20230094 Ver 1_More Info Received_20230315 (2)

Homewood, Sue
From:
Bivens, Kayla <[e-mail]>
Sent:
Wednesday, March 15, 2023 3:51 PM
To:
[e-mail]
Cc:
victor.czar; Thomas, Zachary T
Subject:
[External] RE: Request for Additional Information: SAW-2023-00134 (Sanford Water
Filtration Facility 30 MGD Expansion / 0 Avents Ferry Road / Sanford / Lee County)
Attachments:
Additional Information_2023Mar.pdf, Impact Maps_2023Mar.pdf, Temp LOD and
Deli neation.zip; 2023Mar_Design Plans.pdf, Letter of Availability_2023Feb.pdf
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David,
Good afternoon and thank you for your comments. Please refer to our responses below and feel free to reach out via
email and/or phone if you have any additional questions. Please note, a permit modification has been submitted for the
proposed project due to minor changes to potential installation methodology of the new intake as well as removal
methodology of the existing intake. During the permit modification, special concern was taken to address the comments
you provided. The permit modification has been submitted through the online portal; however, I've included a copy of
the recently submitted documentation to this email for your reference. All changes to the attached Additional
Information section have been denoted in red for ease.
1) It is unclear that this project could be authorized by NWP 7, as the description of this NWP 7 states that "The
construction of intake structures is not authorized by this NWP unless they are directly associated with an
authorized outfall structure." Please provide additional information to confirm that this project fits the
description of NWP 7, or propose authorization via a different NWP.
The proposed intake structure is directly associated with an existing NPDES permitted discharge structure. The
NDPES permit (NC0085359) has been provided to the City of Sanford for the Sanford WFF located off Poplar
Springs Church Road. The facility is classified as a minor facility per the existing NPDES permit.
2) Your PCN included proposed impacts to streams and wetlands, however these and other potentially
jurisdictional boundaries have not been verified by the Corps.
a. A site visit will be required to verify your delineation of potential waters of the US. Please note that your
PCN is considered on hold until your submitted delineation is verified by our office;
Please provide dates and times so we can coordinate a site visit that is convenient for your schedule.
Thank you.
b. Please provide GIS shapefiles or kml/kmz files of the Temporary LOD and delineation of potential waters
of the US to aid in our review;
Shapefiles associated with the temporary LOD and delineation are attached for reference.
c. Further, additional revisions may be required on the PCN and plans based on the final Corps -verified
boundaries of potential waters of the US;
Comment has been noted.
3) Clearly explain any association between the proposed project (Corps Action ID: SAW-2023-00134) and the
proposed overall Vinfast (i.e. Project Blue; Action ID: SAW-2014-00610) single and complete project. Such

information is necessary to determine this project's independent utility from Project Blue due to the coincident
timing of their respective applications and the fact that the City of Sanford would supply all sewer and water
utilities to Project Blue.
The Sanford WFF is being expanded regardless of Vinfast (Project Blue) and, with that, upgrades to the intake
structure and its associated waterline are necessary. Lee County continues to experience exponential growth,
aside from Project Blue, in the form of single and multi -family residential developments. The increase in
development within the Sanford WFF's service area leads to an increase demand in high quality drinking water.
The existing intake is partially buried below the river mud line causing high levels of sediment ingestion,
inhibiting proper collection of water. Due to the potential overlap in construction timelines, coordination with
Project Blue took place to ensure mitigation of the delineated wetlands onsite is not duplicative for the City of
Sanford; however, the proposed project does not rely on the advancement of Project Blue. Additionally, the
potential overlap in construction timelines provided an opportunity to limit impacts to jurisdictional waters by
narrowing the permanent access corridor through coordination of a shared corridor.
