20160361 Ver 1_Application_20160413

CAROLINA
WETLAND SERVICES
Carolina Wetland Services, Inc.
550 East Westinghouse Boulevard
Charlotte, NC 28273
704-527-1177 - Phone
704-527-1133 - Fax
TO: Ms. Karen Higgins
NCDWR — NC DWR, 401 & Buffer Permitting Unit
512 N. Salisbury St
9th Floor, Archdale Building
Raleigh NC 27604
Date: 4/12/2016
CWS Project #: 2016-3867
LETTER OF TRANSMITTAL
20160361
WE ARE SENDING YOU: ®Attached ❑Under separate cover via the
N Prints
❑ Copy of letter
IF
1
D
Ark 1 32016 !
❑ Plans ❑ JD Package ❑ Specifications
❑ Change order ❑ Wetland Survey N Other
)SURES ARE NOT AS NOTED, KINDLY NOTIFY US AT ONCE
1 4/12/2016 1 4 1 Application for WQC 3896
L 2 14/12/2016 I 1 I Application Fee ($570)
THESE ARE TRANSMITTED as checked below:
NFor approval ❑Approved as submitted ❑Resubmit copies for approval
NFor your use ❑Approved as noted ❑Submit copies for distribution
❑As requested ❑Returned for corrections ❑Return corrected prints
❑For review and comment ❑For your verification and signature
REMARKS: Karen, Please find attached four copies of the Pre -Construction Notification and application for
WOC 3896 for the Yale Security — Norton Site project. A check for the application fee of $570 is also attached
Copy to: File
Thank you,
Z71- e. .
�A���
Gregg Antemann, PWS
Principal Scientist
NORTH CAROLINA • SOUTH CAROLINA

Preliminary ORM Data Entry Fields for New Actions
SAW — 201 - BEGIN DATE [Received Date]:
Prepare file folder ❑ Assign Action ID Number in ORM
1. Project Name [PCN Form A2a]: Yale Security - Norton Site
2. Work Type: Private ❑✓ Institutional 11 Government F] Commercial
3. Project Description / Purpose [PCN Form 133d and 63e]:
The purpose of this project is to restore a stream through removal of existing polychlorinated
biphenyl (PCB) contaminated soils from the bed and banks of the stream.
4. Property Owner/ Applicant [PCN Form A3 or A4]:
Yale Security -Norton Site; POC: Mr. Barry Giroux
5. Agent/ Consultant [PCN Form A5 —or ORM Consultant ID Number]: CWS; POC: Mr. Gregg Antemann, PWS
6. Related Action ID Number(s) [PCN Form B5b]:
7. Project Location - Coordinates, Street Address, and/or Location Description [PCN Form 131b]:
3000 East Old Highway 74, Monroe, North Carolina
8. Project Location -Tax Parcel ID [PCN Form 131a]: 090870
9. Project Location — County [PCN Form A2b]: Union
10. Project Location — Nearest Municipality or Town [PCN Form A2c]: Monroe
11. Project Information — Nearest Waterbody [PCN Form 132a]: UT t0 Rays Fork
12. Watershed / 8 -Digit Hydrologic Unit Code [PCN Form 62c]: Yadkin (HUC 03040105)
Authorization: Section 10 F1 Section 404
Regulatory Action Type:
Standard Permit
✓ Nationwide Permit # 38
Regional General Permit #
✓� Jurisdictional Determination Request
❑✓ Section 10 & 404
Pre -Application Request
Unauthorized Activity
Compliance
No Permit Required
Revised 20150602

CAROLINA WETLAND SERVICES, INC.
550 E. Westinghouse Blvd.
Charlotte, NC 28273
704-527-1177 1(office)
704-527-1133I(fax)
April 12, 2016
Mr. William Elliott
U.S. Army Corps of Engineers
151 Patton Avenue, Room 208
Asheville, NC, 28801
Ms. Karen Higgins
NCDEQ, 401 & Buffer Permitting Unit
512 N. Salisbury Street, 91 Floor
Raleigh, NC 27604
Subject: Request for Preliminary Jurisdictional Determination and Pre -Construction
Notification Pursuant to Nationwide Permit No. 38
Yale Security — Norton Site
Monroe, North Carolina
Carolina Wetland Services Project No. 2016-3867
Dear Mr. Elliott and Ms. Higgins,
The Yale Security —Norton Site is 16 acres in extent and is located at 3000 East Old Highway 74 in
Monroe, North Carolina (Figure 1, attached). The purpose of this project is to remediate a stream
through removal of existing polychlorinated biphenyl (PCB) contaminated soils from the bed and banks
of the stream. On behalf of Yale Security Inc., GEI Consultants Inc. has sub -contracted Carolina
Wetland Services, Inc. (CWS) to provide Section 404/401 permitting services for this project. An
executed Agent Authorization Form is attached.
Applicant Name: Yale Security Inc.; POC: Mr. Barry Giroux
Mailing Address: 455 Winding Brook Drive, Suite 201, Glastonbury, CT 06033
Phone Number of Owner/Applicant: 860-368-5340
Street Address of Project: 3000 East Old Highway 74, Monroe, NC
Waterway: UT to Rays Fork
Basin: Yadkin (HUC' 03040105)
City: Monroe
County: Union
Tax Parcel ID number: 090870
Decimal Degree Coordinate Location of Project Site: 34.977402°, -80.48604°
USGS Quadrangle Name: Wingate, NC (1991)
Current Land Use
The site is approximately 16 acres in extent and consists of a manufacturing business with associated
paved parking lots, maintained lawns, and forested areas in the southern portion of the project limits
(Figure 2, attached). Typical on-site vegetation includes red maple (Acer rubrum), white oak (Quercus
alba), eastern red cedar (Juniperus virginiana), green ash (Fraxinus pennsylvanica), sweetgum
(Liquidambar styraciflua), poison ivy (Toxicodendron radicans), spleenwort (Asplenium platyneuron),
"HUC" is the Hydrologic Unit Code U S Geological Survey, 1974 Hydrologic Unit Map, State of North Carolina
NORTH CAROLINA ' SOUTH CAROLINA
WWW.CWS-INC.NET

Yale Security — Norton Site April l2, 2016
Request for PJD and PCN Notification to NWP No. 38 and WOC 3896 CWS Project No. 2016-3867
greenbrier (Smilax rotundifolia), sawtooth blackberry (Rubus argutus), Chinese privet (Ligustrum
sinense), and Japanese honeysuckle (Lonicera japonica).
According to the Soil Survey of Union County' (Figures 3 and 4, attached), on-site soils consist of Badin-
Urban land complex, 2-8 percent slopes (BuB), Cid channery silt loam, 1-5 percent slopes (CmB), and
Tarrus gravelly silty clay loam, 2-8 percent slopes, moderately eroded (TbB2). None of the on-site soils
are listed on the North Carolina Hydric Soils List for Union County3 nor are they listed on the National
Hydric Soils List' as having hydric inclusions (Hydric Criteria 2133).
National Wetland Inventory
Wetlands are an important source of biodiversity and provide a multitude of ecological services. The
National Wetlands Inventory (NWI), created by the U.S. Fish and Wildlife Service,' is a program which
provides wetlands data and analysis available to the public. Review of the NWI GIS layer does not
depict any NWI registered wetlands within the project limits (Figure 5, attached).
Jurisdictional Delineation
On February 18, 2016, CWS scientists Kelly Thames, Professional Wetland Scientist (PWS), and Kaitlin
McCulloch, Staff Scientist I, delineated jurisdictional waters of the U.S. within the project area (Figure 6,
attached). Jurisdictional areas were delineated (flagged in the field), classified, and surveyed with a sub -foot
Trimble Geo7X GPS unit using the United States Army Corps of Engineers (USACE) Routine On -Site
Determination Method. This method is defined in the 1987 Corps of Engineers Wetlands Delineation
Manual', the 2007 USACE Jurisdictional Determination Form Instructional Guidebook', with further technical
guidance from the 2012 Eastern Mountains & Piedmont Regional Supplement.$ A Wetland Determination
Data Form representative of on-site jurisdictional wetlands is attached as DPI. A Wetland Determination Data
Form representative of non jurisdictional upland areas is attached as DP2.
Jurisdictional stream channels were classified according to recent North Carolina Department of
Environmental Quality (NCDEQ) guidance. These classifications include sampling with a D -shaped dip net;
photograph documentation, and defining approximate breakpoints (location at which a channel changes
classification) within each on-site stream channel. A NCDEQ Stream Classification Form representative of
Stream A is attached as SCP I. Locations of the Stream Classification Point and the Wetland Determination
Data Forms are depicted on Figure 6 (attached).
Results
The results of the on-site field investigation conducted by CWS indicate that there is one jurisdictional
stream channel (Stream A) and one jurisdictional wetland area (Wetland AA) located within the project area
(Figure 6, attached). On -Site jurisdictional waters of the U.S. include an unnamed tributary (UT) to Rays
Fork. Rays Fork is part of the Yadkin River Basin (HUC 03040105) and is classified as "Class C Waters"
z United States Department of Agriculture, 2014 Soil Survey of Union County, North Carolina
3 United States Department of Agriculture — Natural Resources Conservation Service, 1999 North Carolina Hydric Soils List, USDA-NRCS
North Carolina State Office, Raleigh
United States Department of Agriculture — Natural Resources Conservation Service, 2012 2012 National Hydric Sods List by State
5 National Wetlands Inventory 2014 U S Fish and Wildlife Service Accessible at http //www fws gov/wetlands/
6 Environmental Laboratory 1987 "Corps of Engineers Wetlands Delineation Manual", Technical Report Y-87-1, US Army Engineer
Waterways Experiment Station, Vicksburg, Mississippi
USACE Jurisdictional Determination Form Instructional Guidebook 2007 USACE Regulatory National Standard Operating Procedures for
conducting an approved Jurisdictional determination (JD) and documenting practices to support an approved JD USACE Headquarters,
Washington, DC
8 US Army Corps of Engineers, April 2012 Regional Supplement to the Corps of Engineers Wetland Delineation Manual Eastern Mountains
and Piedmont Region US Army Engineer Research and Development Center, Vicksburg, Mississippi
2

