliptio roanokensis)......................................................................
14
5.5 Eastern Lampmussel (Lampsilis radiata)......................................................................
14
5.6 Eastern Floater (Pyganodon cataracta).........................................................................
15
5.7 Creeper (Strophitus undulatus)......................................................................................
15
5.8 Paper Pondshell (Utterbackia imbecillis).......................................................................
16
6.0 Discussion/Conclusions.....................................................................................................
16
7.0 Literature Cited..................................................................................................................
17
Appendix A:
Figure 1: Project Vicinity & Survey Reach
Figure 2-1 to 2-3: NCNHP Element Occurrences and Designated Critical Habitats
Appendix B: Select Photographs
1.0 INTRODUCTION
The Town of Clayton is proposing the relocation and expansion of Town's Water
Reclamation Facility (WRF, the Project) on the Neuse River. Three Oaks Engineering
(Three Oaks) was tasked by the Town to conduct a freshwater mussel survey, salvage,
and relocation and a Neuse River Waterdog (Necturus lewisi, NRWD) survey for the
project per the request of the US Fish and Wildlife Service (USFWS).
This section of the Neuse River is known to contain a relatively diverse assemblage of
mussels, including state listed species. This portion of the Neuse River also contains
potential habitat for federally listed Endangered Dwarf Wedgemussel (Alasmidonta
heterodon) and the federally proposed Threatened Atlantic Pigtoe (Fusconaia masoni).
The federally proposed Threatened Neuse River Waterdog, an aquatic salamander, may
also inhabit this portion of the river, thus targeted surveys were requested. This report
details the mussel and NRWD survey efforts conducted in 2021.
Tables 1 lists the nearest element occurrence (EO) in approximate river miles (RM) for
these species relative to the project crossing. Data is according to the NC Natural
Heritage Program database (NCNHP 2021) last updated July 2021 (Appendix A, Figures
2-1 through 2-4).
Table 1—Target Species Element Occurrences
Distance
from
EO
EO
crossing
First
Last
EO
Species Name
ID
Waterbod
Observed
Observed
Status*
Figure
7699
Neuse River
11.7
1951
1951
H
Dwarf
Swift and
Wedgemussel
13799
Middle
18.3
March
March
C
2-1
Creek
1991
2020
Walnut
11071
Creek
12
1951
1951
H
Atlantic Pigtoe
2 2
March
August
11695
Swift Creek
18.3
C
1991
2020
8259
Neuse River
11.7
April 1919
January
nua
H
1987
Neuse River
Waterdog
Swift and
February
2-3
1633
Middle
18.3
April 1979
C
Creek
*: C — NCNHP Current; H —NCNHP Historic
2.0 TARGET PROTECTED AND PROPOSED SPECIES DESCRIPTIONS
2.1 Dwarf Wedgemussel (Alasmidonta heterodon)
2.1.1. Species Characteristics
The DWM was originally described as Unio heterodon (Lea 1829). Simpson (1914)
subsequently placed it in the genus Alasmidonta.
Ortmann (1919) placed it in a monotypic subgenus
Prolasmidonta, based on the unique soft -tissue
anatomy and conchology. Fuller (1977) believed
the characteristics of Prolasmidonta warranted
elevation to full generic rank and renamed the
species Prolasmidonta heterodon. Clarke (1981)
retained the genus name Alasmidonta and
considered Prolasmidonta to be a subjective
synonym of the subgenus Pressodonta (Simpson
1900).
The specific epithet heterodon refers to the chief distinguishing characteristic of this
species, which is the only North American freshwater mussel that consistently has two
lateral teeth on the right valve and only one on the left (Fuller 1977). All other laterally
dentate freshwater mussels in North America normally have two lateral teeth on the left
valve and one on the right. The DWM is generally small, with a shell length ranging
between 25 millimeters (mm) (1.0 inch) and 38 mm (1.5 inches). The largest specimen
reported by Clarke (1981) was 56.5 mm (2.2 inches) long, taken from the Ashuelot River
in New Hampshire. The periostracum is generally olive green to dark brown; nacre
bluish to silvery white, turning to cream or salmon colored towards the umbonal cavities.
Sexual dimorphism occurs in DWM, with the females having a swollen region on the
posterior slope, and the males are generally flattened. Clarke (1981) provides a detailed
description of the species.
Nearly all freshwater mussel species have similar reproductive strategies; a larval stage
(glochidium) becomes a temporary obligatory parasite on a fish. Many mussel species
have specific fish hosts, which must be present to complete their life cycle. Based upon
laboratory infestation experiments, Michaelson and Neves (1995) determined that
potential fish hosts for the DWM in North Carolina include the Tessellated Darter
(Etheostoma olmstedi) and the Johnny Darter (E. nigrum). McMahon and Bogan (2001)
and Pennak (1989) should be consulted for a general overview of freshwater mussel
reproductive biology.
