20070173 Ver 2_NCDOT resp to USACE re PN Comments_20160212

Burdette, Jennifer a
From: [e-mail]
Sent: Friday, February 12, 2016 11:31 AM
To: [e-mail]; [e-mail]; Burdette, Jennifer a
Cc: [e-mail]; Coggins, Tony C; Johnson, Wendi O; Little, Timothy M
Subject: SAW -2015-02127 Novo Nordisk/NCDOT response to Public Notice
Attachments: SAW -2015 -02127 -Public Notice response letter to EPA comments 02.12.pdf;
Neighborhood Meeting 09Feb2016 Meeting Minutes.pdf, Neighborhood Meeting
sign in sheet.pdf
John,
Attached for your review is Novo Nordisk/NCDOT's collective response to the EPA comment received for this project
during the Public Notice period ending on Feb. 8, 2016. Please review and let me know if there is any additional
information need to support our responses.
As part of the Town of Clayton's Major Site Plan and Special Use permit requirements, Novo Nordisk hosted a
Neighborhood Meeting on February 9, 2016. Representatives from Novo Nordisk, NCDOT, Town of Clayton, Fluor
Engineering, and Kimley-Horn were in attendance to assist with any questions. I have attached a copy of the meeting
minutes and sign in sheet for your file. Since there was only one comment received during the Public Notice period and
no request to the USACE to hold a Public Meeting, can we assume that the Section 404/401 will be processed without the
need any further public meetings?
Thank you for your assistance with this project,
Beth
l3e0.1h A, Ilf?eed, IIPW
Kimley-Horn 13001 Weston IParkway, Cary INC
Direct: 919 677-2073 I Mo[::)ile: 919 624.7980
Connect with us: IM.;[ea I I in.ke(11 �`� . I . r,«,R.bo�,�k, I r`€rich ii!°���"
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Kimley»>Horn
February 11, 2016
Mr. John Thomas
P,egulatory Project Manager
U.S Army Corps of Engineers
Raleigh Fbgulatory Feld Office
3331 Heritage Trade Drive, _%ite 105
Wake Forest, NC27587
FE SAW --2015-02127: Individual Section 404/401 Fbrmit Application —Public Notice Response
Novo Nordisk Bright Sty Project
Gayton, Johnston Cbunty, North Carolina
Dear Mr. Thomas:
On behalf of our dient, Novo Nordisk Pharmaceutical Industries, Inc. (Novo Nordisk) and joint
applicant North Carolina Department of Transportation (NCDOT), Kmley-Horn i s submitt i ng t he
following response to the Public Notice of January 6, 2016 for the referenced project. Asof the
comment period deadline of February 8, 2016, the only comment received by the US4CEwasfrom
the USEnvironmental Protection Agency (EPA) —Todd Bowersvia an e-mail dated January 26, 2016.
Therefore, the following commentsare in response to EPA questionstooncernsaddressed in that e -
mai 1.
EPA Comment: The applicant's stated purpose includes "to construct an AP production facility in
North Carolina", and that "the project is necessary to expand the company's ability to produce
ingredients for current and future diabetes fighting products " Additionally, the applicant has stated
that in order to minimize and avoid impacts to the aquatic environment: "In order for the
manufacturing facility to be operationally efficient, the structural components need to be in close
proximity for production sequencing as well as truck deliveries and pickup. "
1. The access road originating from Cordon Fbad does not support the applicants stated
purpose.
NCDOT/Novo Nordisk Fb$nonse: The Cordon Fbad access which is being designed and constructed
by NCDOT, is included in this permit application for the Novo Nordisk facility because it was
determined by the USACEduring pre -application meetings on October 28, 2015 and December 4,
2015, that the Cordon Fbad access is being constructed for the primary purpose of supporting the
pharmaceutical facility and thus does not have independent utility; therefore, supporting the
purpose of constructing an AP production facility.