Yale Security — Norton Site April 12, 2016
Request for PJD and PCN Notification to NWP No. 38 and WOC 3896 CWS Proiect No. 2016-3867
by the NCDEQ. According to the NCDEQ, Class C Waters are defined as: "Waters protected for uses
such as secondary recreation, fishing, wildlife, fish consumption, aquatic life including propagation,
survival and maintenance of biological integrity, and agriculture."9
On -Site jurisdictional waters of the U.S. total approximately 0.07 acre, including 658 linear feet (If) of
jurisdictional stream channel. On -Site jurisdictional waters of the U.S. are summarized in Table 1, next page.
Table 1. Summary of on-site jurisdictional waters of the U.S.
Seasonal Relatively Permanent Waters" (RPWs
Seasonal RPWs are those that exhibit continuous flow for at least three consecutive months per year on a
seasonal basis. This flow regime is the result of a lowering of the water table during dry periods that
prevents groundwater discharge to the stream channel. Seasonal streams do not typically support aquatic
life requiring year-round flow necessary for reproductive and maturation stages.
The results of the on-site field investigation conducted by CWS indicate that there is one seasonal RPW with
intermittent flow located within the project area (Stream A). Stream A originates offsite at the western
boundary of the project limits and flows east for approximately 658 linear feet before continuing off site
(Figure 6, attached). Stream A (R4SB312) exhibits strong natural valley, moderate continuity of channel bed
9 NCDEQ "Surface Water Classifications " http //portal ncdenr org/web/wq/ps/csu/classifications
10 Classifications of streams include Traditionally Navigable Waters (TNWs), Relatively Permanent Waters (RPWs), and Non -Relatively
Permanent Waters (Non-RPWs) Subcategories of RPWs Include perennial streams that typically have year-round flow, and seasonal streams
that have continuous flow at least seasonally Two classifications of Jurisdictional wetlands are used to describe proximity and connection to
TNWs These classifications Include either adjacent of directly abutting Adjacent wetlands are defined as wetlands within floodplains or In
close proximity to a TNW but without a direct visible connection Abutting wetlands have a direct surface water connection traceable to a
TNW
"U.S Army Corps of Engineers Jurisdictional Determination Form Instructional Guidebook May 5, 2007 US Army Corps of Engineers and
the Environmental Protection Agency
http //www usace army miVPortals/2/docs/crvllworks/regulatory/cwa_guide/Jd guidebook _051207final pdf
12 R4SB3 = Intermittent stream with streambed with cobble -gravel bottom, Cowardln et al Classification System, 1979
Jurisdiction
Stream
NCDEQ
Jurisdictional
Stream
Linear Feet
Acreage
Stream
USACE/EPA
Intermittent/
Classification
Classification
(If)
(ac.)
Rapanos
Perennial
(SCP)
Score
Classification"
Stream A
Seasonal RPW
Intermittent
SCP1
25.5
658
0.05
Stream Total:
658 If
0.05
Jurisdiction
Jurisdictional
Linear Feet
Acreage
Wetland
USACE/EPA Rapanos
Data Point
(If)
(ac.)
Classification
Wetland AA
Adjacent to RPW
DPI
N/A
0.02
Wetland Total:
N/A
0.02
Total:
6581f
0.07
Seasonal Relatively Permanent Waters" (RPWs
Seasonal RPWs are those that exhibit continuous flow for at least three consecutive months per year on a
seasonal basis. This flow regime is the result of a lowering of the water table during dry periods that
prevents groundwater discharge to the stream channel. Seasonal streams do not typically support aquatic
life requiring year-round flow necessary for reproductive and maturation stages.
The results of the on-site field investigation conducted by CWS indicate that there is one seasonal RPW with
intermittent flow located within the project area (Stream A). Stream A originates offsite at the western
boundary of the project limits and flows east for approximately 658 linear feet before continuing off site
(Figure 6, attached). Stream A (R4SB312) exhibits strong natural valley, moderate continuity of channel bed
9 NCDEQ "Surface Water Classifications " http //portal ncdenr org/web/wq/ps/csu/classifications
10 Classifications of streams include Traditionally Navigable Waters (TNWs), Relatively Permanent Waters (RPWs), and Non -Relatively
Permanent Waters (Non-RPWs) Subcategories of RPWs Include perennial streams that typically have year-round flow, and seasonal streams
that have continuous flow at least seasonally Two classifications of Jurisdictional wetlands are used to describe proximity and connection to
TNWs These classifications Include either adjacent of directly abutting Adjacent wetlands are defined as wetlands within floodplains or In
close proximity to a TNW but without a direct visible connection Abutting wetlands have a direct surface water connection traceable to a
TNW
"U.S Army Corps of Engineers Jurisdictional Determination Form Instructional Guidebook May 5, 2007 US Army Corps of Engineers and
the Environmental Protection Agency
http //www usace army miVPortals/2/docs/crvllworks/regulatory/cwa_guide/Jd guidebook _051207final pdf
12 R4SB3 = Intermittent stream with streambed with cobble -gravel bottom, Cowardln et al Classification System, 1979

Yale Security — Norton Site April 12, 2016
Request for PJD and PCN Notification to NWP No. 38 and WOC 3896 CWS Project No. 2016-3867
and bank, moderate in -channel structure, moderate grade control, moderate sediment on plants or debris, and
moderate evidence of organic debris lines or piles. Biological sampling revealed a weak presence of fibrous
roots in the streambed and weak evidence of crayfish. Stream A scored 25.5 out of a possible 63 points on the
NCDWR Stream Classification Form, indicating intermittent status (SCP1, attached). A photograph
representative of Seasonal RPW Stream A is attached (Figure 6; Photograph A, attached).
Wetlands
The USACE and the Environmental Protection Agency (EPA) define wetlands as: "Those areas that are
inundated or saturated by surface or groundwater at a frequency and duration sufficient to support, and that
under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil
conditions."13 The USACE uses three parameters to identify jurisdictional wetlands. These parameters are as
follows: 1) hydrophytic vegetation, 2) wetland hydrology, and 3) hydric soils. Except in certain atypical
situations, all three parameters must be present in order for an area to be determined to be a jurisdictional
wetland. This section describes each on-site jurisdictional wetland and the field observations that led to their
determinations.
Wetland AA is approximately 0.02 acre in extent and is located adjacent to Seasonal RPW Stream A. Wetland
AA is classified as a forested wetland (PFOI ") that exhibits low chroma soils (7.5YR 3/2), surface water up to
two feet, saturation to the surface, high water table, water marks on trees, water -stained leaves, aquatic fauna,
and moss trim lines. Dominant vegetation for Wetland AA includes red maple, green ash, sweetgum,
greenbrier, and various sedges (Carex spp.). Figure 6 (attached) depicts the location of this wetland and the
corresponding Wetland Determination Data Form (DPI, attached). Photograph B (attached) is representative
of Wetland AA.
Agency Correspondence
Cultural Resources
CWS consulted the North Carolina State Preservation Office (SHPO) online GIS service15 and found no
sites of architectural, historical, or archaeological significance within the project limits. In addition,
CWS consulted the National Register of Historic Places for Union County16 and found no properties
adjacent to, or within the project limits.
Protected Species
CWS performed a data review using North Carolina Natural Heritage Program (NCNHP) Data Explorer"
on February 24, 2016 to determine the presence of any federally -listed, candidate endangered, threatened
species, or critical habitat located within the project area. Based on this review, there are no records of
federally -protected species within the project limits. A copy of the data review report is attached.
Purpose and Need for the Project
The Yale Security - Norton Site (hereinafter "Site") was developed for its current use in 1956. Since the
initial construction in 1956 the building has been expanded twice towards the rear of the property. In
order for the expansions to occur, fill was necessary to grade out a large flat area to handle the necessary
"Environmental Laboratory 1987 "Corps of Engineers Wetlands Delineation Manual", Technical Report Y-87-1, US Army Engineer
Waterways Experiment Station, Vicksburg, Mississippi
14 PFOI = Forested wetland with broad-leaved deciduous vegetation, Cowardin et al Classification System, 1979
15 North Carolina State Historic Preservation Office, http //gis ncdcr gov/hpoweb/ Accessed February 24, 2016
16 National Register of Historic Places for Union County http //www nationalregisterofhistoncplaces com/nc/union/state html
17 North Carolina Natural Heritage Data Explorer, https //ncnhde natureserve org/, Accessed February 24, 2016

Yale Security — Norton Site April 12, 2016
Request for PJD and PCN Notification to NWP No. 38 and WOC 3896 CWS Project No. 2016-3867
growth for the building and attendant structures (Figure 7, attached). No impacts to jurisdiction waters
of the U.S. occurred during this time.
Since the expansions and subsequent fill material was brought in to the Site, elevated concentrations of
PCBs, lead, cadmium, and volatile organic compounds (VOCs) have been detected in the fill soil. The
source of the PCBs in the soil is not known, but Yale Security believes that PCBs and other constituents
were likely present in the fill material that was used. The placement of off-site materials in the fill area is
believed to have stopped in 1972 when expansions were no longer needed. No reported releases of PCBs
at the Site have been detected, and the distribution of the PCBs in the soil is relatively widespread across
the rear of the Site where the fill occurred. The fill of contaminated soil clearly occurred before the
initiation of what is now the standard practice of screening and sampling the proposed fill material before
placement on a site.
Due to the contaminated fill soils, PCBs were identified in the surface soil (bed and banks) of Seasonal
RPW Stream A located in the southern portion of the property (Figures 7 and 8, attached). Given that the
PCBs were detected across most of the rear of the Site (as opposed to in discrete locations), it is possible
that when the fill material was brought onto the rear of the Site, it may have seeped into the area where
Stream A is located. Elevated concentrations of lead, cadmium and VOCs have not been detected in the
channel soil.
The Site is being investigated and remediated under the North Carolina Department of Environmental
Quality (NCDEQ), Inactive Hazardous Site Branch's (IHSB) Registered Environmental Consultant
(REC) program in accordance with the terms of an Administrative Agreement with the IHSB established
in August 2008 (Docket Number 08 -SF -243). Remedial actions conducted under the REC Program are
governed by the Inactive Hazardous Sites Response Act and the REC Program Rules found at 15A
NCAC 13C.0300.
Proposed and necessary remedial actions include a soil cap and the excavation of the contaminated soils
in the bed and banks of Stream A down to soils exhibiting one or less milligram per kilogram (< 1mg/kg)
of PCBs. Contaminated soils will be removed to a permitted off-site disposal facility. Clean fill will be
used to backfill the excavated area and Stream A will be restored to its pre-existing geomorphological
condition utilizing Rosgen Stream Classification and natural channel design techniques discussed in the
Stream Restoration section of this application.
Avoidance and Minimization
All impacts to on-site jurisdictional waters of the U.S. are temporary, but unavoidable. Proper sediment and
erosion control measures will be used to minimize disturbances to downstream waters. Construction
activities and impacts to on-site jurisdictional waters of the U.S. will comply with all conditions of
Nationwide Permit No. 33 and Water Quality Certification No. 3896. All work will be constructed in the
dry. No permanent impacts to Seasonal RPW Stream A are proposed. Of the 658 linear feet of channel
within the project limits, 560 linear feet will restored linear foot for linear foot. No impacts to
jurisdictional wetlands are proposed.
In an attempt to avoid impacts to jurisdictional waters while still meeting the goals of the project, a "No
Impact" alternative was considered. Due to requirements of the REC program, remedial actions are required
to remove the contaminated soils. Therefore, temporary impacts to Seasonal RPW Stream A are
unavoidable.

Yale Security — Norton Site April 12, 2016
Request for PJD and PCN Notification to NWP No. 38 and WOC 3896 CWS Project No. 2016-3867
The currently proposed restoration plan was developed as a result of site investigation and remedial actions
under the REC program. We believe that Stream A will not only be benefited by the removal of contaminated
soils, but will display an uplift in ecological function through the use of Rosgen Stream Classification and
natural channel design techniques.
The left bank of Stream A will be cleared as the required soil cap will be installed. The majority of the left
bank will be seeded only. As the right bank of Stream A consists of a forested area with many large trees,
minimal and selective clearing is proposed within the first 25 foot buffer of the right bank. Invasive species
control is proposed throughout the 50 -foot buffer.
Proposed Impacts to Jurisdictional Waters
Under Nationwide Permit (NWP) No. 38, unavoidable temporary impacts to jurisdictional waters
associated with this project are limited to a total of 560 linear feet (if) of jurisdictional stream channel
(Stream A [Figure 8, attached]). Temporary impacts will consist of the excavation of the bed and banks
of Seasonal RPW Stream A until in-situ soils exhibit a one or less milligram per kilogram (< 1 mg/kg)
PCB concentration. When the required level is met, clean backfill will be placed in the excavated area
and restored to the proposed geomorphological condition described in the Stream Restoration section.
No permanent impacts are proposed. Proposed impacts are summarized in Table 2 (below).
Table 2. Proposed impacts to.jurisdictional waters of the U.S.
Jurisdictional
Impact
Temporary
Impacts
Feature
Type
or
(linear feet)
Impacts (acre)
Permanent
Stream A
Remediation
Temporary
560
0.04
Total Temporary Stream Impacts
5601f
0.04 acre
Stream Restoration Plan
Existing Conditions Analysis
A geomorphic survey was performed by CWS scientists Kelly Thames, Professional Wetland Scientist
(PWS) and Kaitlin McCulloch, Staff Scientist I on February 29, 2016 of a reference reach located along
Stream A (Figure 9, attached). Rosgen Stream Classification Level 11" was the methodology utilized.
This assessment included a longitudinal profile and representative cross sections of the existing stream
channel (Figures 10 — 12, attached) and a Wolman Pebble Count19 at the riffle cross section (Figure 13,
attached). The stream restoration plan proposes for Stream A to be reconstructed linear foot for linear
foot back to existing conditions. As the only impacts associated with this project are temporary, this plan
will not create permanent impacts to Stream A. The assessment utilized a survey grade Total Station,
following U.S. Forest Service methods.20
18 Rosgen, D L. Applied River Morphology 2nd ed Pagosa Springs, CO Wildland Hydrology, 1996 Print
19 Rosgen, D L Applied River Morphology 2"d ed Pagosa Springs, CO Wildland Hydrology, 1996 Print
20 Harrelson, C C, Rawlins, C L, and J P Potyondy 1994 Stream Channel Reference Sites An Illustrated Guide to Field Techniques USDA
Forest Service General Technical Report RM -245, Fort Collins, CO