2.1.2. Distribution and Habitat Requirements
The historic range of the DWM is confined to Atlantic slope drainages from the
Peticodiac River in New Brunswick, Canada, south to the Neuse River, North Carolina.
Occurrence records exist from at least 70 locations, encompassing 15 major drainages, in
11 states and one Canadian Province (USFWS 1993). When the recovery plan for this
species was written, the DWM was believed to have been extirpated from all but 36
localities, 14 of them in North Carolina (USFWS 1993). The most recent assessment
(2013 5-Year Review) indicates that the DWM is currently found in 16 major drainages,
comprising approximately 75 "sites" (one site may have multiple occurrences). At least
45 of these sites are based on less than five individuals or solely on relict shells. It
appears that the populations in North Carolina, Virginia, and Maryland are declining as
evidenced by low densities, lack of reproduction, or inability to relocate any individuals
in follow-up surveys. Populations in New Hampshire, Massachusetts, and Connecticut
appear to be stable, while the status of populations in the Delaware River watershed
affected by the multiple flood events between 2004 and 2006 are still being studied
(USFWS 2013).
Strayer et al. (1996) conducted range -wide assessments of remaining DWM populations
and assigned a population status to each of the populations. The status rating is based on
range size, number of individuals and evidence of reproduction. Seven of the 20
populations assessed were considered "poor," and two others are considered "poor to
fair" and "fair to poor," respectively. In North Carolina, populations are found in
portions of the Neuse and Tar River basins; however, they are believed to have been
extirpated from the main -stem of the Neuse River.
The DWM inhabits creeks and rivers of varying sizes (down to approximately two meters
wide), with slow to moderate flow. A variety of preferred substrates have been described
that range from coarse sand, to firm muddy sand, to gravel (USFWS 1993). In North
Carolina, DWM often occurs within submerged root mats along stable streambanks. The
wide range of substrate types used by this species suggests that the stability of the
substrate is likely as important as the composition.
2.1.3. Threats to Species
The cumulative effects of several factors, including sedimentation, point and non -point
discharge, stream modifications (impoundments, channelization, etc.) have contributed to
the decline of this species throughout its range. Except for the Neversink River
population in New York, which has an estimated population of over 80,000 DWM
individuals, all the other populations are generally small in numbers and restricted to
short reaches of isolated streams. The low numbers of individuals and the restricted
range of most of the surviving populations make them extremely vulnerable to extirpation
from a single catastrophic event or activity (Strayer et al. 1996). Catastrophic events may
consist of natural events such as flooding or drought, as well as human influenced events
such as toxic spills associated with highways, railroads, or industrial -municipal
complexes.
Siltation resulting from substandard land -use practices associated with activities such as
agriculture, forestry, and land development has been recognized as a major contributing
factor to degradation of mussel populations. Siltation has been documented to be
extremely detrimental to mussel populations by degrading substrate and water quality,
increasing potential exposure to other pollutants, and direct smothering of mussels (Ellis
1936, Marking and Bills 1979). Sediment accumulations of less than one inch have been
shown to cause high mortality in most mussel species (Ellis 1936). In Massachusetts, a
bridge construction project decimated a population of the DWM because of accelerated
sedimentation and erosion (Smith 1981).
Sewage treatment effluent has been documented to significantly affect the diversity and
abundance of mussel fauna (Goudreau et al. 1988). Goudreau et al. (1988) found that
recovery of mussel populations may not occur for up to two miles below points of
chlorinated sewage effluent.
The impact of impoundments on freshwater mussels has been well documented (USFWS
1992a, Neves 1993). Construction of dams transforms lotic habitats into lentic habitats,
which results in changes in aquatic community composition. The changes associated
with inundation adversely affect both adult and juvenile mussels, as well as fish
community structure, which could eliminate possible fish hosts for upstream transport of
glochidia. Muscle Shoals on the Tennessee River in northern Alabama, once the richest
site for naiads (mussels) in the world, is now at the bottom of Wilson Reservoir and
covered with 19 feet of muck (USFWS 1992b). Large portions of all the river basins
within the DWM's range have been impounded; this is believed to be a major factor
contributing to the decline of the species (Master 1986).
The introduction of exotic species such as the Asian Clam (Corbicula fluminea) and
Zebra Mussel (Dreissena polymorpha) has also been shown to pose significant threats to
native freshwater mussels. The Asian Clam is now established in most of the major river
systems in the United States (Fuller and Powell 1973), including those streams still
supporting surviving populations of the DWM. Concern has been raised over
competitive interactions for space, food and oxygen with this species and native mussels,
possibly at the juvenile stages (Neves and Widlak 1987, Alderman 1995). The Zebra
Mussel, native to the drainage basins of the Black, Caspian, and Aral Seas, is an exotic
freshwater mussel that was introduced into the Great Lakes in the 1980s and has rapidly
expanded its range into the surrounding river basins, including those of the South Atlantic
slope (O'Neill and MacNeill 1991). This species competes for food resources and space
with native mussels and is expected to contribute to the extinction of at least 20
freshwater mussel species if it becomes established throughout most of the eastern United
States (USFWS 1992b). The Zebra Mussel is not currently known from any river in
North Carolina.