Kimley»>Horn
Page 2
As a result of a Traffic Impact Sudy prepared by Kmley--Horn and Associates for the project
(submitted to the US4CEaspart of the Section 404/401 permit application submittal), it was
determined that Powhatan [bad could accommodate the proposed additional employee traffic with
turn lane improvements at the US70/Powhatan intersection; however, Powhatan Fbad could not
accommodate both operational and peak construction traffic for Fhase 1 and Phase 2. Construction
for Phase 1 of the facility (in non -wetland areas) is scheduled to begin in March 2016 beginning with
clearing and grubbing and site preparation activities with on-site personnel estimated to be less than
400. By 2017 as structural construction activities begin, on-site personnel with steadily increase to
approximately 1,500 and during the peak of construction in 2018 on-site personnel will increase to
approximately 3, 000 necessitating the need for additional access to the site from Gordon fbad.
The Gordon Fbad access is necessary to support the purpose and need of the pharmaceutical facility
by allowing construction vehides and equipment to safely navigate into the site via US70 to Gordon
Fbad, avoiding potential traffic and congestion along Fbwhatan Fbad during construction. The
Gordon Fbad access is also desirable from a safety operations perspective in that it provides a
separation of truck traffic and operational traffic, as well as an alternative route (other than
Powhatan Fbad) for emergency vehicle access.
2. The access road preferred alternative does not appear to minimize potential impacts to
waters of the United Slates
NGDOT/Novo Nordisk Fbsponse: The Applicants (Novo Nordisk and NCn07) demonstrated in the
application submittal that alternative on-site plans and Gordon Fbad access alternatives were
considered, along with the environmental consequences of each plan, and that the preferred Ste and
Gordon Fbad Access alternatives represented the minimum amount of impact to aquatic resources
while still meeting the project purpose.
In addition to the various Gordon Fbad access alternatives, the widening of Powhatan Fbad from an
existing 2 -lane facility to a 4 -lane facility from the existing/proposed Novo Nordisk driveway
entrances onto Powhatan Fbad down to the Highway 70 intersection was also evaluated as an
alternative. The widening of Fbwhatan Fbad would also require an at -grade widening of the existing
NOWNorfolk Southern Fbilroad crossing. There are dual tracks at this rail crossing location with the
secondary track being utilized by Amtrack as a pullover location. During the times that Amtrack uses
this pullover, the road is temporarily blocked to through traffic restricting the only emergency access
into the Ste. To allow full through access at this location for employees and emergency vehides, a
bridged crossing of the railroad would be required. Because of the required elevation of a bridged rail
crossing (approximately 30 -feet), the bridge would extend past the proposed and existing Novo
Nordisk plant entrance making it not practical. NCDOTrequires that the proposed plant entrance
align with the existing driveway entrance onto Powhatan Fbad. In addition, the widening of
Powhatan Fbad from Best Wood Drive to US 70 would impact numerous residences and businesses
with frontage along Fbwhatan Fbad. Even without the logistical constraints of the railroad crossing
and residential/business impacts, if Powhatan fbad were widened to a 4 -lane facility, the volume of

Kimley»>Horn
Page 3
the proposed operational and construction traffic would result in significant traffic congestion at the
Powhatan Fbad/US 70 intersection. Therefore, the widening of Powhatan Fbad is not considered a
practical alternative.
As stated in the permit, the impacts evaluation of each of the Gordon Fbad access alternatives was
based upon functional designs (construction slope stakes plus 25 -feet). Based upon this evaluation,
the preferred alternative had the least amount of jurisdictional impact with 3.04 acres. Snce the
submittal of the permit application, NCDOT/Wetherill Engineering has moved forward with final
design of the preferred Gordon Fbad access alternative and utilized further avoidance design
measures including tightening fill slopes from 3:1 to 1.5:1 using rock fill plating further reducing
impacts by 0.23 acre (2.81 acre). Once final design on the roadway is complete and prior to the
initiation of construction, NCDOTwill submit a permit modification to the US4CEwith final impact
quantities and mitigation requirements
EPA Comment: Assuming that the access road to the eastern portion of the proposed facility is
indeed justified:
3. Has the applicant considered an access road that originates from Best Wood Drive? It
appears that access from this location (if justified) may require the applicant to consider
working with the adjacent landowner to provide a link to Best Wood Drive.
NGDOT/Novo Nordisk Fbsponse: Access from Best Wood Drive was considered in the early stages of
project planning but not carried forward for the following reasons Best Wood Drive was not
designed/constructed for significant truck traffic Additionally, if Best Wood Drive access onto
Powhatan Fbad were utilized, it would not alleviate the operational and construction traffic on
Powhatan Pbad as required per the Traffic Sudy. If traffic on Best Wood Drive utilized North Tech
Drive for US 70 access that would be problematic because there are currently 19 business driveways
with unrestricted access onto North Tech Drive as well as parking along the street utilized by these
businesses In addition, the North Tech Drive/US70 intersection would have to be signalized to
accommodate the proposed traffic NCDOTrequires a 1,200 -foot spacing between all signalized
intersections The North Tech Drive/US70 signalized intersection would only have an 800 -foot
separation from the Powhatan Fbad/US 70 signalized intersection.
4. Has the applicant considered purchasing or leasing adjacent property in order to minimize
wetland (WD) and stream (S4) impacts?
Novo Nordisk Fosponse: Novo Nordisk approached the USLumber Company about leasing their
vacant warehouse facility for construction equipment staging and site access The warehouse was
under contract for sale to another owner and not a viable lease option.