Yale Security — Norton Site April 12, 2016
Request for PJD and PCN Notification to NWP No. 38 and WOC 3896 CWS Project No. 2016-3867
Geomorphological Description
An upper portion of Stream A exhibits stable characteristics, low banks, and was determined a good
reference reach to survey for the restoration design (Figure 9, attached). A longitudinal profile and a
cross sectional survey were conducted on a representative riffle and a representative pool feature (Figures
10 — 11, attached). The average drainage area for Stream A is approximately 0.082 square miles (52.48'
acres), channel slope averages 0.022 ft/ft, and sinuosity is 1.02 ft/ft. Bankfull width and mean depth for
this reach are 3.40 feet and 0.85 feet, respectively, with a bankfull area of 2.88 sq. ft. and width/depth
ratio of 4.02. The flood prone width for this reach is 10 feet and greater. Rosgen Stream Classification
practice dictates that a longitudinal profile of 20 times bankfull width is the necessary length to survey
for an adequate existing conditions analysis. As bankfull width is 3.40 feet, the necessary length of
stream to survey was 68 linear feet, however CWS surveyed 190 linear feet of longitudinal profile.
Additionally, the entirety of Stream A was assessed for potential longitudinal profile data collection and
the portion as depicted in Figure 9 is the most representative and stable section to reference for the
design. Application of Rosgen Level 11 Stream Classification to a representative riffle section identified
Stream A as an E type channel (Table 3, next page).
Channel Bed Material -
The composition of the streambed and banks'is an important factor of stream character and is ultimately
part of classifying the stream per Rosgen Classification methodology. A Wolman Pebble Count was
performed at the representative riffle cross section (Figure 13, attached). The Wolman Pebble Count
classified at least 50 percent of the substrate of Stream A as coarse sand (D50 = 1.0 mm). The Wolman
Pebble Count, along with the geomorphologic conditions described above, classified the stream as an E
type stream. , - r
Existing Riparian Vegetation
The adjacent riparian area is undeveloped, forested land. The site is surrounded by the manufacturing
operation to the north and a maintained field to the south (Figure 2, attached). Typical riparian
vegetation consists largely of loblolly pine (Pinus taeda) and Chinese privet (Ligustrum sinense), but
also includes sweetgum (Liquidambar styraciflua), red maple (Acer rubrum), flowering dogwood
(Cornus florida), eastern red cedar (Juniperus virginiana), Japanese honeysuckle (Lonicera japonica),
and greenbrier (Smilax rotundifolia).
Stream Restoration Plan
CWS developed a stream design for the restoration of Stream A based on existing channel conditions
(Figure 14, attached). This design will improve the goals of the project and enhance future water quality
by increasing the quality of epifaunal substrate, and enhancing the buffer with native riparian plantings.
Typical cross sectional dimensions for the restoration will be based on the existing cross sectional
dimensions (Figure 15, attached). A longitudinal profile was developed for the restoration to tie into the
existing channel upstream and downstream of the proposed excavation (Figure 16, attached).

Yale Security — Norton Site April 12, 2016
Request for PJD and PCN Notification to NWP No. 38 and WQC 3896 CWS Project No. 2016-3867
Table 3. Summary of existing and design stream conditions
Parameter
Existing
ProposedProposed
Riffle I
Pool
Length of Evaluated (ft.)
190
560
Channel Dimensions
Bankfull Width (ft)
3.40
4
4.5
Mean Bankfull Depth (ft.)
0.85
0.82
1.07
Width/Depth Ratio
4.02
4.86
4.28
Bankf ill Area, (sq. ft.)
2.88
3.29
4.94
Bankfull Maximum Depth (ft.)
1.12
1.11
1.10
Width Floodprone Area (ft.)
>10
>10
>10
Entrenchment Ratio
6.15
3.43
2.50
Channel Pattern
Sinuosity
1.02
1.02
Channel Profile
Channel Slope
0.022
0.022
Rosgen Stream Type
E
E
A pump around will be utilized in order to work in the dry and other erosion and sediment control
techniques will be utilized to minimize sediment escape from the site during construction. These
techniques include employing coir fiber logs within the channel bed immediately downstream of the
construction area. These logs are meant to temporarily prevent downstream sediment migration and will
be removed once the channel has been stabilized with matting.
The restored channel reach is designed to have similar profile and dimension to the reference reach. The
restored stream will have similar channel stability and dimensions to the reference condition, as well as
provide an uplift of aquatic function by providing a higher quality riparian buffer through planting native
plants and controlling invasive plant species. The improvements to the restored stream are designed to
minimize erosion, downstream sediment accumulation, and downstream scouring by redirecting flow and
reducing sheer stress.
Planting Plan
As the remediation plan includes a soil cap to be placed on the slope of the left bank of Stream A, a 50 -
foot buffer cannot be planted with woody species. Only a native seed mix will be used to revegetate the
slopes on the left bank. Natural coconut matting (coir matting) and native seed mix will be installed on
both banks of Stream A once construction is complete. Live stakes will only be installed on the stream
banks and bankfull bench of the left bank of Stream A. Live stakes and native plants will be installed on
the right bank of Stream A in various zones for bank stabilization and erosion control. Vegetation
species will be chosen based on the existing plant community and to add species diversity, particularly in
the riparian zone (Figure 14, attached).
The area of disturbance for the stream restoration consists of five zones: 1) stream banks, 2) bankfull
bench, 3) riparian buffer to plant, 4) riparian buffer to control invasive plants, and 5) riparian buffer to
seed only (Figure 14, attached). Revegetation of the area directly adjacent to the restored channel is

Yale Security — Norton Site April 12, 2016
Request for PJD and PCN Notification to NWP No. 38 and WOC 3896 CWS Project No. 2016-3867
especially important to prevent erosion, downstream sedimentation, and provides important water quality
and habitat services. Hydrophytic plant species such as silky dogwood (Cornus amomum), black willow
(Salix nigra), elderberry (Sambucus canadensis), and soft rush (Juncus effusus) will be planted on the
lower stream banks (Zone 1, approximately 2,250 square feet [sfJ). The bankfull bench (Zone 2,
approximately 2,817 sf) will be planted with other moisture -tolerant species such as river birch (Betula
nigra), green ash and red maple. The riparian buffer to plant is only on the right of Stream A (Zone 3,
approximately 16.450 sf) and will be planted with species such as ironwood, slippery elm, and spicebush
(Lindera benzoin). The riparian buffer to control invasive species (Zone 4, approximately 15,575 sf) will
be preserved from disturbance and will have invasive species treated. The riparian buffer seeding only
(Zone 5, approximately 29,469 sf) will be seeded with a native seed mix only as the required soil cap
prevents the planting of woody species. All disturbed areas will be seeded with temporary and
permanent native riparian seed mixes, and stream banks will be matted with natural coconut matting.
Planting plan and seeding details are summarized in Tables 4 and 5 (below) and Figure 14 (attached).
Table 4. Proposed planting plan.
Zone 1 - Stream Banks 2,250 sq ft
Common name
Botanical name Size Spacing
# of Plants
Soft rush
Juncus e usus Plu 3' Toe*
375
Silky dogwood
Cornus amomum Live stake 2' 0. C.
190
Black willow
Salix nigra Live stake T O.C.
190
Elderberry
Sambucus canadensis Live Stake T O.C.
190
* Eve 3' at toe of slopes on both banks
Zone 2 - Bankfull Bench 2,817 s ft
Common name
Botanical name Size Spacing
# of Plants
Green ash
Fraxinus pennsylvanica Bare root 3' O.C.
105
River birch
Betula nigra Bare root 3' 0. C.
105
Red maple
Acer rubrum Bare root 3' 0. C.
105
Zone 3 -Riparian Buffer to Plant 16,450 sq ft
Common name
Botanical name Size Spacing
# of Plants
S icebush
Lindera benzoin One Gallon 4' O.C.
205
Green ash
Fraxinus pennsylvanica One Gallon 4' O.C.
205
Red maple
Acer rubrum One Gallon 4' O.C.
205
Ironwood
1 Carpinus caroliniana One Gallon 4' O.C.
205
Slippery elm
Ulmus rubra One Gallon T O.C.
205
Zone 4 - Riparian Buffer to Control Invasives 15,575 sq ft
This zone will be avoided from clearing and will not require re -vegetation, however the
invasive species present will be controlled through invasive plant management.
Zone 5 - Riparian Seeding Only 29,469 sq ft
This zone will not require woody planting due to the required soil cap, however this zone
will be seeded with a temporary and native riparian seed mix.

Yale Security — Norton Site April 12, 2016
Request for PJD and PCN Notification to NWP No. 38 and WOC 3896 CWS Project No. 2016-3867
Table 5. Proposed seeding plan.
Zones 1, 2, 3, & 5:
Permanent Riparian Seed Mix; 46,053 sf (1.05 acres)
Common Name
Botanical Name
% Mix
Red -top panicgrass
Panicum rigidulum
20
Little blue stem
Schizachyrium scoparium
15
Lanceleaf tickseed
Coreopsis lanceolata
10
Partridge pea
Chamaecrista fasciculata
10
Black-eyed susan
Rudbeckia hirta
10
Beaked panicgrass
Panicum anceps
10
River oats
Chasmanthium latifolium
5
Deer tongue
Dichanthelium clandestinum
5
Virginia wild rye
Elymus virginicus
5
Purple top
Tridens flavus
5
Tickseed sunflower
Bidens aristosa
5
Zones 1, 2, 3, & 5: Temporary Seed Mix; 46,053 sf (1.05 acres)
Early Summer Season
Winter Season
40 lbs/acre of German Millet or
40 lbs/acre Rye
Seeding Mixture
Brown Top Millet
(gram)
80 lbs/acre Tall .
80 lbs/acre of Tall Fescue
Fescue
May 1 st - September 15th
September 15th -
Seeding Dates
Refertilize if growth is not fully,
May 1 st
adequate.
Seeding Amendments
Apply limestone and fertilizer per soil tests, or 2000
lbs/acre limestone and 750 lbs/acre 10-10-10 fertilizer.
Specifications for matting installation and a pump -around operation are included as Figures 17 and 18
(attached).
Monitoring Plan
CWS will be responsible for conducting monitoring of the restoration site for five years following the
restoration activities, if required. Monitoring reports will include an evaluation of current conditions as
compared to as -built conditions, mitigation site progression, and maintenance recommendations, if
necessary. Monitoring reports will be submitted to the USACE and NCDEQ following the completion of
the geomorphic survey and vegetation monitoring fieldwork, annually.
Channel Stability
Permanent benchmarks and cross sections will be established and marked with rebar and PVC stakes
following completion of the restoration activities during the as -built survey. Stakes and benchmarks will
be recorded with a sub -foot Trimble Geo7x GPS unit. A channel stability analysis will be conducted on
the restored stream reach, annually, during the winter season. This will include a geomorphic survey of
two permanent cross sections (one riffle and one pool), the longitudinal profile, Wolman Pebble Counts,
and photographic documentation.
10

