20100899 Ver 3_Corps Response Final - all Attachments 6-7-17_20170607

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Submit by Anonymous User 6/7/2017 5:34:04 PM (Supplemental Submital)
Accept by Montalvo, Sheri A 6/8/2017 8:40:58 AM (NON -DOT Project)
• The task was assigned to Montalvo, Sheri A 6/7/2017 5:34 PM

Water Resources
ENVIRONMENTAL QUALITY
Staff Review:
Updated ID#: 20100899
Updated Version: 3
Reviewers Email Address:
Sue. [e-mail]
Submitted Information:
Is this a public transportation
project?
f Yes
r No
What type of project is this?
F Existing Project
r Pre -Application Information
Existing Project Information:
..................................................................................................................................................................
ID# 20100899
DARR/DAG Minter (exarrple 20150001)
Version: 3
Project Name: Clearwater paper
County: Cleveland
Name: Clement Riddle
Who is subnitting the information?
Email Address: [e-mail]
Describe the
attachments:
Please upload all files that need to be submited.
Corps Response Final - all Attachments 6-7-17.pdf 39.55MB
Only pdf files are accepted.
W By checking the box and signing box below, I certify that:
Q I have given true, accurate, and complete information on this form;
Q I agree that submission of this Supplemental Information form is a "transaction" subject to Chapter 66, Article 40 of the
NC General Statutes (the "Uniform Electronic Transactions Act")

• I agree to conduct this transaction by electronic means pursuant to Chapter 66, Article 40 of the NC General Statutes
(the "Uniform Electronic Transactions Act');
• I understand that an electronic signature has the same legal effect and can be enforced in the same way as a written
signature; AND
o I intend to electronically sign and submit the Supplemental Information form.
Signature:
' �t

CLearWaLer
Cleat -Water Environmental Consultants, Inc.
www.cwenv.com
June 5, 2017
Mr. David Shaeffer
US Army Corps of Engineers
151 Patton Avenue, Room 208
Asheville, North Carolina 28801
RE: Response to Corps Comments
Clearwater Paper Corporation
Cleveland County, North Carolina
Action ID SAW -2014-00061; DWQ Project # 10-0899 v3
Dear Mr. Shaeffer,
Please reference the letter dated April 24, 2017 (Attachment A) sent by the US Army
Corps of Engineers (Corps) in response to the permit application submitted by
C1earWater Environmental Consultants, Inc. (CEC), on behalf of the Clearwater Paper
Corporation represented by Mr. Brian Hoaglund. The permit application requested
written authorization for the impacts associated with expansion of the existing Clearwater
Paper facility and associated infrastructure. The comments provided and relayed by the
Corps are listed and discussed below.
As requested CEC is submitting separate written responses to comment comments from
the NC Wildlife Resources Commission (WRC), US Fish and Wildlife Service and the
NC Division of Water Resources. These response letters are enclosed with this submittal
for your reference.
Based on further refinements to the site plan (Attachment B - Figure 6) proposed stream
impacts amounts have changed at impact locations 1, 2, and 3. The proposed permanent
stream impact grand total submitted in February 2017 was 1,6821f. of stream impact and
0.12 acres of wetland impact. The new proposed impacts based on the refined site plan is
1,599 If. There are no changes to the proposed wetland impacts. These changes are
further explained in Comment 3 section below.
Comments Provided by the Corps
Corps Comment #1 - "Multiple siting criteria are discussed in the application.
However, the criteria is vague and cannot reasonably be used to compare offsite
alternatives to determine whether they are reasonable or practicable. For example, the
minimum property size requirement necessary to fulfill the overall project purpose is not
clear. In terms of property availability, it is unclear how close the facility must be to the
32 Clayton Street
Asheville, NC 28801
828-698-9800 Tel