Kimley»>Horn
Page 4
EPA Recommendation: Fbr impacts associated with preferred alternative 3B, specifically Ste 9,
the EPA recommendsspanning the stream/wetland/and/or providing bottomless box culverts
across the floodplain of the UT to Fbedy Branch to prevent undue impacts to the stream's
geomorphology and floodplain access function.
NGDOT/Novo Nordisk Fbsponse: In order to construct a bottomless box culvert at the crossing of the
UTto Fbedy Branch, bedrock would need to be located within 2 -feet of the ground surface. In this
coastal plain physiographic region, bedrock is not looted with 2 -feet and construction would require
piles be driven for the bottomless box culvert construction, which isnot a practical option. Bridging
the stream/floodplain area would add an estimated $400, 000 to $500, 000 to the Gordon Fbad
access construction cost which is not practical for 1881f of stream impact. There is currently a 48"
reinforced concrete pipe (FXV underneath Gordon Fbad at the existing stream crossing. NCDOT
proposes to utilize a 54" RCP for the proposed crossing and will bury the pipe at least 12"below the
bed of the stream to maintain aquatic passage, stream geomorphology, and floodplain access
Cbnstruction of the culvert will also follow NCDOTBMPand NCDWRrequirements
EPA Recommendation: Fbgarding impacts to isolated wetland (WG), EPA recommends that the
applicant confer with the NCDWRand consider providing compensatory mitigation at a 1:1 ratio
(2.18 acres or Wetland Mitigation Units) from a suitable mitigation bank or the NCDMS
Novo Nordisk Fb�ponse: As included in the application submittal, based upon the NC Wetland
Assessment Method (NGWAM), basin wetland WG scored a "High" rating due to the overall size and
minimal disturbance to the wetland interior. As such a 1:1 mitigation ratio is proposed for this 2.18
acre impact. Snoe the isolated wetland does not connect to any offsite waters non -riparian wetland
credits will be utilized for mitigation of wetland WG impacts Mitigation credits will be purchased by
Novo Nordisk from FL -source Environmental Solutions, LLC(FE!� banks that are active in the Neuse
Fiver Basin (HUC03020201). Due to the credit need for this project, and the expected timeline for
permit review, FTShas provided documentation that based on anticipated credit release schedules
on the active banks in the watershed, they expect to be able to provide the required mitigation
credits If the proposed credit release schedule changes and the required credits are not available at
the time of project construction, Novo Nordisk will secure mitigation for the proposed impacts by
payment into the NCDMSILFprogram. NCDMShas accepted Novo Nordisk's request for in4ieu fee
payment for up to 10 acres of wetland mitigation credits

Kimley»>Horn
If there is any additional information you need in response tothe Public Notice or to assist in the
processing of this Individual Section 404 Permit Application, please do not hesitate to contact meat
919-677-2073 or Beth.F;[e-mail].
Sncerely,
Kimley-Horn and Associates, Inc.
Beth Feed, PWS
cc: Jean Gi bby, USACE
Jennifer Burdette, NCDEQ- DWR
Gary Lohr, Novo Nordisk
Timothy Little, NCDOT
David Bendan, Ruor

Minutes
Meeting: NNPII DAPI US Neighborhood Meeting
Date of meeting: 09Feb2016 at 1800
Participants: Town of Clayton, Fluor, Kimley-Horn, NNPII DAPI US, Johnston Co. Sheriff's Dept.,
Neighborhood residents (See attached Attendance Roster)
Excused: Justin Lamb, Chris Johnson, et al.
Meeting organiser: Gary Lohr
Note Taker: Beth Reed/Jessica Gadbois
Copy: Town of Clayton
Topic/Action
Responsible
Deadline
Meeting commenced at 18:14 with Gary Lohr
Gary Lohr
N/A
• Introduced self & DAPI US Project
• Introduced groups present:
o Kimley-Horn
o Town of Clayton
o Johnston County
o NC -DOT
o Fluor
o Jo Co Sheriff's Department
o Neighbors of NNPII DAPI US Project
PowerPoint utlized by Gary Lohr to present & discuss DAPI US
Gary Lohr
N/A
Expansion Project
• Agenda included:
o Welcome
o Safety & Practicalities
o Novo Nordisk overview
• Origin of Novo Nordisk as a company
• Product lines
• Introduced GLP1-0ral Protien potential
■ Worldwide Pandemic of Diabetes
• Supply vs Demand
• Need for additional insulin production
o See Q & A section: #1
o Novo Nordisk in Clayton
■ History/Development of existing facility
• Expansions to meet continued supply & demand
• 2014 Expansion utilized remaining Novo Nordisk
property W. of Powhatan Rd.
• Novo's commitment to their Triple Bottom
Line:
• Financial, Social & Environmental responsibility:
Focus on Social & Environmental
**Continued on page 2**
Page 1 of 2