Yale Security — Norton Site April 12, 2016
Request for PJD and PCN Notification to NWP No. 38 and WQC 3896 CWS Project No. 2016-3867
Vegetation Monitoring
Riparian vegetation will be monitored, annually, during the growing season. This will include woody
vegetation stem counts percent coverage in order to infer survivability and growth rates, as well as a
survey for invasive species and necessary treatment recommendations. Four permanent vegetation plots
(10 -foot by 10 -foot) will be established during the as -built survey with rebar and PVC stakes. Vegetation
plots will be recorded with a sub -foot Trimble Geo7x GPS unit.
Compensatory Mitigation
There are no permanent impacts to jurisdictional waters of the U.S. associated with this project. We
believe that the proposed restoration plan is the best possible plan that meets the project goals while
minimizing impacts to jurisdictional waters of the U.S. to the greatest extent possible. Therefore,
mitigation is not required for this project.
11

Yale Security — Norton Site April 12, 2016
Request for PJD and PCN Notification to NWP No. 38 and WOC 3896 CWS Project No. 2016-3867
On behalf of Yale Security Inc., CWS is submitting a Pre -Construction Notification Application with
attachments in accordance with Nationwide Permit General Condition No. 31, and pursuant to Nationwide
Permit No. 38 and Water Quality Certification No. 3896.
Please do not hesitate to contact me at 704-408-1683, or through email at [e-mail] should you have
any questions or comments regarding this application.
Sincerely,
�- 74;iT�_ _V� •Iz"KX" i
Gregg Antemann, PWS Kelly Thames, PWS
Professional Wetland Scientist Project Scientist
S o°c ���Ib1iN� •!
Attachments: Figure 1. USGS Site Location Map
Figure 2. Aerial Imagery
Figure 3. Current USDA-NRCS Soils Map of Union County
Figure 4. Historic USDA-NRCS Soils Map of Union County
Figure 5. National Wetland Inventory Map
Figure 6. Approximate Jurisdictional Boundary Map
Figure 7. Limits of Contaminated Area
Figure 8. Limits of Contaminated Area
Figure 9. Geomorphic Overview
Figure 10. Representative Cross Section — Riffle
Figure 11. Representative Cross Section — Pool
Figure 12. Longitudinal Profile
Figure 13. Wolman Pebble Count
Figure 14. Stream Restoration and Planting Plan View
Figure 15. Proposed Typical Cross Section
Figure 16. Proposed Longitudinal Profile
Figure 17. Matting Detail
Figure 18. Pump -Around Detail
Agent Authorization Form
Preliminary Jurisdictional Determination Form
Pre -Construction Notification
NCDEQ Stream Classification Form (SCP I)
Routine Wetland Determination Data Forms (DP1-DP2)
Agency Correspondence
Representative Photographs (A -B)
12

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REFERENCE: USDA-NRCS HISTORIC SOIL SURVEY OF UNION COUNTY, NC, SHEETS 23 AND 24, DATED 1990.
scALE: 1 inch = 1,000 feet DATE 2/15/2016 Historic USDA-NRCS Soil Survey FIGUI?h No.
CWS PROJECT NO: DRAWN BY. KJM of Union County
2016-3867
Yale Security - Norton Site
APPLICANTNO: CHECKED BY KMT CAROLINA Monroe, North Carolina 4
WETLAND SERVICES CWS Project No. 2016-3867
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CWS PROTECT NODRAWN BY:
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APPLICANT NOCHECKED BYGCA CAROLINA Monroe, North Carolina : WETLAND SERVICES CWS Project No. 2016-3867 to : :
Parameter Existing Condition
Bankfull Width ft. 3.40
Mean Bankfull Depth ft. 0.85
Width/De th Ratio 4.02
Bankfull Areas . ft. 2.88
Bankfull Maximum Depth ft. 1.12
Width of Flood rove Area ft. 20.90
Entrenchment Ratio 6.15
Sinuosity 1.02
Water Surface Slope ft./ft. 0.022
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Bankfull Area (sq. ft.)
4.94
Bankfull Maximum Depth (ft.)
1.10
Width of Floodprone Area (ft.)
11.50
Entrenchment Ratio
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Sinuosity
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0.022
Rosgen Stream Type
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Representative Cross Section - Pool
CWS PROSECT NO: DRAWN BY:
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APPLICANT NO: CHECKED BY: GCA C A R O ERI N A Monroe, North Carolina
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®
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Typical Cross Section
r1GURE No
15
CWS PROTECT NO
2016-3687
DRAWN 6Y
KMT
Yale Security—Norton Site
Monroe, North Carolina
APPLICANTNO
CHECKED BY
GCA
WETLAND SERVICES
CWS Project No. 2016-3867
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CWS Project No. 2016-3867
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APPLICANTCHECKED BY CAROLINA Monroe, North Carolina '
GCA WETLAND SERVICES CWS Project No. 2016-3896
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SCALE DATE
n/a 3/1/2016 Matting Detail FIGURE NO.
CWS PROJECT NO DRAWN BY
2016-3867 KMT Vale Security - Norton Site17
APPLICANTCHECKED BY CAROLINA Monroe, North Carolina '
GCA WETLAND SERVICES CWS Project No. 2016-3896

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CWS PROJECT NO DRAWN BY
2016-3867 KMT Yale Security - Norton Site
APPLICANT CHECKED BY C A R D L I N A Monroe, North Carolina 18
GCA WETLAND SERVICES CWS Project No. 2016-3896

AGENT CERTIFICATION OF AUTHORIZATION
I, the undersigned, a duly authorized owner (or representative) of record of the
property/properties identified herein, do authorize a representative of the Wilmington
District, U.S. Army Corps of Engineers (Corps) to enter upon the property herein
described for the purpose of conducting on-site investigations and issuing a determination
associated with Waters of the U.S. subject to Federal jurisdictional under Section 404 of
the Clean Water Act and/or Section 10 of the Rivers and Harbors Act of 1899.
I, Barry Giroux, representing Yale Security Inc., hereby certify that I have authorized
Gregg Antemann of Carolina Wetland Services, Inc. to act on my behalf and take all
actions necessary to the processing, issuance, and acceptance of this request for wetlands
determination / permitting and any and all standard and special conditions attached.
We hereby certify that the above information submitted in this application is true and
accurate to the best of our knowledge.
6m4m
Applican s tore
31q /(,*
Date
Agent's signature
3-8-2016
Date
Completion of this form will allow the agent to sign all future application correspondence.

ATTACHMENT A
PRELIMINARY JURISDICTIONAL DETERMINATION FORM
BACKGROUND INFORMATION ,
A. REPORT COMPLETION DATE FOR PRELIMINARY JURISDICTIONAL
DETERMINATION (JD): 4-12-2016
B. NAME AND ADDRESS OF PERSON REQUESTING PRELIMINARY JD:
Carolina Wetland Services, Inc., POC. Mr. Gregg Antemann
550 E Westinghouse Blvd., 28273, Charlotte, NC
C. DISTRICT OFFICE, FILE NAME, AND NUMBER:
Wilmington District -Asheville Regulatory Field Office
D. PROJECT LOCATION(S) AND BACKGROUND INFORMATION:
3000 East Old Highway 74 in Monroe, North Carolina
(USE THE ATTACHED TABLE TO DOCUMENT MULTIPLE WATERBODIES AT DIFFERENT
SITES)
State: NC County/parish/borough: union City: Monroe
Center coordinates of site (lat/long in degree decimal format):
Lat. 34.9774020 ON; Long. -80.486040 °N/
Universal Transverse Mercator: NAD83
Name of nearest waterbody: UT to Rays Fork
Identify (estimate) amount of waters in the review area:
Non -wetland waters:
658 linear feet: 3' width (ft) and/or 0.05 acres.
Cowardin Class: R4SB3
Stream Flow: seasonal
Wetlands: 0.02 acres.
Cowardin Class: PF01
Name of any water bodies on the site that have been identified, as Section 10
waters:
Tidal:
Non -Tidal:
1

E. REVIEW PERFORMED FOR SITE EVALUATION (CHECK ALL THAT
APPLY):
❑ Office (Desk) Determination. Date:
Field Determination. Date(s): 2-18-2016
SUPPORTING DATA. Data reviewed for preliminary JD
(check all that apply - checked items should be included in case file and,
where checked and requested, appropriately reference sources below):
✓❑ Maps, plans, plots or plat submitted by or on behalf of the
applicant/consultant:
❑✓ Data sheets prepared/submitted by or on behalf of the
applic nt/consultant.
Office concurs with data sheets/delineation report.
Office does not concur with data sheets/delineation report.
0
❑ Data sheets prepared by the Corps:
❑ Corps navigable waters' study:
❑ U.S. Geological Survey Hydrologic Atlas:
❑ USGS NHD data
❑ USGS 8 and 12 digit HUC maps
❑✓ U.S. Geological Survey map(s). Cite scale & quad name: 124.000, Mmme(1991)& WUigal.(1991)
❑✓ USDA Natural Resources Conservation Service Soil Survey.
Citation: Current (2014) and Historic (1990) for Union County
❑✓ National wetlands inventory map(s). Cite name: USFWS NWI (1995) for NC
❑ State/Local wetland inventory map(s):
❑ FEMA/FIRM maps:
❑ 100 -year Floodplain Elevation is:
(National Geodectic Vertical Datum of 1929)
❑✓ Photographs: Aerial (Name & Date): NC oNEMAP (2014)
QOther (Name & Date): Site Photographs, dated February 2016
❑ Previous determination(s). File no. and date of response letter:-
❑ Other information (please specify): '
4
a

1. The Corps of Engineers believes that there may be jurisdictional waters of the
United States on the subject site, and the permit applicant or other affected party
who requested this preliminary JD is hereby advised of his or her option to
request and obtain an approved jurisdictional determination (JD) for that site.
Nevertheless, the permit applicant or other person who requested this
preliminary JD has declined to exercise the option to obtain an approved JD in
this instance and at this time.
2. In any circumstance where a permit applicant obtains an individual permit, or
a Nationwide General Permit (NWP) or other general permit verification requiring
"pre -construction notification" (PCN), or requests verification for a non -reporting
NWP or other general permit, and the permit applicant has not requested an
approved JD for the activity, the permit applicant is hereby made aware of the
following: (1) the permit applicant has elected to seek a permit authorization
based on a preliminary JD, which does not make an official determination of
jurisdictional waters; (2) that the applicant has the option to request an approved
JD before accepting the terms and conditions of the permit authorization, and
that basing a permit authorization on an approved JD could possibly result in less
compensatory mitigation being required or different special conditions; (3) that
the applicant has the right to request an individual permit rather than accepting
the terms and conditions of the NWP or other general permit authorization; (4)
that the applicant can accept a permit authorization and thereby agree to comply
with all the terms and conditions of that permit, including whatever mitigation
requirements the Corps has determined to be necessary; (5) that undertaking
any activity in reliance upon the subject permit authorization without requesting
an approved JD constitutes the applicant's acceptance of the use of the
preliminary JD, but that either form of JD will be processed as soon as is
practicable; (6) accepting a permit authorization (e.g., signing a proffered
individual permit) or undertaking any activity in reliance on any form of Corps
permit authorization based on a preliminary JD constitutes agreement that all
wetlands and other water bodies on the site affected in any way by that activity
are jurisdictional waters of the United States, and precludes any challenge to
such jurisdiction in any administrative or judicial compliance or enforcement
action, or in any administrative appeal or in any Federal court; and (7) whether
the applicant elects to use either an approved JD or a preliminary JD, that JD
will be processed as soon as is practicable. Further, an approved JD, a proffered
individual permit (and all terms and conditions contained therein), or individual
permit denial can be administratively appealed pursuant to 33 C.F.R. Part 331,
and that in any administrative appeal, jurisdictional issues can be raised (see 33
C.F.R. 331.5(a)(2)). If, during that administrative appeal, it becomes necessary
to make an official determination whether CWA jurisdiction exists over a site, or
to provide an official delineation of jurisdictional waters on the site, the Corps will
provide an approved JD to accomplish that result, as soon as is practicable.

