20240379 Ver 1_AWT Response to DWQ Comments- Request for Additional Informaiton 20240379 Ver1_20240521

Below are answers to comments DWQ sent 5/14/2024 regarding Lillington South Regional Sewer
Extension — Project Jay Meyers.
Below is a reiteration of DWQ questions. Words in blue are AWT/Jay Meyers answers.
1. In the PCN the response for CA. Protect Description 41. " The expansion will lay underground
pipeline along the existing pipeline... moving the pump station to the north would mean adding
approximately 500 feet ...It would negatively impact the developable area... making property
acquisition more costly for the town." Seems to contradict the response under 5. E. 1. Avoidance
and Minimization, where it is stated "... the force main alignment was moved to the north so as to
minimize wetland impact as opposed to following the existing gravity sewer, even though this
resulted in need for acquiring additional easements..."
Please clarify which statement( s) accurately describe the current plan and how the plan
minimizes
wetland impacts. Provide further justification as needed to adequately document that all
reasonable avoidance and minimization efforts have been taken.
Moving the pump station to the north would require 500-feet of additional gravity sewer with
depths much greater than a force main. The force main, which has 3-4 feet of bury and is
half the size of the gravity line, is the one that's alignment moved to the north to avoid some
wetlands. So, the PCN is talking about 2 different pipes and 2 different impacts.
2. Table of Wetlands Impacts show W1 to W5 but plan sheets show W1, W2, W5 and W6. Please
clarify nomenclature and correct either impacts table or labels on all Plan sheets and resubmit
updated documents.
Please see updated Impact Summary Table titled "Impact Summary Wetland ID Updated
052124. Here you will see I have added two columns. One reads "Proposed Impact ID AWT"
and second reads "Proposed Impact ID JM LOD Wetland Impact Drawing. There was a slight
difference in howJayand I identified thewetlands.
3. The two Wetland Impacts plan sheets show the limit of disturbance up to the top of streambank
or across stream (Between W1 and W2 and near W5). Standard 401 Certification requirement
states " Any utility construction corridor that is parallel to a stream or open water shall not be
closer than 10 feet to the top of bank or ordinary high- water mark." If this requirement cannot
be met in a specific location, please identify that location and provide details of why the project
cannot be modified to meet this condition. Please also submit a very detailed construction
sequence that includes additional measures that will be taken to protect long term stream
stability and to protect downstream water quality standards.
W1 is crossing ditch otherwise is notwithin 10-feet of stream bank. Looking atAWT's
Wetland/Stream Impact Map, that part of the stream is drawn in accordingto GIS records.
The extent of the maps gives you the impression it is very close. W2 is not within 10 feet of
the stream. I have attached an exhibit (exhibit 17may2024) for W5. Beaver dams were
removed in this area about three years ago and the stream appears to be still establishing
its course. We are also faced with property owners wanting to preserve buildable areas on
Julie Davidson of AWT submitted these responses 5/21 /24 on behalf of Jay Meyers Engineering/City
of Lillington

their property. So, I believe that the impacts are minimal in location proposed but can
discuss further.
4. There are no stream impacts (temporary or permanent) stated in the PCN. Please confirm that is
accurate or update accordingly and provide detailed plan sheets at a closer scale as needed.
No stream crossing other than the ditch on 201
5. Standard 401 Certification requirements state, " Construction corridors in wetlands and/ or across
stream channels shall be minimized to the maximum extent practicable and shall not exceed 40
feet wide." Please confirm there are no areas that will exceed 40' of disturbance (temporary or
permanent)
No areas will exceed 40-feet of disturbance for pipeline corridors.
6. PCN states under item C. 4b. " A new easement will be established with the expansion." Standard
401 Certification regulation states, " Permanent maintained access corridors in wetlands and
across stream channels shall be restricted to the minimum width practicable and shall not exceed
30 feet wide." Permanent easements are different than permanent, maintained corridors. Do
you intend to have permanent, maintained corridors wider than 30 feet? If so, justify.
The existing sewer easement will be abandoned. While the gravity sewer will have a 40-foot
easement, the maintained area will likely only be 20-feet. The forcemain has a 30-foot
easement but again the width maintained will be about 20-feet.
7. Item E. 4h. on PCN states mitigation is waiting for a letter form in -lieu program. Please provide a
copy of the letter or current status.
This letter was received 4/24/2024. It has been included with this response.
8. On the PCN Item G. 1. is answered " No", however, this is noted as an ARPA funded project, which
are public funds. The answer should be, " Yes", with a comment / reference to the project #
SRPW- ARP- 0326. No additional comments are required on this item as it is noted for future
reference. OK, thank you.
9. On the PCN item G. 3b. The comment is specific to Pump Station and Collection System capacity,
but does not address potential downstream water quality cumulative impacts from additional
construction/ development. Please provide additional narrative description.
Lillington's UDO addresses stormwater runoff and environmental conservation for
cumulative impact mitigation. See planning page for UDO environmental section.
Julie Davidson of AWT submitted these responses 5/21 /24 on behalf of Jay Meyers Engineering/City
of Lillington

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ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
MARC RECKTENWALD
Director
Alicia Gregory
Town of Lillington
PO Box 296
Lillington, NC 27546
NORTH CAROLINA
Environmental Quality
April 24, 2024
Project: Lillington South Regional Sewer Expansion
Expiration of Acceptance: 10/24/2024
County: Harnett
The purpose of this letter is to notify you that the NCDEQ Division of Mitigation Services (DMS) is willing to
accept payment for compensatory mitigation for impacts associated with the above referenced project as
indicated in the table below. Please note that this decision does not assure that participation in the DMS in -
lieu fee mitigation program will be approved by the permit issuing agencies as mitigation for project impacts.
It is the responsibility of the applicant to contact permitting agencies to determine if payment to the DMS will
be approved. You must also comply with all other state, federal or local government permits, regulations or
authorizations associated with the proposed activity including G.S. § 143-214.11.
This acceptance is valid for six months from the date of this letter and is not transferable. If we have not
received a copy of the applicable 404 Permit/401 Certification/Buffer Approval within this time frame,
this acceptance will expire. It is the applicant's responsibility to send copies of the permits to DMS. Once
DMS receives a copy of the permit(s) an invoice will be issued based on the required mitigation in that permit
and payment must be made prior to conducting the authorized work. The amount of the in -lieu fee to be paid
by an applicant is calculated based upon the Fee Schedule and policies listed on the DMS website.
Based on the information supplied by you in your request to use the DMS, the impacts for which you are
requesting compensatory mitigation credit are summarized in the following table. The amount of mitigation
required and assigned to DMS for this impact is determined by permitting agencies and may exceed the
impact amounts shown below.
River Basin
Impact Location
8-di it HUC
Impact Type
Impact Quantity
Cape Fear
03030004
Riparian Wetland
0.26
Upon receipt of payment, DMS will take responsibility for providing the compensatory mitigation. The
mitigation will be performed in accordance with the In -Lieu Fee Program instrument dated July 28, 2010.
Thank you for your interest in the DMS in -lieu fee mitigation program. If you have any questions or need
additional information, please contact [e-mail].
Sincerely,
Kelly B. Williams
In -Lieu Fee Program Coordinator
cc: Julie Davidson, agent
North Carolina Department of Environmental Quality I Division of Mitigation Services
217 West Jones Street 1 1652 Mail Service Center I Raleigh, North Carolina 27699-1652
h(h�TH :.AROI iRA IV
o �nmmmenni w�a 919,707,8976