20221576 Ver 1_09_Utilities 1_City of Sanford Response Letter to July 26 RFI_20230804

1017 Main Campus Dr., Suite 1200 + Raleigh, North Carolina 27606 + 919-582-5850 + FAX [phone] www.freese.com
August 3, 2023
Response to Request for Information — City of Sanford Utilities
USACE Action ID No. SAW-2014-00610 — Dateo f RFI: July 26, 2023
DWR Project No. 20221576
Comments received (Black Text) and Responses (Blue Text)
USACE Comments
1) On the "Phase I Water and Sewer Line Potential WOTUS Impacts" drawings submitted on 6/1/2023,
the legend lists the light blue line as the "Phase 2 Water" line and the dark blue line as the "Phase 1
Water"; this appears to be reversed on the sheets themselves.
The Phase I Water and Sewer Line Potential WOTUS Impacts legend has been updated
to accurately reflect the line types.
2) Phase 2 Sewer
a. Impacts S-38, S-36, S-34, S-33, and S-87 are all very large temporary impacts, which do not
appear to be justified by the size of the sewer line installation. Please justify that these
temporary impacts have been minimized to the maximum extent practicable for the utilities
necessary to support the Vinfast project alone, rather than any future unrelated project.
The temporary impact areas have been reduced to the area required to install
impervious dikes and the pump -around erosion and sediment control measures at each
location. The remainder of the stream that is within the limits of disturbance will not be
impacted and will be protected with coir wattle erosion control measures. The plan set
notes have also been updated to include language that no grubbing will occur along
streams both in the temporary impact areas and within the limits of disturbance.
b. Sheets FM-5, FM-6, and FM-7 show proposed grades several feet above the elevation of the
Streams P2S_S29, P2S_28, P2S_27, RD_P2S_SD, and P2S_S26. Furthermore, the grades and
culverts that are shown on these plan sheets appear to be proposed for a future unrelated
road project and are not consistent with minimization practicable for the proposed project.
Please revise the plan sheets accordingly.
The installation of the sewer line along the section of Phase 2 sewer (Sheets FM-2
through FM-9) will require grading of the existing ground surface to allow for access by
construction equipment and to facilitate future access for maintenance and repair of
the sewer line. The topography in this area precludes burial of the line as shown on the
remainder of the project due to constructability and access issues that would result
from the depth of burial associated with the topography (in excess of 20 feet in some
locations). The method of construction will include the grading of the project area
(within the established limits of disturbance) to provide the required overburden depth
for the sewer line, and as a result several of the streams will require culverts to facilitate
access along the alignment. All references to the future road alignment in the area have
been removed from the plans.
3) Itemized comments regarding avoidance and minimization and apparent inconsistencies between
various impact drawings and plan sheets are provided in columns V and W on the attached

FREESE
Page 2 of 4
spreadsheet; please revise and update the affected drawings, plans, and impact spreadsheets
accordingly.
Responses to USACE comments that are related to inconsistencies are included in the
attached table and the excel file that has been provided with the updated plan sets.
Responses to comments related to avoidance and minimization are detailed below.
Updated impact areas in shapefile format have also been provided.
Phase 1 Water— No comments related to avoidance and minimization
Phase 2 Water
o Impact ID W-53c
■ The access road from Corinth Road is an unimproved dirt road that is
approximately 8 to 10 feet wide that the landowner currently uses for
property access. The existing road is wide enough for the average
wheelbase width of construction vehicles, however due the height and
width of the equipment, removal of vegetation along the road will be
required to facilitate construction access. Post -construction activities,
including access for maintenance and repair, may require equipment
similar to the type used for construction, which will require future
vegetation management along the road. Given the future potential for
tree removal or trimming along the road, the permanent cover
conversion impact classification was selected for this area. No road
expansion will occur in the area (i.e., no filling of the wetland areas),
and the road will be returned to pre -construction condition upon
completion of the construction activities.
o Impact ID W-59
■ The wetland area within the staging area at the end of the HDD area
along Gulf Creek was identified as the headwaters for the larger
wetland complex that is located between the staging area and Gulf
Creek. Relocation of the staging area to the south will result in a larger
wetland impact and the soil saturation within that area would result in
construction equipment and supplies sinking below the ground surface
and cause long lasting permanent impacts to the physical structure of
the wetland soils. The open area to the west of the staging area
contains the Dixie high pressure gas pipeline that limits use of
construction equipment and requires a 25-foot offset from the gas line.
Similar restrictions are present along the northern boundary of the
staging area, where utilities limit the project limits of disturbance.
Corinth Road runs along the eastern boundary of the staging area,
providing further limitation to the relocation of the staging area.
Furthermore, the HDD installation requires equipment to be staged
parallel to the proposed boring location, which necessitates the current
limits of disturbance. The wetland area will be returned to pre -
construction conditions at the completion of the project.
o Impact ID W-62
■ The wetland area is located within the HDD laydown area for the HDD
crossing of the Cape Fear River. Similar to Impact ID W-59, the area is
bordered along the western boundary by the Dixie high pressure gas
pipeline, which does not allow use of construction equipment. The area
to the east of the laydown area contains additional wetland area, and
the area to the northeast borders a large unnamed tributary of the Cape

Page 3 of 4 FWTIICVOLS
Fear River, which does not allow enough room for placement of HDD
equipment. The HDD installation requires equipment to be staged
parallel to the proposed boring location, which necessitates the current
limits of disturbance. The wetland area will be returned to pre -
construction conditions at the completion of the project.
Phase 2 Sewer
o Impact IDs S-33, S-34, S-35, S-36, S-38, S-87
■ These temporary stream impacts were located along the section of
Phase 2 sewer (Sheets FM-2 through FM-9) that will require grading of
the existing ground surface to allow for access by construction
equipment and to facilitate future access for maintenance and repair of
the sewer line. The topography in this area precludes burial of the line
as shown on the remainder of the project due to constructability and
access issues that would result from the depth of burial associated with
the topography (in excess of 20 feet in some locations). The method of
construction will include the grading of the project area (within the
established limits of disturbance) to provide the required overburden
depth for the sewer line, and as a result several of the streams will
require culverts to facilitate access along the alignment. The temporary
impact areas have been reduced to the area required to install
impervious dikes and the pump -around erosion and sediment control
measures at each location. The remainder of the stream that is within
the limits of disturbance will not be impacted and will be protected with
coir wattle erosion control measures. The plan set notes have also been
updated to include language that no grubbing will occur along streams
both in the temporary impact areas and within the limits of disturbance

City of Sanford
Updated WOTUS Impacts Table

millimmillimilmillim
INN
milloomillimilmossomm
ION
millsomillimilmossom
ION
millsomillimilmossomm
ION
IBM
INN
-2E
ION
IBM
ION
millsomillimilmossomm
INN
111111110011111011101111011
INN
LLE1111101111011111111101
INN
.....
..
...
.
. . . .
...
1111111111111110111111111
INN
mosionougglailmosso
.0
ION

8
\\/
9
/\
/
E
E
ML

`
\
}}
`
}}
`
}}
`
\
E E
/\
f E E
/\
E 'E
/ /
E
/
E 'E
Ea R
E
2 -
/
E
/
E 'E
Ea R
Ea
2 B
/
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E

.E /
'E
2
f-
/
Ea
E '
E
\\
}
/
/
6
E
E
E
E