This preliminary JD finds that there "maybe" waters of the United States on the
subject project site, and identifies all aquatic features on the site that could be
affected by the proposed activity, based on the following information:
IMPORTANT NOTE: The information recorded on this form has not
necessarily been verified by the Corps and should not be relied upon for
later jurisdictional determinations.
Signature and date of
Regulatory Project Manager
(REQUIRED)
4
3-15-2016
Signature and date of
person requesting preliminary JD
(REQUIRED, unless obtaining
the signature is impracticable)

Estimated
Amount of
Cowardian
Class of Aquatic
Site Number
Latitude
Longitude
Aquatic
Class
Resource
Resource in
Review Area
Seasonal RPW
34 977402°
-80 486525°
R4SB3
6581f
non -section 10 -- non -tidal
Stream A
Wetland AA
34 977402°
-80 486525°
PFOI
0 02 ac
non -section 10 -- non -tidal
wetland

Office Use Only.
Corps action ID no
DWQ project no.
Form Version 1 3 Dec 10 2008
Page 1 of 13
PCN Form — Version 1 3 December 10, 2008 Version
Pre -Construction Notification PC Form
A. Applicant Information
1.
Processing
1 a. Type(s) of approval sought from the
Corps
®Section 404 Permit El Section 10 Permit
1 b Specify Nationwide Permit (NWP) number: 38 or General Permit (GP) number
1c.
Has the NWP or GP number been verified by the Corps?
❑ Yes
® No
1d
Type(s) of approval sought from the DWQ (check all that apply)
® 401 Water Quality Certification — Regular ❑ Non -404 Jurisdictional General Permit
❑ 401 Water Quality Certification — Express ❑ Riparian Buffer Authorization
le
Is this notification solely for the record
because written approval is not required?
For the record only for DWQ 401
Certification
❑ Yes ® No
For the record only for Corps Permit
❑ Yes ® No
1f
Is payment into a mitigation bank or in -lieu fee program proposed for mitigation
of impacts? If so, attach the acceptance letter from mitigation bank or in -lieu
fee program.
❑ Yes
® No
1g
Is the project located in any of NC's twenty coastal counties. If yes, answer 1h
below
❑ Yes
® No
1 h.
Is the project located within a NC DCM Area of Environmental Concern (AEC)?
❑ Yes
® No
2.
Project Information
2a
Name of project
Yale Security - Norton Site
2b
County
Union
2c
Nearest municipality / town
Monroe
2d
Subdivision name
N/A
2e
NCDOT only, T.I.P. or state
project no.
N/A
3.
Owner Information
3a
Name(s) on Recorded Deed.
Yale Security, Inc
3b
Deed Book and Page No
5865-742
3c
Responsible Party (for LLC if
applicable):
N/A
3d
Street address
3000 East Old Highway 74
3e
City, state, zip
Monroe, NC 06511
3f
Telephone no
3g.
Fax no.,
3h
Email address
Page 1 of 13
PCN Form — Version 1 3 December 10, 2008 Version

4.
Applicant Information (if different from owner)
4a. Applicant is
❑ Agent ® Other, specify Yale Security, Inc
4b
Name.
Mr Barry Giroux
4c.
Business name
(if applicable):
Yale Security, Inc
4d. Street address
455 Winding Brook Drive, Suite 201
'4e
City, state, zip
Glastonbury, CT 06033
4f.
Telephone no
860-368-5340
4g
Fax no
4h.
Email address
BGiroux@geiconsultants com
5.
Agent/Consultant Information (if applicable)
5a
Name:
Gregg Antemann, PWS
5b.
Business name
(if applicable).
Carolina Wetland Services, Inc
5c.
Street address:
550 E. Westinghouse Blvd
5d
City, state, zip.
Charlotte, NC 28273
5e
Telephone no.:
704-408-1683
5f.
Fax no
704-527-1133
5g
Email address-
[e-mail]
Page 2 of 13
PCN Form — Version 1.3 December 10, 2008 Version

B.
Project Information and Prior Project History
1.
Property Identification
1a.
Property identification no (tax PIN or parcel ID):
09087005
1 b. Site coordinates (in decimal degrees)-
Latitude: 35 335345 Longitude. - -
80486040
(DD DDDDDD) (-DD DDDDDD)
1 c.
Property size-
16 acres
2.
Surface Waters
2a.
Name of nearest body of water (stream, river, etc ) to
proposed project
UT to Rays Fork
2b
Water Quality Classification of nearest receiving water
Class C
2c
River basin:
Yadkin (HUC# 03040105)
Page 3 of 13
PCN Form — Version 1.3 December 10, 2008 Version

3. Project Description
3a. Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of this
application
The site is approximately 16 acres in extent and consists of a manufacturing business with associated paved parking lots,
maintained lawns, and forested areas in the southern portion of the project limits (Figure 2, attached). Typical on-site
vegetation includes red maple (Acer rubrum), white oak (Quercus alba), eastern red cedar (Juniperus virginiana), green
ash (Fraxinus pennsylvanica), sweetgum (Liquidambar styraciflua), poison ivy (Toxicodendron radicans), spleenwort
(Asplenium platyneuron), greenbrier (Smilax rotundifolia), sawtooth blackberry (Rubus argutus), Chinese privet
(Ligustrum sinense), and Japanese honeysuckle (Lorncera japonica).
3b. List the total estimated acreage of all existing wetlands on the property'
0.02 acre
3c List the total estimated linear feet of all existing streams (intermittent and perennial) on the property:
658 If of seasonal channel
3d Explain the purpose of the proposed project:
The Yale Security - Norton Site (hereinafter "Site") was developed for its current use in 1956. Since the initial construction in
1956 the building has been expanded twice towards the rear of the property. In order for the expansions to occur, fill was
necessary to grade out a large flat area to handle the necessary growth for the building and attendant structures (Figure
7, attached) No impacts to jurisdiction waters of the U S. occurred during this time
Since the expansions and subsequent fill material was brought in to the Site, elevated concentrations of PCBs, lead,
cadmium, and volatile organic compounds (VOCs) have been detected in the fill soil. The source of the PCBs in the soil
is not known, but Yale Security believes that PCBs and other constituents were likely present in the fill material that was
used. The placement of off-site materials in the fill area is believed to have stopped in 1972 when expansions were no
longer needed. No reported releases of PCBs at the Site have been detected, and the distribution of the PCBs in the soil
is relatively widespread across the rear of the Site where the fill occurred. The fill of contaminated soil clearly occurred
before the initiation of what is now the standard practice of screening and sampling the proposed fill material before
placement on a site.
Due to the contaminated fill soils, PCBs were identified in the surface sod (bed and banks) of Seasonal RPW Stream A
located in the southern portion of the property (Figures 7 and 8, attached). Given that the PCBs were detected across
most of the rear of the Site (as opposed to in discrete locations), it is possible that when the fill material was brought onto
the rear of the Site, it may have seeped into the area where Stream A is located Elevated concentrations of lead,
cadmium and VOCs have not been detected in the channel sod, however, they are potentially present.
The Site is being investigated and remediated under the North Carolina Department of Environmental Quality (NCDEQ),
Inactive Hazardous Site Branch's (IHSS) Registered Environmental Consultant (REC) program in accordance with the
terms of an Administrative Agreement with the IHSB established in August 2008 (Docket Number 08-SF-243). Remedial
actions conducted under the REC Program are governed by the Inactive Hazardous Sites Response Act and the REC
Program Rules found at 15A NCAC 13C 0300.
Proposed and necessary remedial actions include a soil cap and the excavation of the contaminated soils in the bed and
banks of Stream A down to soils exhibiting one or less milligram per kilogram (<_ 1 mg/kg) of PCBs. Contaminated soils
will be removed to an off-site disposal Clean fill will be used to backfill the excavated area and Stream A will be restored
to its pre-existing geomorphological condition utilizing Rosgen Stream Classification and natural channel design
techniques discussed in the Stream Restoration section of this application.
3e. Describe the overall project in detail, including the type of equipment to be used.
Under Nationwide Permit (NWP) No 38, unavoidable temporary impacts to jurisdictional waters associated with this
project are limited to a total of 560 linear feet (If) of jurisdictional stream channel (Stream A [Figure 8, attached])
Temporary impacts will consist of the excavation of the bed and banks of Seasonal RPW Stream A until in-situ soils
exhibit a one or less milligram per kilogram (<_ 1 mg/kg) PCB concentration. When the required level is met, clean backfill
will be placed in the excavated area and restored to the proposed geomorphological condition described in the Stream
Restoration section in the attached cover letter
Standard equipment such as front loaders, track hoes, and excavators will be utilized.
Page 4 of 13
PCN Form — Version 1.3 December 10, 2008 Version

4.
Jurisdictional Determinations
4a.
Have jurisdictional wetland or stream determinations by the
Corps or State been requested or obtained for this property /
project (including all prior phases) in the past?
Comments
El Yes ®No El Unknown
4b.
If the Corps made the jurisdictional determination, what type
of determination was made?
❑ Preliminary ❑ Final
4c.
If yes, who delineated the jurisdictional areas?
Name (if known):
Agency/Consultant Company.
Other
4d.
If yes, list the dates of the Corps jurisdictional determinations or State determinations and attach documentation
5.
Project History
5a.
Have permits or certifications been requested or obtained for
this project (including all prior phases) in the past?
❑ Yes ® No ❑ Unknown
5b
If yes, explain in detail according to "help file" instructions.
6.
Future Project Plans
6a.
Is this a phased project?
❑Yes No
6b.
If yes, explain
Page 5 of 13
PCN Form — Version 1.3 December 10, 2008 Version

C Proposed Impacts Inventory
1 Impacts Summary
1 a. Which sections were completed below for your project (check all that apply):
❑ Wetlands ® Streams - tributaries ❑ Buffers
❑ Open Waters ❑ Pond Construction
2. Wetland Impacts
If there are wetland impacts proposed on the site, then complete this question for each wetland area impacted
2a.
2b
2c.
2d.
2e
2f
Wetland impact
Type of jurisdiction
number —
Type of impact
Type of wetland
Forested
(Corps - 404, 10
Area of impact
Permanent (P)
(if known)
DWQ — non -404, other)
(acres)
or Temporary T
W1 ❑ P ❑ T
❑ Yes
❑ Corps
❑ No
❑ DWQ
W2 ❑ P ❑ T
❑ Yes
❑ Corps
❑ No
❑ DWQ
W3 ❑ P ❑ T
❑ Yes
❑ Corps
❑ No
❑ DWQ
W4 ❑ P ❑ T
❑ Yes
❑ Corps
❑ No
❑ DWQ
W5 ❑ P ❑ T
❑ Yes
❑ Corps
❑ No
❑ DWQ
W6 ❑ P ❑ T
❑ Yes
❑ Corps
❑ No
❑ DWQ
2g. Total wetland impacts
2h. Comments:'
3. Stream Impacts
If there are perennial or intermittent stream impacts (including temporary impacts) proposed on the site, then complete this
question for all stream sites impacted.
3a.
3b.
3c.
3d.
3e
3f
3g.
Stream impact
Type of impact
Stream name
Perennial
Type of jurisdiction
Average
Impact
number -
(PER) or
(Corps - 404, 10
stream
length
Permanent, (P)
intermittent
DWQ — non -404,
width
(linear
or Temporary (T)
(INT)?
other)
(feet)
feet)
S1 ❑ P ® T
Restoration/Excavation
Stream A
❑ PER
® INT
® Corps
❑ DWQ
3'
560'
S2 ❑ P ❑ T
❑ PER
❑ Corps
❑ INT
❑ DWQ
S3 ❑ P ❑ T
❑ PER
❑ Corps
'
❑ INT
❑ DWQ
S4 ❑ P ❑ T
❑ PER
❑ Corps
❑ INT
❑ DWQ
S5 ❑ P ❑ T
❑ PER
❑ Corps
❑ INT
❑ DWQ
S6 ❑ P ❑ T
❑ PER
❑ Corps
❑ INT
❑ DWQ
3h. Total stream and tributary impacts
560 Lf
31. Comments: Tempoaray impacts to Stream A total 560 If (0.04 ac.).
Page 6 of 13
PCN Form — Version 1.3 December 10, 2008 Version