2.2 Atlantic Pigtoe (Fusconaia masont)
2.2.1. Species Characteristics
The Atlantic Pigtoe was described by Conrad (1834) from the Savannah River in
Augusta, Georgia. Although larger specimens exist,
the Atlantic Pigtoe seldom exceeds 50 mm (2 inches)
in length. This species is tall relative to its length,
except in headwater stream reaches where specimens
may be elongated. The hinge ligament is relatively
short and prominent. The periostracum is normally
brownish, has a parchment texture, and young
individuals may have greenish rays across the entire
shell surface. The posterior ridge is biangulate. The
interdentum in the left valve is broad and flat. The
�I�III�Ijl�I�I�l�I�II,I�I�I�ICI�1�1�1 anterior half of the valve is thickened compared with
, s i6 a is 19 !d the posterior half, and, when fresh, nacre in the
anterior half of the shell tends to be salmon colored, while nacre in the posterior half
tends to be more iridescent. The shell has full dentation. In addition to simple papillae,
branched and arborescent papillae are often seen on the incurrent aperture. In females,
salmon colored demibranchs are often seen during the spawning season. When fully
gravid, females use all four demibranchs to brood glochidia (VDGIF 2014).
The Atlantic Pigtoe is a tachytictic (short-term) breeder, brooding young in early spring
and releasing glochidia in early summer. The Bluegill (Lepomis macrochirus) and Shield
Darter (Percina peliata) have been identified as potential fish hosts for this species
(O'Dee and Waters 2000). Additional research has found Rosefin Shiner (Lythrurus
ardens), Creek Chub (Semotilus atromaculatus), and Longnose Dace (Rhynichthys
cataractae) are also suitable hosts (Wolf 2012). Eads and Levine (2011) found White
Shiner (Luxilus albeolus), Satinfin Shiner (Cyprinella analostana), Bluehead Chub
(Nocomis leptocephalus), Rosyside Dace (Clinostomus funduloides), Pinewoods Shiner
(Lythrurus matutinus), Creek Chub, Swallowtail Shiner (Notropis procne), and Mountain
Redbelly Dace (Chrosomus oreas) to also be suitable hosts for Atlantic Pigtoe.
2.2.2. Distribution and Habitat Requirements
Johnson (1970) reported the range of the Atlantic Pigtoe extended from the Ogeechee
River Basin in Georgia north to the James River Basin in Virginia; however, recent
curation of the H. D. Athearn collection uncovered valid specimens from the Altamaha
River in Georgia (Sarah McRae, USFWS, personal communication). It is presumed
extirpated from the Catawba River Basin in North and South Carolina south to the
Altamaha River Basin (USFWS 2018a). The general pattern of its current distribution
indicates that the species is currently limited to headwater areas of drainages and most
populations are represented by few individuals. In North Carolina, aside from the
Waccamaw River, it was once found in every Atlantic Slope river basin. Except for the
Tar River, it is no longer found in the mainstem of the rivers within its historic range
(Savidge et al. 2011). It is listed as Endangered in Georgia, South Carolina, and North
Carolina, and as Threatened in Virginia. It has a NatureServe rank of G2 (imperiled).
The Atlantic Pigtoe has been found in multiple physiographic provinces, from the
foothills of the Appalachian Mountains, through the Piedmont and into the Coastal Plain,
in streams less than one meter wide to large rivers. The preferred habitat is a substrate
composed of gravel and coarse sand, usually at the base of riffles; however, it can be
found in a variety of other substrates and lotic habitat conditions.
2.2.3. Threats to Species
Threats to the Atlantic Pigtoe are similar to those described for the DWM and have
contributed to the decline of this species throughout its range. Atlantic Pigtoe appears to
be particularly sensitive to pollutants and requires clean, oxygen -rich water for all stages
of life. All the remaining Atlantic Pigtoe populations are generally small in numbers and
restricted to short reaches of isolated streams. The low numbers of individuals and the
restricted range of most of the surviving populations make them extremely vulnerable to
extirpation from a single catastrophic event.
2.2.4. Designated Critical Habitat
The Atlantic Pigtoe is proposed for listing under the Endangered Species Act (ESA) as a
Threatened Species with Section 4(d) Rule and Critical Habitat Designation. In
accordance with Section 4 of the ESA, Critical Habitat for listed species consists of:
(1) The specific areas within the geographical area occupied by the species at the
time it is listed, in which are found those physical or biological features
(constituent elements) that are:
a. essential to the conservation of the species, and
b. which may require special management considerations or protection
(2) Specific areas outside the geographical area occupied by the species at the time it
is listed in accordance with the provisions of Section 4 of the Act, upon a
determination by the Secretary that such areas are "essential for the conservation
of the species."
