20190866 Ver 1_Notice of Initial Credit Release - NCDMS Huntsman Mitigation Site_20221007 (2)

Baker, Caroline D
From: Davis, Erin B
Sent: Monday, November 7, 2022 5:52 PM
To: Baker, Caroline D
Subject: FW: [External] FW: Notice of Initial Credit Release/ NCDMS Huntsman Mitigation Site/
SAW-2019-00836/ Wilkes County
Laserfiche Upload: Email & Attachment
DWR#: 20190866 v.1
Doc Date: 10/7/22
Doc Type: Mitigation — Mitigation Information
Doc Name: General topic of email title
From: Kristi Suggs <[e-mail]>
Sent: Friday, October 7, 2022 8:42 AM
To: Tugwell, Todd J CIV USARMY CESAW (US) <[e-mail]>; Davis, Erin B <[e-mail]>;
Wilson, Travis W. <[e-mail]>; Bowers, Todd <[e-mail]>; Haywood, Casey M CIV
USARMY CESAW (USA <[e-mail]>; Leslie, Andrea J <[e-mail]>; McHenry,
David G <[e-mail]>; Reid, Matthew <[e-mail]>; Harmon, Beth
<[e-mail]>; Stanfill, Jim <[e-mail]>; Allen, Melonie <[e-mail]>;
Shawn Wilkerson <[e-mail]>; Aaron Earley <[e-mail]>; Wiesner, Paul
<[e-mail]>; Crumbley, Tyler A CIV USARMY CESAW (USA <[e-mail]>
Cc: Sara Thompson <[e-mail]>; Emily Israel <[e-mail]>
Subject: [External] FW: Notice of Initial Credit Release/ NCDMS Huntsman Mitigation Site/ SAW-2019-00836/ Wilkes
County
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Good Morning Everyone,
As requested, Wildlands is providing written response to the NCIRT's comments regarding the Huntsman Mitigation
Site's Baseline Monitoring Report and Record Drawings prior to the Site meeting on October 13, 2022. Included with our
responses are the georeferenced CCVP maps for the Site. Please see attached and let me know if you have any
questions or need any additional documentation. Thank you very much!
Kristi Suggs
Kristi Suggs I Senior Environmental Scientist
0:704.332.7754 x110 M: 704.579.4828
Wildlands Engineering, Inc.
1430 S. Mint St, Suite 104
Charlotte, NC 28203
From: Browning, Kimberly D CIV USARMY CESAW (USA) <[e-mail]>
Sent: Wednesday, September 14, 2022 2:10 PM
To: Wiesner, Paul <[e-mail]>

Cc: Tugwell, Todd J CIV USARMY CESAW (USA)<[e-mail]>; '[e-mail]'
<[e-mail]>; Wilson, Travis W. <[e-mail]>; Bowers, Todd <[e-mail]>;
Haywood, Casey M CIV USARMY CESAW (USA) <[e-mail]>; Andrea Leslie
<[e-mail]>; McHenry, David G <[e-mail]>; Reid, Matthew
<[e-mail]>; Harmon, Beth <[e-mail]>; Stanfill, Jim <[e-mail]>;
Melonie Allen <[e-mail]>; Shawn Wilkerson <[e-mail]>; Aaron Earley
<[e-mail]>; Crumbley, Tyler A CIV USARMY CESAW (USA) <[e-mail]>
Subject: Notice of Initial Credit Release/ NCDMS Huntsman Mitigation Site/ SAW-2019-00836/ Wilkes County
Good afternoon,
The 15-Day As-Built/MYO review for the Huntsman Mitigation Site (SAW-2019-00836) ended September 9, 2022. Per
Section 332.8(o)(9) of the 2008 Mitigation Rule, this review followed the streamlined review process. All comments
received from the NCIRT are incorporated in the email below. There were no objections to issuing the initial 30% credit
release of 1,745.082 warm stream mitigation units; however, we are requesting a written response to IRT comments
prior to the site visit scheduled for October 13, 2022. Please send a georeferenced CCPV map along with your
responses. Please find attached the current signed ledger.
The site visit will be held October 13, 2022, 10:30 am, Wilkes County (36.140626,-80.932103)
Kim Isenhour, USACE:
1. In addition to DWR's concerns, please confirm what size rock was used in the constructed riffles on UT1. As I
recall, there was degradation on a steep section near STA 210+50 (?). DWR expressed concerns about the size of
the material used; and questioned whether using larger rock in these riffles and embedding some Class I and
only top dressing with any remaining on -site smaller material may have been more appropriate. Please provide
more detail on this repair.
Erin Davis, NCDWR:
1. The PP14 photo shows the Ingle Hollow Road culvert. In response to WRC's draft mit plan review comment
regarding the perched culvert being an aquatic passage barrier, a sill was to be added downstream setting the elevation
to submerge the pipe outlet six inches. Based on the photo it's difficult to see if water is being backed up into the
culvert. Please confirm that the structure was installed as noted and the barrier has been abated.
2. The photo of veg plot 2 appears to show exposed soil with no signs of germination or straw cover, unlike the
other veg plot photos. Has cover/stabilization of this area been addressed? Additionally, please watch for rill formation
and sediment migration along graded slopes that were not matted (e.g., PP8 and PP9). Between working with pond
bottom sediments, areas of priority 2 and very steep side slopes, DWR is concerned about sediment movement within
and adjacent to the site becoming a stream pollutant risk beyond initial construction.
3. The step pool conveyance BMP photos for Old Bus Branch (PP27) and Rifle Trib. (PP23) appear very different,
with Rifle Trib. having significantly more riprap. What facilitated the Rifle Trib. BMP design change from a vegetated
BMP to a riprap step pool conveyance channel? It seems the vegetated BMP would offer more water quality benefits.
4. Since a permanent veg plot was shown in the UT1 lower pond bottom in both draft and final mitigation plan
monitoring figures, DWR did not require one in our review comments. However, since that veg plot has been changed to
a mobile plot, DWR is now requiring a permanent veg plot within the UT 1 lower pond bottom.
5. IRT members expressed concerns about the proposed buffer widths during the mitigation plan review. One
reason DWR was concerned about narrower buffers along UT1 was that it meant steeper side slopes, which as the
redline shows resulted in multiple riprap lined ditches not planned for in the initial design. Of particular concern is that
four of the riprap ditches are in the vicinity of existing chicken houses. Please provide more information on the necessity
of adding the riprap ditches. How does this affect the mitigation plan Section 3.4 functional uplift to "diffuse overland
non -point source pollutants from adjacent land use"? Additionally, Sheet 1.1.5 shows added riprap covering an existing
wetland area. If this was/is a jurisdictional feature, why wasn't a non -hardened stabilization option applied?

6. Section 3.3 noted a couple riffle cross sections were larger than designed. Are these areas shown on the redline
drawings? If not, can you please identify the locations.
7. Please add stream and reach labels to the CCPV Figures 3.1 and 3.2.
Please reach out with any questions.
Thanks,
Kim
Kim Isenhour
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers 1 919.946.5107