4. Open Water Impacts
If there are proposed impacts to lakes, ponds, estuaries, tributaries, sounds, the Atlantic Ocean, or any other open water of
the U S then individually list all open water impacts below.
4a
Open water
impact number
— Permanent
(P) or
Temporary T
4b.
Name of waterbody
(if applicable)
4c.
Type of impact
4d.
Waterbody type
4e.
Area of impact (acres)
01 ❑PEI
02 ❑P❑T
03 ❑P❑T
04 ❑P❑T
4f. Total open water impacts
4g Comments:
5. Pond or Lake Construction
If pond or lake construction proposed, then com tete the chart below
5a.
Pond ID
number
5b.
Proposed use or purpose of
pond
5c.
Wetland Impacts (acres)
5d
Stream Impacts (feet)
5e
Upland
(acres)
Flooded
Filled
Excavated
Flooded
Filled
Excavated
Flooded
P1
P2
K Total
5g Comments:
5h Is a dam high hazard permit required?
❑ Yes ❑ No If yes, permit ID no
51. Expected pond surface area (acres):
5j. Size of pond watershed (acres).
5k. Method of construction
Page 7 of 13
PCN Form — Version 1.3 December 10, 2008 Version

6. Buffer Impacts (for DWQ)
If project will impact a protected riparian buffer, then complete the chart below. If yes, then individually list all buffer impacts
below. If any impacts require mitigation, then you MUST fill out Section D of this form
6a.
❑ Neuse ❑ Tar -Pamlico ❑ Other
Project is in which protected basin?
❑ Catawba ❑ Randleman
6b.
6c.
6d.
6e.
6f.
6g
Buffer impact
number —
Reason
Buffer
Zone 1 impact
Zone 2 impact
Permanent (P)
for
Stream name
mitigation
(square feet)
(square feet)
or Temporary
impact
required?
T
61 ❑ PEI T
El Yes
❑ No
B2 ❑P❑T
El Yes
❑ No
B3 ❑P❑T
El Yes
❑ No
6h. Total buffer impacts
6i. Comments
D. Impact Justification and Mitigation
1. Avoidance and Minimization
1a. Specifically describe measures taken to avoid or minimize the proposed impacts in designing project
All impacts to on-site jurisdictional waters of the U S. are temporary, but unavoidable Proper sediment and erosion control
measures will be used to minimize disturbances to downstream waters. Construction activities and impacts to on-site
jurisdictional waters of the U S will comply with all conditions of Nationwide Permit No. 33 and Water Quality Certification No
3896 All work will be constructed in the dry No permanent impacts to Seasonal RPW Stream A are proposed Of the 658
linear feet of channel within the project limits, 560 linear feet will restored linear foot for linear foot. No impacts to jurisdictional
wetlands are proposed
In an attempt to avoid impacts to jurisdictional waters while still meeting the goals of the project, a "No Impact" alternative was
considered. Due to the North Carolina Department of Environmental Quality (NCDEQ), Inactive Hazardous Site Branch's
(IHSB) Registered Environmental Consultant (REC) program, remedial actions are required to remove the contaminated soils
Therefore, temporary impacts to Seasonal RPW Stream A are unavoidable.
The currently proposed restoration plan was developed as a result of the project history and the remedial actions required by
the NCDEQ IHSB REC program. We believe that Stream A will not only be benefited by the removal of contaminated soils,
but will display an uplift in ecological function through the use of Rosgen Stream Classification and natural channel design
techniques.
The left bank of Stream A will be cleared as the required soil cap will be installed The majority of the left bank will be seeded
only. As the right bank of Stream A consists of a forested area with many large trees, minimal and selective clearing is
proposed within the first 25 foot buffer of the right bank. Invasive species control is proposed throughout the 50 -foot buffer.
1 b Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques.
Impacts to on-site jurisdictional waters of the U.S have been reduced to the maximum extent possible All work will be
constructed in the dry in accordance with Water Quality Certification (WQC) No. 3896 Proper sediment and erosion control
measures will be used to minimize disturbances to downstream waters.
Page 8 of 13
PCN Form — Version 1 3 December 10, 2008 Version

2. Compensatory Mitigation for Impacts to Waters of the U.S. or Waters of the State
2a Does the project require Compensatory Mitigation for
impacts to Waters of the U S. or Waters of the State?
❑ Yes ® No
2b. If yes, mitigation is required by (check all that apply):
❑ DWQ ❑ Corps
2c If yes, which mitigation option will be used for this project?,
❑ Mitigation bank
❑ Payment to in -lieu fee program
❑ Permittee Responsible Mitigation
3. Complete if Using a Mitigation Bank
3a Name of Mitigation Bank:
3b. Credits Purchased (attach receipt and letter)
Type
Quantity
3c Comments:
4. Complete if Making a Payment to In -lieu Fee Program
4a Approval letter from in -lieu fee program is attached
❑ Yes
4b. Stream mitigation requested
linear feet
4c. If using stream mitigation, stream temperature,
❑ warm ❑ cool ❑cold
4d. Buffer mitigation requested (DWQ only).
square feet
4e Riparian wetland mitigation requested-
acres
4f. Non -riparian wetland mitigation requested
acres
4g Coastal (tidal) wetland, mitigation requested
acres
4h Comments:
5. Complete if Using a Permittee Responsible Mitigation Plan
5a. If using a permittee responsible mitigation plan, provide a description of the proposed mitigation plan.
6. Buffer Mitigation (State Regulated Riparian Buffer Rules) — required by DWQ
6a Will the project result in an impact within a protected riparian buffer that requires
buffer mitigation'?
El es ® No
6b. If yes, then identify the square feet of impact to each zone of the riparian buffer that requires mitigation. Calculate the
amount of mitigation required.
Zone
6c
Reason for impact
6d
Total impact
(square feet)
Multiplier
6e
Required mitigation
(square feet)
Zone 1
3 (2 for Catawba)
Zone 2
1.5
6f. Total buffer mitigation required:
6g If buffer mitigation is required, discuss what type of mitigation is proposed (e g , payment to private mitigation bank,
permittee responsible riparian buffer restoration, payment into an approved in -lieu fee fund).
Page 9 of 13
PCN Form —Version 1.3 December 10, 2008 Version

6h. Comments
Page 10 of 13
PCN Form — Version 1 3 December 10, 2008 Version

E. Stormwater Management and Diffuse Flow Plan (required by DWQ)
1. Diffuse Flow Plan
1a Does the project include or is it adjacent to protected riparian buffers identified
❑ Yes ® No
within one of the NC Riparian Buffer Protection Rules?
lb If yes, then is a diffuse flow plan included? If no, explain why
Yes ❑
❑ No
Comments
2. Stormwater Management Plan
2a. What is the overall percent imperviousness of this project?
%
2b Does this project require a Stormwater Management Plan?
❑ Yes ® No
2c If this project DOES NOT require a Stormwater Management Plan, explain why No change in impervious area.
2d. If this project DOES require a Stormwater Management Plan, then provide a brief, narrative description of the plan
❑ Certified Local Government
2e. Who will be responsible for the review of the Stormwater Management Plan?
❑ DWQ Stormwater Program
❑ DWQ 401 Unit
3. Certified Local Government Stormwater Review
3a In which local government's jurisdiction is this project?
❑ Phase II
3b. Which of the following locally -implemented stormwater management programs
❑ NSW
❑ USMP
apply (check all that apply)
❑ Water Supply Watershed
❑ Other
3c. Has the approved Stormwater Management Plan with proof of approval been
❑ Yes ❑ No
attached?
4. DWQ Stormwater Program Review
❑ Coastal counties
❑ HQW
4a. Which of the following state -implemented stormwater management programs apply
❑ ORW
(check all that apply)
❑ Session Law 2006-246
❑ Other
4b Has the approved Stormwater Management Plan with proof of approval been
attached?
❑ Yes ❑ No
5. DWQ 401 Unit Stormwater Review
5a Does the Stormwater Management Plan meet the appropriate requirements?
❑ Yes ❑ No
5b. Have all of the 401 Unit submittal requirements been met?
❑ Yes ❑ No
Page 11 of 13
PCN Form — Version 1.3 December 10, 2008 Version

F.
Supplementary Information
1.
Environmental Documentation (DWQ Requirement)
1a
Does the project involve an expenditure of public (federal/state/local) funds or the
❑ Yes
® No
use of public (federal/state) land?
lb
If you answered "yes" to the above, does the project require preparation of an
environmental document pursuant to the requirements of the National or State
❑ Yes
❑ No
(North Carolina) Environmental Policy Act (NEPA/SEPA)?
1c
If you answered "yes" to the above, has the document review been finalized by the
State Clearing House? (If so, attach a copy of the NEPA or SEPA final approval
letter )
❑ Yes
❑ No
Comments:
2.
Violations (DWQ Requirement)
2a.
Is the site in violation of DWQ Wetland Rules (15A NCAC 2H 0500), Isolated
Wetland Rules (15A NCAC 2H .1300), DWQ Surface Water or Wetland Standards,
❑ Yes
® No
or Riparian Buffer Rules (15A NCAC 2B .0200)?
2b
Is this an after -the -fact permit application?
❑ Yes
® No
2c.
If you answered "yes" to one or both of the above questions, provide an explanation of the violation(s):
3.
Cumulative Impacts (DWQ Requirement)
3a
Will this project (based on past and reasonably anticipated future impacts) result in
❑ Yes
® No
additional development, which could impact nearby downstream water quality?
3b.
If you answered "yes" to the above, submit a qualitative or quantitative cumulative impact analysis in accordance with the
most recent DWQ policy. If you answered "no," provide a short narrative description.
The project will not result in additional future development.
4.
Sewage Disposal (DWQ Requirement)
4a
Clearly detail the ultimate treatment methods and disposition (non -discharge or discharge) of wastewater generated from
the proposed project, or available capacity of the subject facility.
N/A
Page 12 of 13
PCN Form — Version 1 3 December 10, 2008 Version