On October 11, 2018, USFWS proposed the Atlantic Pigtoe as a Threatened species
under the ESA. Critical habitat designation provided at that time (CFR Vol. 52 No. 186)
consists of the following:
• Unit 1 - 29 river mi (46.7 river km) of Craig Creek in Craig and Botetourt
Counties, Virginia.
• Unit 2 - 1 mile (1.6-km) of Mill Creek in Bath County, Virginia
• Unit 3 - 3 miles (4.8-km) of the Middle James River in Fluvanna and Buckingham
Counties, Virginia
• Unit 4 - 50 river miles (80.5 river km) of the Nottoway River in Nottoway,
Lunenburg, Brunswick, Dinwiddie, and Greenville Counties, Virginia
• Unit 5 - 5 miles (8 km) of the Meherrin River in Brunswick County, Virginia
• Unit 6 - 7 miles (11.3 km) of the Dan River in Pittsylvania County, Virginia and
Rockingham County, North Carolina
• Unit 7 - 12 miles (19.3 km) of Aarons Creek in Granville County, North Carolina
and along the Mecklenburg County -Halifax County line in Virginia and North
Carolina
• Unit 8 - 85 miles (136.8 km) of the mainstem of the upper and middle Tar River
as well as several tributaries (Bear Swamp Creek, Crooked Creek, Cub Creek, and
Shelton Creek), in North Carolina
• Unit 9 - 8 miles (93.3-km) of Sandy/Swift Creek in Granville, Vance, Franklin,
and Nash Counties, North Carolina
• Unit 10 - 85 miles (136.8 km) in Fishing Creek, Little Fishing Creek, Shocco
Creek, and Maple Branch located in Warren, Halifax, Franklin, and Nash
Counties, North Carolina
• Unit 11 - 30 miles (48.3 km) of the Lower Tar River and Fishing Creek in
Edgecombe County, North Carolina
• Unit 12 - 60 river miles (95 river km) in four subunits including Flat River, Little
River, Eno River, and the Upper Eno River
• Unit 13 - 61 river miles (98.2 river km) in five subunits including Swift Creek,
Middle Creek, Upper Little River, Middle Little River, and Contentnea Creek, in
North Carolina
• Unit 14 - 6 miles (9.7 km) of habitat in the New Hope Creek in Orange County,
North Carolina
• Unit 15 - 10 river miles (16.1 river km) in Randolph County, North Carolina,
including 3the mainstem as well as Richland Creek and Brush Creek
• Unit 16 - 40 miles (64.4 km) of Little River in Randolph and Montgomery
Counties, North Carolina
Critical Habitat Unit 13 occurs 18.3 RM downstream of the project area, more
specifically the Swift Creek subunit, which consists of 25 river miles (40 river km) in
Johnson County, North Carolina (Figure 2-2).
2.3 Neuse River Waterdog (Necturus lewisa)
2.3. L Species Characteristics
The Neuse River Waterdog is a fully aquatic salamander and was first described by C.S.
Brimley in 1924 as a subspecies of the Common
Mudpuppy (N. maculosus); it was elevated to
species status in 1937 by Percy Viosca, Jr.
The Neuse River Waterdog's average size
rangesfrom 6-9 inches (15.24 — 22.86 cm) in
length; record length is 11 inches (27.94 cm). It
has a somewhat stocky, cylindrical body with
smooth skin, a rather flattened, elongate head with
a squared -off nose, and small limbs. The tail is
vertically flattened with fins on both the top and
bottom. Distinct from most salamanders, the
Neuse River Waterdog, and other Necturus species,
have four toes on each foot. The Neuse River
Waterdog is a rusty brown color on the dorsal side
and dull brown or slate colored on the ventral side.
Both dorsal and ventral sides are strongly spotted but the ventral side tends to have fewer
and smaller markings; spots are dark bluish to black. They also have a dark line running
through the eye. Adults are neotenous and retain three bushy, dark red external gills
usually seen in larval amphibians. Both male and female are similar in appearance and
can be distinguished only through differences in the shape and structure of the cloaca
(Beane and Newman 1996; Conant and Collins 1998; EDGE of Existence 2016).
Individuals become sexually mature at approximately 5-6 years of age. Breeding
normally occurs in the spring. The male deposits a gelatinous spermatophore that is
picked up by the female and used to fertilize between 30-50 eggs. The fertilized eggs are
attached to the underside of flat rocks or other submerged objects and guarded by the
female until they hatch in June or July (Conant and Collins 1998; EDGE of Existence
2016).
2.3.2. Distribution and Habitat Requirements
The Neuse River Waterdog is found only in the Neuse and Tar River basins of North
Carolina (AmphibiaWeb 2006; Beane and Newman 1996; Frost 2016).