4) Is rip rap proposed to be placed in the stream bed or banks associated with any stream crossings? If so, ensure
that the rip rap complies with NWP Regional Condition B.8 a and b, include the rip rap on the plan and profile
views of these crossings, and ensure that the stream impacts associated with rip rap are included and itemized
clearly as permanent impacts on the PCN;
No riprap fill is proposed below the ordinary high-water line for stream bed or banks associated with stream
crossings. The proposed influent pipe will be buried below existing grade and temporarily impacted bed and
banks will be set back to grade using the original substrate set aside during construction activities. Any riprap
used during bank stabilization will not encroach on or below the stream's ordinary high-water line. Installation
of a temporary stream crossing will take place at S1 via a dragline bridgemat that will span from top of bank to
top of bank. Please refer to detail 2 and detail C-35-0704 on sheet PPD6 of the attached design plans associated
with the recent permit modification.
5) Provide a restoration plan for all temporary wetland and stream impacts per NWP Regional Conditions B.10.c
and 11. Include confirmation that the top 6-12 inches of the trench will be backfilled with topsoil from the
trench in the wetland impact areas.
A restoration plan for temporary impacts to onsite wetlands and streams is provided in the attached Additional
Information document. Disturbed areas, including wetland and stream impacts, will be returned to original
grade and seeded with an appropriate native seed mix as soon as possible, not to exceed 90 days of completion
of the project. In wetlands, the contractor shall remove and stockpile the top 12" of material. The stockpiled
material shall be used to backfill the top 12" of the trench in wetlands during backfill operations. Trenches will
be constructed and backfilled per applicable regulations to ensure waters of the U.S. are not subject to drainage
during construction activities. Please refer to the erosion control section on sheet C001 of the attached design
plans for additional details relative to the restoration of temporarily disturbed wetland areas following
construction. Swamp matting will be used during construction where appropriate in wetland areas. Excavation
of the pipe trench will be performed as prescribed by the USACE in jurisdictional areas, and side casting of
excavated material into abutting wetland areas will be avoided to the extent feasible. In areas where avoidance
is not feasible, side casting will occur as prescribed by NWP 58.
6) The PCN and Delineation Impact Map 4 mentions a permanent access road off of Avents Ferry Road, traversing
W3, "associated with an ongoing project that will be permitted, mitigated, and installed by others prior to
Hazen's proposed project." Note that the ongoing project referenced is Project Blue (Action ID: SAW-2014-
00610), which has not at present been authorized, nor is a permit decision timeframe known at this point. The
Corps would consider all proposed impacts to potential waters of the US associated with the current project
based on the current in -field condition at the time of permitting, and cannot rely on as -yet unauthorized
wetland impacts proposed for other projects.
Given the unknown timeframe associated with Project Blue's permit decision, temporary access roads have
been added to the attached design plans for the proposed project. A temporary stream crossing associated with
S1 is proposed off Lower River Road. Please refer to page PP8 of the attached design drawings for additional

details related to the temporary stream crossing. Swamp mats will be placed across W3 during construction
activities to provide temporary crossing of the non -forested wetland.
7) As noted above, no permit decision has been made for Project Blue (SAW-2014-00610), nor is a decision
timeframe known at this point. Compensatory mitigation requirements for the current proposed project cannot
rely on as -yet unauthorized wetland impacts proposed for other projects. At present, the current project
proposes permanent conversion of 0.821 acre of forested wetlands to herbaceous wetlands, which would
require compensatory mitigation (typically at a 1:1 ratio) per Nationwide Permit Regional Condition B.10.d due
to permanent reduction in wetland function.
A letter of availability has been acquired from Wildlands Holdings IV, LLC to confirm sufficient wetland credits
are available at Middle Cape Fear Umbrella Mitigation Bank: Daniels Creek Mitigation Site to satisfy the 0.821
acre of permanent conversion impacts requested in the comments received with this RFI. Given the
undetermined timeline for permitting relative to Project Blue, the City of Sanford will plan to mitigate for the
0.821 acre of conversion impacts associated with the Sanford Water Filtration Facility 30 MGD Expansion. To
ensure mitigation of the proposed project area is not duplicative, coordination with Project Blue will take place
prior to the purchase of mitigation credits. Mitigation credits will be purchased by whichever project (i.e.,
Sanford WFF 30 MGD Expansion or Project Blue) is first to reach the construction phase following receipt of
required permits. A total of 0.821 acre was requested for the initial letter of availability; however, 0.53 acre of
permanent impact will result from the proposed project. The surrounding 0.28 acre of temporary impact being
utilized for the proposed project's limits of disturbance will be seeded with appropriate wetland seeding mix
following construction activities. Please refer to the attached letter of availability provided by Wildlands
Holdings IV, LLC for further details.