5. Endangered Species and Designated Critical Habitat (Corps Requirement)
5a Will this project occur in or near an area with federally protected species or
❑ Yes ® No
habitat?
5b. Have you checked with the USFWS concerning Endangered Species Act
❑ Yes ® No
impacts?
EJ Raleigh
5c. If yes, Indicate the USFWS Field Office you have contacted.
❑ Asheville
5d What data sources did you use to determine whether your site would Impact Endangered Species or Designated Critical
Habitat?
CWS performed a data review using North Carolina Natural Heritage Program (NCNHP) Data Explorer on February 24,
2016 to determine the presence of any federally -listed, candidate endangered, threatened species, or critical habitat
located within the project area Based on this review, there are no records of federally -protected species within the
project limits. A copy of the data review report is attached.
6. Essential Fish Habitat (Corps Requirement)
6a Will this project occur in or near an area designated as essential fish habitat?
❑ Yes ® No
6b. What data sources did you use to determine whether your site would impact Essential Fish Habitat?
NOAA Fisheries: hftp://sharpfin.nmfs noaa.gov/website/EFH_Mapper/map aspx
7. Historic or Prehistoric Cultural Resources (Corps Requirement)
7a WIII this project occur in or near an area that the state, federal or tribal
governments have designated as having historic or cultural preservation
❑ Yes ® No
status (e g., National Historic Trust designation or properties significant in
North Carolina history and archaeology)?
7b What data sources did you use to determine whether your site would impact historic or archeological resources?
CWS consulted the North Carolina State Preservation Office (SHPO) online GIS service and found no sites of
architectural, historical, or archaeological significance within the project limits. In addition, CWS consulted the National
Register of Historic Places for Union County and found no properties adjacent to, or within the project limits
8. Flood Zone Designation (Corps Requirement)
8a WIII this project occur in a FEMA -designated 100 -year floodplain?
El es ® No
8b. If yes, explain how project meets FEMA requirements
8c. What source(s) did you use to make the floodplain determination? FEMA FIRM No 3710545500J and 3710545400J
Z"J
Mr. Gregg Antemann, PWS
74; a
C_ ~`'`�
3-15-2016
Applicant/Agent's Printed Name
Date
Applicant/Agent's Signature
(Agent's signature is valid only if an authorization letter from the applicant
is provided
Page 13 of 13
PCN Form — Version 1 3 December 10, 2008 Version

NC DWO Stream Identification Form Version 4.11
Date: _ _
Pro]ectlSite'N000/I dif t
Latitude: 314 �7IOU (a
Evaluator: K) rV1 /(iVl
County: 011 ion
Longitude:'�Q�y�� �1
Total Points: {
Stmarn Is at leasttntermlttent r'
C,
Stream Determination {circle one)
Bphomeral 1 rrnitte Perennial
Other �-�r (ti) r9
e.g. Quadname:�'��1
if z 19 or erenrdal if a 304 a
2_ Sinuosity of channel along thalweg
0
A. Geomo holo Subtctai = 111 - J
Absent
Weak
Moderate
Strong
1a Continuity of channel bed and bank
0
1
2
3
2_ Sinuosity of channel along thalweg
0
1
2
3
3. in -channel structure: ek riffle -pool, step -pool,
ri le- ool se Lence
0
1
O
3
4 Particle size of stream substrate
0
0.5
2
3
5 Activelrelict floodplain
0
0.5
2
3
6. Depositional bars or benches
0
1
2
3
7. Recent alluvia! deposits
0
1
2
3
8 Headcuts
1` 1
2
3
9 Grade control
0
1.5
10 Natural valley
0
0.5
F 1.5
11. Second or greater order channel
No = 0 t
Yes = 3
Sketch:
"arliflulal ditches are not rated; see�ddiscusstons In manual
B. Hvdroloav (Subtotal =;' ] .l5
12. Presence of Baseflow
0 1
2
3
13. Iron oxidizing bacteria
0 1
2
3
14. Leaf Nter
1,5 1
0.5
0
15. Sediment on plants or debris
0 0.5
1
1.5
16. Organic debris lines or piles
I 0 0.5
1
1.5
17. Sal -based evidence of high water table?
I No = 0es
0.5
= 3
U. U10100v t5ubtotal = -'J_ I -x l
18. Fibrous roots in stream oed
3
r2
1
0
19. Rooted upland plants In streambed
M2
1
0
20. Macrobenthos (note diversity and abundance)
0_0
2
3
21. Aquatic Mollusks
0
1
2
3
22. F-sh
C'613
0.5
1
1.5
23. Crayfish
0
0.5
1
1.5
24. Amphibians
1
1.5
25. Algae
0
0.5
1
1.5
26. Wetland plants In streambed
FACW = 0.75; OSL = 1.5
Olier = 0)
"perennial streams may also be Identified using other methods. See p. 35 of manual.
Notes:
Sketch:

WETLAND DETERMINATION DATA FORM — Eastern
ff Mountains and Piedmont Region
Project/Site: �Y¢J Yl .q fir CityiCounty. '/I ��� (� Samptng Date:
Appllcart/Owner: &LL t' �� + r 11,1f" State: N Sampling Point: b F11 _ G�t�'i1) otl /I
Investigator(s); r 1 ti� * Seclion,Township, Range: W )orof
Landform (hlllslope, terrace, etc.): 'p"r* Y f r4til: / Local relief (concave, convex, none): rt)17icA V L Slope
SuioreCiDn (LRR o ML ( : i ; (g Lal: o �1 a I1 f'( J, Long: ` � `' A • T 1 Datum, NA R 3
Soil Map Unit Name: _ CI (,1 i �l� )l�l' f t.1 ,1 i� <70(1(�TT=�o t��s r)."t ��� NWI classificatlon: uA
Are climatic / hydrologic conditions on the site typical for this time of year? Yes_ No_ (If no, explain in Remarks)
Are Vogoatlon , Soil , or Hydrology slgnlficanilg disturbed? Afe'Normal Circumslancos" present? Yos _— No
Are Vegetation_, Sail _,or Hydrology naturally problemadc7 (if needed, explain any answers in Remarks.)
SUMMARY OF FINDINGS — Attach site map showing sampling polnt locations, transects, important features, etc.
Hydrophydc Vegetation Present? Yes No Is the Sampled Area
Hydric Soil Present? Yes No within a Wetland? Yes_ No
Wetland Hydrology Present? Yes No
Remarks:
`1`iv &0- r4 jvool it Ir t � � �� � 011 i-, ,j iv r OF
HYDROLOGY
Wetland Hydrology Indicators:
Secondary, Indicators (minimum of Cavo required)
Primary Indicators (minimum of one is mrruired•
check all that appal
Surface Soil Cracks (B6)
Surface Water (A-)
_ True Aquatic Plants (1314)
Spars" Vegetated Concave Surface (B8)
High Water Table (A2)
_ Hydrogen Sulfide Oder (Cl)
_ Drainage Patterns (B10)
Saturation (0)
_ Oxidized Rhizospheres on Living Roots (C?)
1C Moss Trim Lines (B16)
Water Marks (B1)
_ Presence of Reduced Iron (C4)
_ Dry -Season Water Table (C2)
_ Sedlmort Deposits (B2)
_ Recent Iron Reduction in Tilled Soils (C6)
_ Crayfish Burrows (CB)
_ Drift Deposits (83;
_ Thin Muck Surface (0)
___. Saturation Visible on Aerial Imagery (C9)
_ Algal Mat or Crust (134)
Other (Explain in Remarks)
_ Stunted or Stressed Plants (131)
Iron Deposits (135)
_ Geomorphic Position (D2)
Inundation Visible on Aerial Imagery (137)
X
_ Shallow Aqullard (D3)
Water -Stained Leaves (139)
_ Microtopographic Relief (D4)
Aquatic Fauna (813)
_ FAC -Neutral Test (06)
Field Observations:
Surrace Water Present? Yes it No
J
Depth (inches): _
Water Table Present') Yes No
Depth (inches):Orl
Saturation Present? Yes X No
Depth (Inches): I r
Wetland Hydrology Present? Yes y No
Incluces capillary fri o
Describe Recorded Data (stream gauge. monitoring well, aerial photos, previous Inspections), if available:
Remarks:
W lamd are
pmenio
6uh1v r Jot �11 u 1 i 6 0 f wea
US Army Corps or Engineers Fasle'n Mountains and Piedmont – Version 2.0

VEGETATION (Four Strata) — Use scientific names of plants.
t Absolute Dominant Indicator
Tree Slfatum (Plot size- \T ) C er ecles? St lus
3. C, tt1 UV ,tV+1 r1_ V Wl t'!1 r" 1 UPS -
7. r.
A.
7.
f� = Total Cover
50% of Total cover: el 0 2096 of total cover._
Sa Ilna •u strAlum (Plot size. 04 4+ 1
1. t'itA11lt1� vilmmWVoyiY(tk !d-
2, T_
3.
4.
6.
7.-
7-
9.
.-9.
= Total Cover
50% of total cover: 1 b _ 20% 61 total cover:
Herb Siralin (Plot size:
Cart t AX ✓ttn �tc� t 1.' c�._ _ -AL
2. �rAi-fJ( Cd[�i�. '�0 may,■
4,
5.
6.
70,
11,
= Total Cover
50% of total cover: 20% of total cover:��
Mt2bdv We Stratum (Plot size: )
1.
2.
3.
4.
5.
Total Cover
50% of total cover: 2o% or total cover
rs hare or on a separate sheet.)
Sampling PDint:IX WIod
Dominance Test worksheet:
Number of Dominant Species 0.41
That Are OBL, FACW, or FAG: I (A)
Total Number of Dominant
Species Across All Strata: (B)
Percent of Dominani Species (� t
That Are OBL, FACW, or FAC: (A/B)
Prevalenco Index worksheet: -
Total % Cover or:
Multla by:
OBL species
K 1
FAM species
x2=
PAC species
x 3
FACU species
,t 4 =
UPL species
x 5 c
Column Totals:
(A) ([3j
PrevaleiceIndox = B/A -
Hydrophytic Vegetation Indicators:
1 - Rapid lest for Hydrophylic Vegelation
_ 2 - Dominance Test Is X50%
_ 3 - Prevalence Index is 53.0'
4 - Morphological Adaplalions' (Podvidu suppaling
data In Remarks or on a separate sheet)
_ Problematic Hydrophytic Vegetation' (EkpjgIn)
'indfcatcrs of hydric soll and wetland hydrology must
be'present, unless disturbed or problematic.
Tree — Woody plants, excluding vines. 3 in. (7.6 cm) or
more in diameter at breast height (DQH), regardless of
height.
Sapling/Shrub - Voody plants. excluding vines, less
than 3 in. DBH and greater than or equal to 3.28 ft (1
m) tall,
Herb —All herbaceous (non -woody) plants, regardless
of size, end woody plants less than 3,29 ft tall.
Woody vine — All woody vines greater than 3.28 ft in
Hydrophytic
vegetation
Present? Yes A— Wo
10010 D'r N QJmu�altir VP��nfian 6(6'FAC or
Od-�VA
US Army Corps of Engineers Eastern Mountains and Piedmont- Version 2 0

SOIL
Sampling Paint: tJ71- who)rr��,
Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.)
Depth Rtalrix Redox Features
Ilnches) Color (moist) __ &___ color (moist) _ ' Tour ' oc _ TvAurr_ Remarks
iq_�pa
'T e: C -Concentration. D=De lotion, RM=Red iced Matrix, MS -Masked Sand Grains. zLocabon: PL -Pore Uni , M=Malrix.
Hydric Soil Indicators:
Indicators for Problematic Hydric Soils':
_ Histosal (Al)
_ Dark Surface (S7)
_ 2 cm Muck (A10) (MLRA 147)
_ Histic Epipedon (A2)
_ Paiyvalue Below Surface (S8) (fALRA W. 148)
_ Coast Prairie Redox (A76)
_ Black Hrslir, (A3)
_ Thin Dark Surface (S9) (MLRA 147, 148)
(MLRA 147, 148)
_ Hydrogen Sulfide (A4)
_ Loamy Gleyed Matrix (F2)
_ Piedmont Floodplain Solis 0-'l 9)
_ Stratified Layers (A5)
XL Depleted Matrix (F3)
(MLRA 136.147)
_ 2 cm Muck (Al 0) (LRR N)
_ Redox Dark Surface (FB)
" Very Shallow Dark Surface (TF12)
— Depleted Below Dark Surface (All 1)
_ Depleted Dark Surface (F7)
_ Other (Explain in Remarks)
_ Thick Dark Surface (Al2)
_ Redox Depresslons (F8)
_ Sandy Mucky Mineral (Si) (LRR N,
_ Iran -Manganese Masses (F12) (LRR N,
MLRA 147. 148)
MLRA 136)
_ Sandy Gleyed Matrix (S4)
_ Umhric Surface (F13' (MLRA 136,122)
'Indicators of hydrophytic vegetation and
_ Sandy Redox (S5)
_ Piednront Floodplain Soils (1719) (MLRA 148)
wetland hydrology must be present,
_ Str:pped Matrix (SG)
_ Red Parent Material (1721) (MLRA 127, 147)
unless disturbed or problematic.
Restrictive Laver (if observed):
Type:
Depth (inches):
Rema•ks:
I I It. (11., , , . ,
lmlfrjl�if
Hydrlc Soil Present? Yes Y_ No
US Army Corps of Engineer; Eastern Mountains and Piedmont – Version 2.0