Neuse River Waterdogs inhabit rivers and larger streams, where they prefer leaf beds in
quiet waters. They need high levels of dissolved oxygen and good water quality. The
Neuse River Waterdog is generally found in backwaters off the main current, in areas
with sandy or muddy substrate. Adults construct retreats on the downstream side of
rocks or in the stream bank where they remain during the day. They are active during the
night, leaving these retreats to feed. Neuse River Waterdogs are carnivorous, feeding on
invertebrates, small vertebrates, and carrion. Neuse River Waterdogs are most active
during winter months even when temperatures are below freezing. During summer
months, they will burrow into deep leaf beds and are rarely found. It has been suggested
that this inactivity in summer may be an adaptation to avoid fish predators, which are
more active at these times. In addition, Neuse River Waterdogs produce a defensive,
toxic skin secretion that is assumed to be distasteful to predators (AmphibiaWeb 2006;
Beane and Newman 1996; Conant and Collins 1998; EDGE of Existence 2016;
NatureServe Explorer 2016).
2.3.3. Threats to Species
Any factors that reduce water quality are threats to the Neuse River Waterdog. These can
include changes that result in siltation and pollution reducing habitat quality (e.g.,
channelization, agricultural runoff, and industrial and urban development).
Impoundments are also a threat to the dispersal of the species as it is unable to cross
upland habitat; Neuse River Waterdogs do not climb and are unlikely to use fish passages
(NatureServe Explorer 2016).
2.3.4. Designated Critical Habitat
As mentioned in Section 1.0, on May 22, 2019, the Neuse River Waterdog was proposed
for listing under the ESA as a Threatened Species with Section 4(d) Rule and Critical
Habitat Designation. Critical habitat designation provided at that time (CFR Vol. 84 No.
99) consists of the following:
• Unit 1 - 8.6 river mi (13.8 river km) of the Upper Tar River in Granville County
• Unit 2 - 10.5 river mi (16.9 river km) of Upper Fishing Creek in Warren County
• Unit 3 - 63 river mi (101 river km) of lower Little Fishing Creek in Halifax, Nash,
and Edgecombe Counties.
• Unit 4 - 68-river-mi (110-river-km) segment of Sandy Creek and Red Bud Creek
in Franklin, Nash, and Edgecombe Counties
• Unit 5 - 100-river-mi (161-river-km) segment of the Middle Tar River in
Franklin, Nash, and Edgecombe Counties
• Unit 6 - 60 river mi (96.6 river km) in the Lower Tar River Subbasin including
portions of Town Creek, Otter Creek, and Tyson Creek in Edgecombe and Pitt
Counties
• Unit 7 - 41.5 river mi (66.8 river km) of the Eno River in Orange and Durham
Counties
• Unit 8 - 17.4-river-mi (28-river-km) segment of the Flat River in Person and
Durham Counties
• Unit 9 - 7.6-river-mi (12.2-river-km) stretch of Middle Creek in Wake and
Johnston Counties
• Unit 10 - 23.35-river-mi (37.6-river-kin) stretch of Swift Creek in Johnston
County
• Unit 11 - 89.6-river-mi (144.2-river-km) segment of the Little River including
Buffalo Creek in Franklin, Wake, Johnston, and Wayne Counties
• Unit 12 - 18.7-river-mi (30-river-km) segment of Mill Creek in Johnston and
Wayne Counties
• Unit 13 — 40-river-mi of (64.4- river -km) of Middle Neuse River in Wayne and
Lenoir Counties
• Unit 14 — 117-river-mi (188.3-river-km) of Contentnea Creek, Neuse River,
Nahunta Swamp, and Pinetree Creek in Wayne, Greene, Wilson, Lenoir, Pitt, and
Craven Counties
• Unit 15 — 10-river-mi (16-river-km) of Swift Creek in Craven County
• Unit 16 — 62-river-mi (100-river-km) of Trent River including Beaver Creek in
Jones County
The Study Area is 18.3 RM upstream of proposed Critical Habitat Unit 10 in Swift Creek
and Unit 11 in Middle Creek (Figure 2-3).
3.0 SURVEY EFFORTS
NRWD trapping efforts were conducted by a combination of Three Oaks personnel Tom
Dickinson (Permit 92 1 -ES00343), Tim Savidge (Permit 921-ES0034), Kate Sevick
(Permit 92 1 -ES00485), Lizzy-Stokes Cawley, and Joanna Salvucci March 9-12, 2021.
Targeted mussel surveys were conducted on August 25, 2021 by Three Oaks personnel
Tom Dickinson (Permit 21-ES00343), Tim Savidge (Permit 21-ES0034), Lizzy Stokes -
Cawley, and Trevor Hall.
3.1 Conditions of Reach Evaluated: Neuse River
The channel in this portion of the Neuse River was 45-55 meters wide, with banks up to 4
meters high that ranged from relatively stable to exhibiting significant erosion and
undercutting. Habitat in the majority of the reach consisted of run with several riffle
breaks located downstream of the project area; a large sand and gravel bar was present
below the confluence with Sam's Branch. Substrates were dominated by unconsolidated
shifting sands with consistent areas of cobble and gravel in deeper runs and associated
with bars and riffle breaks. Areas of clay and silt accumulations were present along the
river margins as well as woody debris and root mats. A small section of riprap lined the
bank around the existing outfall.