8) Given the proximity of this project to known populations of several threatened/endangered species (namely the
Cape Fear shiner), as well as potentially suitable habitat for these species occurring within the project action
area, we will initiate informal consultation with the US Fish and Wildlife Service (USFWS). Please note that the
Corps cannot verify the use of any NWP until Section 7 consultation is complete.
It has been noted that informal consultation with the USFWS was requested as of February 16, 2023. Thank you.
9) Given that the proposed project activities occur in areas that may contain archeological resources, consultation
may need to be initiated with the State Historic Preservation Office; they require up to 30 days to respond to our
coordination request. Please note that the Corps cannot verify the use of any NWP until consultation pertaining
to Section 106 of the National Historic Preservation Act is complete.
Comment has been noted. Thank you.
10) It is your responsibility to contact the North Carolina Division of Water Resources (NCDWR) Raleigh Regional
Office to determine the 401 requirements for this project. Please note that, if an Individual 401 Water Quality
Certification (WQC) is required from NCDWR (which appears to be the case here), the Corps cannot verify the
use of any NWP without a valid 401 WQC.
Coordination with NCDWR has been initiated as of January 23, 2023 following NCDWR receival of the 401
permitting fee.
11) Please note that responses to the questions above may prompt additional information requests to allow full
evaluation of the proposed project.
Comment has been received and noted.
Thank you!
Kayla Bivens
Assistant Scientist I Hazen and Sawyer
4011 Westchase Blvd, Suite 500, Raleigh, NC 27607
540 797-1636 (cell) 1919 833-7152 (main)
kbivens(j�haze nandsawyer.com I haze nandsawye r. com

From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Tuesday, February 14, 2023 6:28 PM
To: Bivens, Kayla <[e-mail]>; victor.czar <[e-mail]>
Cc: Thomas, Zachary T <[e-mail]>
Subject: Request for Additional Information: SAW-2023-00134 (Sanford Water Filtration Facility 30 MGD Expansion / 0
Avents Ferry Road / Sanford / Lee County)
Caution! External email - think before you click
0
Thank you for your PCN, dated 1/16/2023, for the above referenced project. I have reviewed the information and need
clarification before proceeding with verifying the use of Nationwide Permits (NWPs) 7 and 58 (https://saw-
reg.usace.army.mil/NWP2021/NWP-7.pdf, https://saw-reg.usace.army.mil/NWP2021/NWP58.pdf). Please submit the
requested information below (via e-mail is fine) within 30 days of receipt of this Notification, otherwise we may deny
verification of the use of the NWP(s) or consider your application withdrawn and close the file:
1) It is unclear that this project could be authorized by NWP 7, as the description of this NWP 7 states that "The
construction of intake structures is not authorized by this NWP unless they are directly associated with an
authorized outfall structure." Please provide additional information to confirm that this project fits the
description of NWP 7, or propose authorization via a different NWP.
2) Your PCN included proposed impacts to streams and wetlands, however these and other potentially
jurisdictional boundaries have not been verified by the Corps.
a. A site visit will be required to verify your delineation of potential waters of the US. Please note that your
PCN is considered on hold until your submitted delineation is verified by our office;
b. Please provide GIS shapefiles or kml/kmz files of the Temporary LOD and delineation of potential waters
of the US to aid in our review;
c. Further, additional revisions may be required on the PCN and plans based on the final Corps -verified
boundaries of potential waters of the US;
3) Clearly explain any association between the proposed project (Corps Action ID: SAW-2023-00134) and the
proposed overall Vinfast (i.e. Project Blue; Action ID: SAW-2014-00610) single and complete project. Such
information is necessary to determine this project's independent utility from Project Blue due to the coincident
timing of their respective applications and the fact that the City of Sanford would supply all sewer and water
utilities to Project Blue.