WETLAND DETERMINATION DATA FORM — Eastern Mountains and Piedmont Region
Projecrisite: CitylCouniy t "i Sampling Date: �•
ApplicanUOvmer (^ T State: N Sampfino Point -_JD• l) ��, If k�
Investigator(s): _ �Q 1vi it t I, lul Section. Township, Range: Ir_n t) 1 V , e
Landform (hillslope, terrace, etc.): _Illy 5 �/X`. ,! r, Local rollef+(concave, convex, none)- dt�1 t1 V,(— Slope (%}:
Subregion (LRRo RLRI. 1`�tID Lat:. i . Tin (;1o1 Long:' rk (If. �+,� Dalumi l
Soil Map Unit Namet 1P I' I • r f J 1 t' • '4 NWI classification: Ah
Are Climatic l hydrologic conditions on the ite typical for this time of year? Yes No (If no, explain in Remarks.)
Are Vegetation Soft or Hydrology signiflcantly disturbed? Are'Narmal Circumstances" present? Yes -X- No
Arc Vegetetbn Soil or Hydrology naturally problematic? (If needed explain any answers in Remarks.)
SUMMARY OF FINDINGS -- Attach site map showing sampling point locations, transects, important features, etc.
Hyd(ophytic Vegetation Present? Yes No --X_ is the Sampled Area
Hydric Sof) Present? Yes No—X'_ within a Wetland? Yes No X
Wetland Hydrology Present? Yes No_
Remar<s:
f
HYDROLOGY
Wetland Hydrology Indicators:
Secondary Indicators (minimum of two rea0adl
P, Itnafy Ingicaigirs (min4mum of one is
• check all That a I
_ Surface Soil Cracks (86)
_ Surface Water (Al)
� True Aquatic Plants (1314)
_ Sparsely Vegetated Concave Surface (86)
High Water Table (A2)
_ Hydrogen Sulfide Odor (Cl)
_ Drainage Patterns (910)
_ Saturation (A3)
_ Oxidized Rhizospheres an Living Roots (0) _ Moss Trim Lines (1316)
_ Water Marks (B1)
_ Presence of Reduced Iron (C4)
_ Dy -Season Water Table (C2)
_ Sediment Deposits (82)
_ Recent Iron Reduction in Tilled Soils (C6)
_ Crayfish BLrrows (C8)
_ DrIR Deposits (133)
_ Thin Muck Surface (C7)
_ Saturation Visible on Aerial Imagery (C9)
Algal Met or Crust (B4)
Other (Explain in Remarks)
_ Stunted or Stressed Plants (41)
_ Iron Deposits (135)
_ Geomorphic Position (D2)
_ Inundation Visible on Aerial Imagery
(B7)
— Shallow Aquitard (D3)
_ Water -Stained Leaves (89)
_ Microtopographic Relief (D4)
_ Aquatic Fauna (B -i 3)
_ FAC -Neutral Test (D5)
Field Observations:
Surface Water Preseil? Yes
No Depth (Inches):
Water Table Present? Yes
No_Y Depth (Inches):
Saturation Present? Yes
No Depth (inches):
Wetland Hydrology Present? Yes No
(Includes ca illar• fringe)
Describe Recorded Data (stream gauge, munitoring well, aerfal photas, prevhvus Inspectlans). If available:
Remarks:
4%
/
Vy flifl'
US Army Corps of Engineers Eastern Mountains and Piedmont – Version 2.0

VEGETATION (Four Strata) - Use scientific names of plants.
f Absolute Dominant Indicator
Tree Stratum (Plot site: )6 i* ) Cover Species? Status
1. k1 my► ! Mao,
2. --rIrl -
5.
6.
7.
= Total Cover
50% of tdtal cover:_ 20% of total cover:�.�
SaplingiShrub Stratum' (Plot size: 15 f__4 t
2.,� If V1I1W Y to f V1('Q6611nV1A
3.
4.
7, -
8. - - -
9,
_�� ) = Total Cover
Og116 of total cover. 1! ' � 2D% ar total cover:
__
Hrr :rattan (Plot size: 10 � 1• ) is C
1.AI1;M), VIt%e'ejf 7 Phta
2- 261ll10Ax ��ti�t;nrlf�":,Itr,�,• (b far"
3.. 01,11(LY'A - '1 _
4.lit_ 6 M v3 rQ 4 + tYy% re �_ _A g
5.
7. -
10.
11.
n Total Cover
0% of t tal cover: _,-Is 20% of total eager:( 0
Woody vine SUa um (Plot size: l A )
1• _
2.
3.
4.
Sampling Point: �'� i i+) I'I�
Number of DominantSpecios
Thal Are OHL, FACW, or FAC: (A)
Total Number of Dominant
Species Across All SIrate: 49 (B)
Percent of Dominent Species rl
�
That Are OBI-, FAC%V, or FAC: 3�, _ _ - (A!B)
Prevalence Index worksheet:
Talal % Cover of: •
multiply bvby:-
OHL species
x 1 =
FACW species
x 2 =•
FAC species
x3=
FACU species
x 4 =
UFL species
x 5 =
Column Totals:
(A) (B)
Prevalence Index =
B/A a
Hydrophytic Vegetation Indicators:
1 - Rap;d Test for Hydrophytic Vegetation
2 - Dominance Test is ?5046
_ 3 - Prevalence Index is 53,01
4 . Morphological Adaptations' (Provide supporting
data In Rcmarks or on a separate sh-oco
_ 'Problematic Hydrophytic.Vegetation' (Explain)
llnd Gators of hydric soil and wetland hydrology must
be p esenl, unless disturbed or problematic.
Definitions of Four Veaetation Strata:
Tree - Woody, plants, excluding vines, 3 In. (7.6 cm) of
more In diameter at breast height (DBI'I), regardless or
height.
SaplinglShrub - Woody plants, excluding vines, less
than 3 in. DBH and greater than or equal to 3.28 ft (1
m) tall.
Herb.- All herbaceous (non -woody) planet, regardless
of sizo, and wpody plents less than 3.28 ft tall,
woody vine - All woody vines greater than 3.28 ft In
s - Hydrophytic
Vegetation
= Total Cover Present? Yes No
56% of total cover: 20% of total cover;
Remarks: (Irtciudo photo members here or on a separate sheet.)
of 4v, dowflow vtvafjr()Y� cirt jf Mier,
US A'my Corps of Engineers Zasteed Mauntalr sand Piedmont - Version 2.0

SOIL
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Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.)
Depth Matrix Redox Features
'finches) , Color (moist) % Celer (moist) Tvne Texiure Remarks
'T e: G --Concentration. D=Do lesion, RPA=Reduced Vlatrixj"S=Masked Sand Grains, ZLccawn: PL -Pore Lining. M=Malrix
Hydric Soil Indicators:Indicators
for Problematic Hydric Soils°:
_ 'Irstosol (Al)
` Dark Surface (57)
2 cm Muck (A10) (MLRA 147)
_ Histic Eplpedo►t (A2)
— Pblyvaluc Below Surface (56) (PALRA 147, 140)
_ COW Prairie Redox (A16)
_ Black Hisft (A3)
— Thin Dark Surface (S9) (MLRA 147,14S)
(MLRA 147,148)
_ Hydrogen Sulfide (A4)
____ Loamy Gley ed Matrix (F2)
_ . Piedmont Floodplain Soils (Fig)
— Stratified Layers (A6)
— Depleted Matrix (F3)
(MLRA 13k 147)
— 2 cm Mdck 0101 (LRR N)
_ Redox Dark Surface (176)
— Very Shallow Dark Surface (712)
_ Depleted Below Dark Surface (All)
_ Depleted Dark Surface (F7)
_ Other (Fxplain in Remarks)
— Thick Dark Surface (Al2)
_ Redox Depressions(Fe)
_ Sandy Mucky Mineral (Si". (LRR N,
_ (ron-Manganese Masses (F7 2) (LRR N,
MLRA 147,146)
MLRA 136)
Sandy Gleyed Matrix (S4)
= Umbric Surface (Fl 31 (MLRA 136,122)
'Indicators of hydrophytic vegetation and
_ Sandy Redox (55)
i Piedmont Floodplain Sails (F19) (MLRA 148)
wetland hydrology must be present,
_ S_ripped Matrix (56)
_ Red Parent Material (F21) (MLRA 127, 147)
unless disturbed or problematic.
Restrictive Latvr (if observed):
Type:
Depth (inchas): Hydric Soil Present? Yes
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U5 Army Corps of Engineers Eastern Mouhlain$ and Piedmont— Version 2.0
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NORTH CAROLINA DEPARTMENT OF NATURAL AND CULTURAL RESOURCES
Pat McCrory Bryan Gossage Susan Kluttz
Governor Executive Director Secretary
Clean Water Management Trust Fund
February 24, 2016
Kaitlin McCulloch
Carolina Wetlands Inc
550 East Westinghouse Blvd
Charlotte, NC 28273
kaitlin@cws-inc net
RE- Norton Site, 2016-3867
Dear Kaitlin McCulloch:
NCNHDE-1284
The North Carolina Natural Heritage Program (NCNHP) appreciates the opportunity to provide information
about natural heritage resources from our database that have been compiled for the project referenced
above
A query of the NCNHP database, based on the project area mapped with your request, indicates that there
are no records for rare species, important natural communities, natural areas, or conservation/managed
areas within the proposed project boundary. Please note that although there may be no documentation of
natural heritage elements within the project boundary, it does not imply or confirm their absence; the area
may not have been surveyed. The results of this query should not be substituted for site-specific surveys
where suitable habitat exists In the event that rare species are found within the project area, please contact
the NCNHP so that we may update our records.
The attached 'Potential Occurrences' table summarizes rare species and natural communities that have
been documented within a one -mile radius of the property boundary The proximity of these records
suggests that these natural heritage elements may potentially be present in the project area if suitable
habitat exists and is included for reference.
Tables of natural areas and conservation/managed area within a one -mile radius of the project area, if any,
are also included in this report. The location of the natural areas and conservation/managed areas can be
viewed online on the Natural Heritage Data Explorer found at: https:Hncnhde.natureserves[gL
Please note that natural heritage element data are maintained for the purposes of conservation planning,
project review, and scientific research, and are not intended for use as the primary criteria for regulatory
decisions Information provided by the NCNHP database may not be published without prior written
notification to the NCNHP, and the NCNHP must be credited as an information source in these publications.
Maps of NCNHP data may not be redistributed without permission.
The NC Natural Heritage Program may follow this letter with additional correspondence if a Dedicated Nature
Preserve (DNP), Registered Heritage Area (RHA), or Federally -listed species are documented near the
project area.
If you have questions regarding the information provided in this letter or need additional assistance, please
contact John Finnegan at gov or 919 707 8630
Sincerely,
NC Natural Heritage Program

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