3.2 Survey Methodology
Surveys for mussels and Neuse River Waterdog were conducted from approximately
1,312 feet (400 meters) downstream of the project area to approximately 328 feet (100
meters) for a distance of approximately 1,640 feet (500 meters). The reach and trapping
locations are depicted in Figure 1.
3.2.1. Freshwater Mussels
Areas of appropriate habitat were searched, concentrating on the stable habitats preferred
by the target species. The survey team spread out across the river into survey lanes.
Visual surveys were conducted using glass bottom view buckets (bathyscopes) in shallow
areas and near banks, as addition to use of scuba equipment for deeper sections. Tactile
methods were employed, particularly in banks under submerged rootmats. All freshwater
bivalves were recorded and returned to the substrate. Timed survey efforts provided
Catch Per Unit Effort (CPUE) data for each species. Relative abundance for freshwater
snails and freshwater clam species were estimated using the following criteria:
➢ (VA) Very abundant > 30 per square meter
➢ (A) Abundant 16-30 per square meter
➢ (C) Common 6-15 per square meter
➢ (U) Uncommon 3-5 per square meter
➢ (R) Rare 1-2 per square meter
➢ (P-) Ancillary adjective "Patchy" indicates an uneven distribution of the species
within the sampled site.
3.2.2. Neuse River Waterdog
Methods were developed by Three Oaks in consultation with the USFWS and NCWRC
and were designed to replicate winter trapping efforts conducted as part of the recent
species status assessment undertaken by these agencies and collaborators. The Neuse
River Waterdog is more active when water temperatures are low, an adaptation that may
help them avoid fish predation, thus, trapping is generally conducted late October through
March. Trapping during this time of year also reduces the potential for unintended
mortality (by drowning) of bycatch of small turtles and other reptiles, as they are
generally not active during the winter months.
The agencies requested total of 20 traps for this project; at least ten traps upstream of the
outfall and ten below the outfall. Traps were placed approximately 10 meters apart from
each other to span a stretch of approximately 200 meters (Figure 1). Trap sites were
selected based on habitat conditions and accessibility. Undercut banks, with some
accumulation of leaf pack, as well as back eddy areas within runs were the primary
microhabitats selected; however, all of the microhabitats (pool, riffle, run, etc.) occurring
at a site were sampled with at least one trap. Traps were baited with a combination of
chicken livers and hot dogs and allowed to soak overnight. The traps were checked daily,
all species found within the traps were recorded, and the traps were rebaited.
4.0 RESULTS
The survey results by target species are presented as follows.
4.1 Freshwater Mussels
A total of 16.7 person hours of mussel survey time were spent in the reach, with the eight
mussel species in Table 2 being found. Other mollusk species located included the Asian
Clam (Corbicula fluminea).
Table 2. CPUE for Freshwater Mussels in Neuse River
Scientific Name
Common Name
# live
Abundance/
CPUE
Freshwater Mussels
CPUE
lasmidonta undulata
Triangle Floater
4
.24/hr
lli do con araea
Carolina Slabshell
43
2.57/hr
lli do com lanata
Eastern Elli do
306
18.32/hr
lli do roanokensis
Roanoke Slabshell
372
22.28/hr
am silis radiata
Eastern Lam mussel
10
.60/hr
Pyganodon cataracta
Eastern Floater
1
.05/hr
tro hitus undulatus
1
.05/hr
-Creeper
Utterbackia imbecillis
Paper Pondshell
1
.05/hr
Freshwater Snails and Clams
Relative
Abundance
Corbicula uminea[Asian Clam
C
4.2 Neuse River Waterdog
The NRWD was not captured during the trapping efforts. Several fish species were
trapped during the efforts in relatively low density (Table 3).
Table 3. Neuse River Trapping Surveys Species Found
Trap
Day 1
Day 2
Day 3
Day 4
1
Pirate Perch 1
2
3
4
5
6
7
8
—
9
Spottail Shiner (1),
White Shiner 1
10
11
S ottail Shiner 1
12
S ottail Shiner 1
S ottail Shiner 7
13
S ottail Shiner 2
S ottail Shiner (1)
14
S ottail Shiner 1
15
Tessellated Darter
1
16
S ottail Shiner 1
17
18
19
20
5.0 MUSSEL SPECIES FOUND
The following provides descriptions and status of the mussel species found. Additional
details can be found in the references cited.
5.1 Triangle Floater (Alasmidonta undulata)
This species was described from the Schuylkill River
near Philadelphia (Say 1817). Its range extends from
the Catawba River in North Carolina north to the
lower St. Lawrence River. The shell shape is
subtriangular to ovate and inflated. The anterior and
ventral shell margins are rounded. The periostracum
is yellowish green with broad green or black rays.