Topic/Action
Responsible
Deadline
o DAPI Expansion
• Novo's commitment to job site & community
■ Social Responsibility: Giving back to the
community
• Job creation
• Environmental Aspirations
• LEED
• Minimize wetland impact
• Waste strategies
• Water usage
• Heat Recovery
• Minimze Waste
■ Rational for Expansion:
• Site Clayton: sq. Footage, acreage & project cost
• Meet increased demands on insulin supply due to
rapid increase in worldwide Diabetes patients
• Diversify products & production locations
o Project Execution
• Gary Lohr hands Execution portion of presentation
over to Bailey Forrest, Site Manager - Fluor
Engineering at 18:27
o Project Execution/ Logistics
Bailey Forrest
N/A
■ Introduced self, excitement for project & Novo
Nordisk as a client
• Fluor Philosophy: contain activity within site
■ Site Layout
• Construction Schedule & duration
• Phase 1 & Phase 2
• Measures taken to minimize Wetland Impact
• Gordon Road
• Reviewed Map of Gordon Rd.
o Access location & needs
o Note: This opened Q & A's #2. - 8
• Closing: Gary Lohr closed meeting 18:46
Gary
N/A
o Provided contact information
Lohr/Bailey
o Shared gratitude for attendance & project support
Forrest
o Proposed ideas for Social/Environmental responsibility
• Community Garden for educational purposes as well
as potential donations to local food banks
• Bailey Forrest closed with "Being a good neighbor, we are
here to stay & be good neighbors"
Questions & Answers
Question #1: Neighborhood resident: What is attributing to the rise in
Gary Lohr
N/A
Diabetes worldwide?
Answer: Gary Lohr: A number of attributing factors such as
environmental, genetics, diet, obesity as well as early/accurate detection
have influenced the increase in Diabetic patients globally.
Question #2: Multiple residents: Requested a closer look at Gordon
Tim Little
N/A
Road via the map on the Presentation screen and what the
impact/improvements will be on the Road.
Answer: Tim Little with NCDOT responded on the street
improvements: The intersection improvements at US 70/Gordon Road will
be required including signalization and US 70/Powhatan Road intersection
improvements will also be required based upon the results of the Traffic
Study prepared by Kimle -Horn and Associates.
Page 2 of 3

Topic/Action
Responsible
Deadline
Question #3: Neighborhood resident: Is the property line, beyond the
Bailey Forrest
N/A
track, anywhere near Entrance?
Answer: Bailey Forrest: Spoke of the Security House,
laydown/construction then proceeded to show the resident on the
Presentation slide Map.
Question #4: Neighborhood resident: How far does the road & bridge
Bailey
N/A
come up from US Hwy 70?
Forrest, Gary
Answer: Norwood Thompson responded the road would go through a
Lohr & Tim
southern field not across from Edenborough.
Little
Answer: Bailey Forrest zoomed in on the Presentation Map to show Bridge
across the Rail Road.
Answer: Gary Lohr spoke on the importance of taking traffic away from
the neighborhood.
Answer: Tim Little spoke on the traffic, Street/Road improvements on
Edenborough, Gordon & Bus 70.
Question #5: Neighborhood resident inquired about Gate C
Bailey Forrest
N/A
Answer: Bailey Forrest explained this was temporary for staging
Question #6: Neighborhood resident: Are you widening Gordon Road?
Tim Little
N/A
Answer: Tim Little: There will be minimal widening required from Gordon
Road Access tie in to Gordon Road back to the Gordon Road/US 70
Intersection; 2 feet wide on shoulders for Trucks traffic.
Question #7: Allen Wellons: How many employed by Construction
Bailey Forrest
N/A
Craft?
Answer: Bailey Forrest : 1600-1800 Construction Craft for 2018, they
will have split access to the site.
(Allen replied he liked the numbers of employment)
Question #8: Neighborhood resident: Do you anticipate more land
Gary Lohr
N/A
acquisition for future projects?
Answer: Gary Lohr: No additional acquisitions are proposed and if future
expansion occurs outside the Phase 1 and 2 plans, it would be located to
avoid wetland areas and potentially in the upland area within the existing
property adjacent to the Powhatan/Glen Laurel Road intersection.
➢ End of Meeting Minutes/Q&A
Page 2 of 3

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