4) Is rip rap proposed to be placed in the stream bed or banks associated with any stream crossings? If so, ensure
that the rip rap complies with NWP Regional Condition B.8 a and b, include the rip rap on the plan and profile
views of these crossings, and ensure that the stream impacts associated with rip rap are included and itemized
clearly as permanent impacts on the PCN;
5) Provide a restoration plan for all temporary wetland and stream impacts per NWP Regional Conditions B.10.c
and 11. Include confirmation that the top 6-12 inches of the trench will be backfilled with topsoil from the
trench in the wetland impact areas.
6) The PCN and Delineation Impact Map 4 mentions a permanent access road off of Avents Ferry Road, traversing
W3, "associated with an ongoing project that will be permitted, mitigated, and installed by others prior to
Hazen's proposed project." Note that the ongoing project referenced is Project Blue (Action ID: SAW-2014-
00610), which has not at present been authorized, nor is a permit decision timeframe known at this point. The

Corps would consider all proposed impacts to potential waters of the US associated with the current project
based on the current in -field condition at the time of permitting, and cannot rely on as -yet unauthorized
wetland impacts proposed for other projects.
7) As noted above, no permit decision has been made for Project Blue (SAW-2014-00610), nor is a decision
timeframe known at this point. Compensatory mitigation requirements for the current proposed project cannot
rely on as -yet unauthorized wetland impacts proposed for other projects. At present, the current project
proposes permanent conversion of 0.821 acre of forested wetlands to herbaceous wetlands, which would
require compensatory mitigation (typically at a 1:1 ratio) per Nationwide Permit Regional Condition B.10.d due
to permanent reduction in wetland function.
8) Given the proximity of this project to known populations of several threatened/endangered species (namely the
Cape Fear shiner), as well as potentially suitable habitat for these species occurring within the project action
area, we will initiate informal consultation with the US Fish and Wildlife Service (USFWS). Please note that the
Corps cannot verify the use of any NWP until Section 7 consultation is complete.
9) Given that the proposed project activities occur in areas that may contain archeological resources, consultation
may need to be initiated with the State Historic Preservation Office; they require up to 30 days to respond to our
coordination request. Please note that the Corps cannot verify the use of any NWP until consultation pertaining
to Section 106 of the National Historic Preservation Act is complete.
10) It is your responsibility to contact the North Carolina Division of Water Resources (NCDWR) Raleigh Regional
Office to determine the 401 requirements for this project. Please note that, if an Individual 401 Water Quality
Certification (WQC) is required from NCDWR (which appears to be the case here), the Corps cannot verify the
use of any NWP without a valid 401 WQC.
11) Please note that responses to the questions above may prompt additional information requests to allow full
evaluation of the proposed project.
Please let me know if you have any questions.
Sincerely,
Dave Bailey
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE-SAW-RG-R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Mobile: [phone]
Email: [e-mail]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: https://regulatory.ops.usace.army.mil/customer-service-survey/
Thank you for taking the time to visit this site and complete the survey.
From: RaleighNCREG <[e-mail]>
Sent: Tuesday, January 17, 2023 2:39 PM
To: [e-mail]
Cc: Bailey, David E CIV USARMY CESAW (USA)<[e-mail]>
Subject: SAW-2023-00134 (Sanford Water Filtration Facility 30 MGD Expansion / 0 Avents Ferry Road / Sanford NC / Lee
County)
Good afternoon,

Your Pre -Construction Notification (PCN) NWP request has been received, assigned action ID SAW-2023-00134 and
forwarded to Dave Bailey for further processing.
Please refer to the action ID in all correspondence.
Thank you,
Josephine Schaffer
From: [e-mail] <[e-mail]>
Sent: Monday, January 16, 2023 12:28 PM
To: RaleighNCREG <[e-mail]>
Cc: SAW-PCN-RG <[e-mail]>
Subject: [Non-DoD Source] PCN - Lee - Non -DOT
A new project has been received on 1/16/2023 12:25 PM for Sanford Water Filtration Facility 30 MGD Expansion. The
link below will take you to the project folder.
https://edocs.deg.nc.gov/Laserfiche/index.aspx?db=WaterResources#id=2643567;view=browse
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