This species is considered Special Concern
throughout its range (Williams et al. 1993). It is
considered Threatened in North Carolina.
5.2 Eastern Elliptio (Elliptio complanata)
This species was described as *a complanata from
the Potomac River in Maryland (Lightfoot 1786). Shell
characteristics are highly variable. Shell shape is
typically trapezoidal to rhomboid, and compressed to
inflated. The usually straight ventral margin is mostly
parallel with the dorsal margin and the posterior margin
is broadly rounded. Shell thickness varies from thin to
solid. Johnson (1970) synonymized well over a
hundred species with E. complanata. Due to the
taxonomic uncertainty within the E. complanata complex, it is unclear whether these
different represent different species, or simply represent ecophentypic variation within
one species. This species is widely distributed along the Atlantic Slope from Altamaha
River Basin in Georgia north to the St. Lawrence River Basin, and west to Lake Superior
and parts of the Hudson Bay Basin. It can be found in a variety of habitats from large
rivers and, lakes to small headwater streams. The species is widespread and common
throughout its range and considered stable (Williams et al. 1993).
5.3 Carolina Slabshell (Elliptio congaraea)
This species was described from the Congaree River,
South Carolina by Lea (1831). One species (E.
planilateris) described from the Neuse River Basin
(Conrad 1838) were synonomized with E. congaraea
(Johnson 1970). The range of this species extends
from the Ogeechee River, Georgia north to the
Chowan River, North Carolina. The shell is
rhomboid and subcompressed with moderately full
beaks. The front of the shell is wedge-shaped, with
the posterior end obliquely truncate above and biangulate below. The posterior slope is
moderately sharp and usually has numerous cross corrugations or wrinkles. The
periostracum is greenish -yellow or tawny. Williams et al. (1993) list this species as
Special Concern.
5.4 Roanoke Slabshell (Elliptio roanokensis)
The Roanoke Slabshell was described from the
Roanoke River (exact location unknown) by Lea
(1838). The reported range extends from the
Connecticut River in Massachusetts south to the
Savannah River in Georgia (Walter 1954)). Based
on shell morphologies, Johnson (1970) synonymized
this and 100 other species into the Elliptio
complanata complex; however, it is now widely recognized as being a valid species
(Turgeon et al. 1988). The periostracum is generally very smooth, often with placations
(furrows) and reddish yellow in color. Shells of this species reach lengths exceeding 150
mm. Williams et al. (1993) lists this species as Special Concern and it is listed as Special
Concern in North Carolina.
5.5 Eastern Lampmussel (Lampsilis radiata)
The Eastern Lampmussel was described from the
Potomac River by Lamarck (1819). Carolina
Fatmucket was described from the Yadkin/Pee Dee
River Basin in North Carolina as Unio conspicuus
by Lea (1874), which Simpson (1914) considered a
variety of L. radiata radiata (Eastern Lampmussel)
The Carolina Fatmucket was synonomized with L.
radiata radiata by Johnson (1970). The taxonomic
status of the Lampsilis radiata complex is still
uncertain. Both the Eastern Lampmussel and the Carolina Fatmucket forms are known t
0
occur in the Neuse River Basin. This large mussel is subelliptical to subovate in outline.
Shells are generally thick and solid, with rounded anterior and posterior margins. The
periostracum is usually yellowish or brownish green with dark green rays over the entire
surface. Like other members of this genus, this species is sexually dimorphic, with the
shells of the male being more elongate, and the females more rounded and swollen,
particularly in the posterior margin. Williams et al. (1993) considers this species to be
Stable; however, the Eastern Lampmussel is considered Threatened in North Carolina.
5.6 Eastern Floater (Pyganodon cataracta)
Described by Say (1817) in the deep part of a mill
pond presumably near Philadelphia, this species is
wide ranging in the Atlantic drainages from the
lower St. Lawrence River Basin south to the
Altamaha River Basin, Georgia, and in the
Alabama -Coosa River drainage, and the
Apalachicola and Coctawhatchee River Basins,
Florida. The shells of this species are uniformly
thin and lack hinge teeth. The shell shape is ovate,
subelliptical and elongate, with an evenly rounded anterior margin and a broadly rounded
ventral margin. The periostracum is light to dark green with broad green rays on the
posterior slope. Ortmann (1919) recognized three generalized shell forms, the pond
form, the creek/small river form and the big river form, that were related to
environmental conditions. The pond form occurs in small ponds with muddy substrates
and is characterized by very thin elongate inflated shells. The creek form occurs in riffle -
pool habitats in gravel substrates and is much thicker and more compressed. The big river
form is generally short and inflated and occurs in soft substrates. This species is
considered common and currently Stable throughout its range (Williams et al. 1993).
5.7 Creeper (Vrophitus undulatus)
This species was described from the Schuylkill
River near Philadelphia (Say 1817). Its range
extends throughout much of the Interior River Basin
and Atlantic Slope regions. The shell is elliptical to
rhomboid in outline and somewhat inflated. The
anterior end is rounded, and the posterior end is
bluntly pointed. The periostracum is yellowish
green to brown, with dark green rays. This species
occupies a variety %J habitats, from high -gradient
small streams, to larger rivers. Williams et al. (1993), considers it Special Concern and it
is listed as Threatened in North Carolina.
5.8 Paper Pondshell (Utterbackia imbecillis)
fine green rays.
1993).
Described from the Wabash River in Indiana (Say
1829), this mussel occurs throughout the Mississippi
River and Great Lakes drainages, as well as
sporadically along the Atlantic slope. It has an
extremely thin shell that is oblong and inflated. The
dorsal and ventral margins are nearly straight and
parallel. The periostracum is greenish yellow with
This species is considered common throughout its range (Williams et al.
6.0 DISCUSSION/CONCLUSIONS
These efforts provide updated survey data for the Clayton Water Reclamation Facility
Project. The mussel results indicate that the study area supports a diverse freshwater
mussel fauna consisting of at least eight species including the state Threatened Triangle
Floater, Eastern Lampmussel, and Creeper. Target Federally protected mussels and the
Neuse River Waterdog were not observed. While other species were not found during
these surveys, potential habitat is present; thus, the presence of additional species cannot
be altogether ruled out.
To offset impacts, a mussel relocation has been requested prior to instream construction
of the new outfall, currently planned for 2022. Carefully planned and implemented
mussel relocations can mitigate impacts to mussel species from instream construction
activities.
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51609. Docket No. FWS-R4-ES-2018-0046.
United State Fish and Wildlife Service (USFWS). 2018b. Neuse River waterdog.
https://www. fws. gov/southeast/wildli fe/amphibi ans/neuse-river-waterdog/
United State Fish and Wildlife Service (USFWS). 2021. Endangered and Threatened
Wildlife and Plants; Threatened Species Status with Section 4(d) Rule for Neuse
River Waterdog, Endangered Species Status for Carolina Madtom, and
Designations of Critical Habitat. 50 CFR 17:86 FR 30688, 30688-30751. Docket
No. FWS-R4-ES-2018-0092.
Viosca, P., Jr. 1937. A tentative revision of the genus Necturus, with descriptions of three
new species from the southern Gulf drainage area. Copeia 1937:120-138.
Virginia Department of Game and Inland Fisheries (VDGIF). 2014. Atlantic Pigtoe
Conservation Plan. Bureau of Wildlife Resources. VDGIF, Richmond, VA. 31 pp.
Wolf, E.D. 2012. Propagation, Culture, and Recovery of Species at Risk Atlantic Pigtoe.
Virginia Tech Conservation Management Institute, Project No. 11-108. 55pp.
Walter, W. M. (1954). Mollusca of the upper Neuse River basin, North Carolina,
Durham, NC. Durham, North Carolina, Duke University. Ph.D.: 220.
Williams, J. D., M. L. Warren, Jr., K. S. Cummings, J. L. Harris, and R. J. Neves. 1993.
Conservation status of the freshwater mussels of the United States and Canada.
Fisheries 18 (9): 6-22.
Clayton WRF NRWD Aquatic Species Survey Report October 2021
Three Oaks Job# 21-300 Page 1
APPENDIX A
Figures
Clayton WRF NRWD Aquatic Species Survey Report October 2021
Three Oaks Job# 21-300 Page 2
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Project Vicinity and Survey Locations
Johnston County, North Carolina
Date. October 2021
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Clayton WRF NRWD Aquatic Species Survey Report October 2021
Three Oaks Job# 21-300 Page 3
a
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Date: October 2021
scale 0 0.5 1 Miles
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Clayton WRF NRWD Aquatic Species Survey Report October 2021
Three Oaks Job# 21-300 Page 4
q Y a * Project Location
a
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scale: 0 0.5 1 Miles
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Job No 21-300
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2-2
Clayton WRF NRWD Aquatic Species Survey Report October 2021
Three Oaks Job# 21-300 Page 5
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Clayton WRF NRWD Aquatic Species Survey Report October 2021
Three Oaks Job# 21-300 Page 6
APPENDIX B
Select Photographs
Clayton WRF NRWD Aquatic Species Survey Report October 2021
Three Oaks Job# 21-300 Page 7
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Clayton WRF NRWD Aquatic Species Survey Report October 2021
Three Oaks Job# 21-300 Page 9
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Clayton WRF NRWD Aquatic Species Survey Report October 2021
Three Oaks Job# 21-300 Page 10
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Clayton WRF NRWD Aquatic Species Survey Report
Three Oaks Job# 21-300
October 2021
Page 11
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Clayton WRF NRWD Aquatic Species Survey Report October 2021
Three Oaks Job# 21-300 Page 12
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Clayton WRF NRWD Aquatic Species Survey Report October 2021
Three Oaks Job# 21-300 Page 13
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