Mr. David Shaeffer
June5,2017
Page 2 of 10
existing facility to satisfy the overall project pwpose. Additionally, it is not clear how far
the facility needs to be from railways, interstates, existing utilities, and the existing labor
force. In terms of cost efficiency, it is unclear what constitutes a reasonable cost for a
project of similar type, scope, and size. Please revise the siting criteria accordingly. "
The siting criteria has been revised clarified as requested. Expansion of paper making
and converting capacity is essential for CWP. CWP in this application and the previously
authorized Individual permit emphasized the importance of adding to the existing
facilities capability rather than building a new stand-alone paper mill. There are
numerous advantages to this approach as stated previously.
A. Property Size CWP needed to identify a site that was large enough for expansion.
The property size was expected to be between 200 and 300 acres depending on
the shape of the parcel and access corridors for rail and trucks. The selected site,
along with the former Tampa Warehouse property (25 acres) totals approximately
261 acres.
B. Property Availability - CWP analyzed property immediately adjacent to the east
of the existing facility and reviewed the 46 -acre parcel owned by Cleveland
County adjacent and to the west of the existing facility. No other sites were found
to be available and in close proximity to the existing facility that would allow for
efficient expansion. As requested (pers. Com David Shaeffer, Corps) additional
information regarding off-site alternatives considered is provided in response to
Corps comment #2 below. The currently proposed alternative site was not
available for purchase in 2011 or during the permitted expansion plans of 2015.
C. Access to Rail - CWP must have direct access by rail directly to the mill. It is
cost prohibitive to bring pulp in by truck. All CWP pulp comes in by rail to this
facility and all of the paper making operations in the consumer products division
are rail served (Las Vegas NV, Lewiston ID, Neenah WI, Ladysmith WI, Shelby
NC.) All cars are contained on existing property for loading and unloading.
CWP expects the new facility to receive 15 or more rail cars per week expanding
to 30 or more at full buildout. To utilize trucks for this volume would be cost
prohibitive.
D. Access to interstate - The site must be close and have ready access to major 4 lane
highways/interstates. All CWP facilities are within five to ten_ miles of major
highway/interstate access.
E. Access to Utilities - CWP needs access to significant utilities that are typical for
large industrial users. All the utilities, electricity, water, gas, and sewer are
readily available and will meet the CWP demand with minimal upgrades. There
is no major expansion needed to electric, sewer, gas, water service providers (.ie.
power plant, WWTP, etc.)

Mr. David Shaeffer
June 5, 2017
Page 3 of 10
F. Access to an Existing Labor Force - One goal of manufacturing is to keep
production costs low so that costs for final products remain desirable for
consumers. This allows customers to purchase necessary goods at a reasonable
price while manufacturers make a reasonable profit. One way to minimize the
cost of consumer goods is to minimize the size of the labor force. Expanding an
existing facility is desirable because the labor force is already present. Clearwater
Paper would likely hire additional shift workers; however, other staff members,
such as management, would be able to expand their scope of work to include the
expansion and additional manufacturing. Constructing a new facility, in a new
location, would require an entire new labor force. Additionally, a minimized
labor force equates to less parking which leads to less land disturbance and less
environmental impact. Consideration of the labor force is of high importance to
Clearwater Paper and their continued operation.
G. Proximity to Target Market - Our facilities generally serve a market within a 500 -
mile radius of the plant in order to economically ship finished products to our
customers. There are exceptions to this depending on market demand and
capacity/capability of individual operations which require us to transfer product
between facilities (not desirable).
Clearwater Paper's Shelby facility provides tissue paper distribution for the
southeast. Additional manufacturing capability needs to be located in the market
needing supply (in this case, the southeast). Existing Clearwater Paper facilities
do exist out-of-state; however, utilizing these facilities for southeast production
and distribution would not be feasible or cost efficient. The closest tissue
converting facility is in Elwood, IL approximately 728 miles from Shelby, NC.
And, the closest papermaking facility is in Neenah WI approximately 915 miles
from Shelby, NC. In either instance, material would need to be freighted to
another facility to complete the manufacturing process and then freighted back to
Shelby for distribution to the southeast. Paper products are bulky, heavy, and
easily damaged making them expensive to transport. This factor dictates that the
facility be located relatively close to the market it supplies (southeast) in order to
decrease freight cost to the consumer.
H. Cost Efficiency - In terms of cost efficiency, it is unclear what constitutes a
reasonable cost for a project of a similar type, scope, and size.
The technology is owned by the original equipment manufacturer (OEM). The
products made and the receipt of manufacture are proprietary. Thus, the cost
efficiency in management of personnel, raw material and logistics makes having
sites close together advantageous. This particular site also has favorable
topography to meet our operational and maintenance needs of having a basement
that is at grade making it possible to drive into the basement for maintenance and
delivery of key raw materials.

Mr. David Shaeffer
June 5, 2017
Page 4 of 10
Additional factors the applicant would like to add to the site selection criteria include the
following:
I. Presence of Streams - It is likely that any large tract of land in western North
Carolina would contain significant amounts of streams. However, the applicant
wanted to avoid any tract that had a disproportionately high amount of stream
resources when compare to other tracts of similar size.
The proposed expansion site is of the size required to house manufacturing equipment; is
available; has access to rail, utilities, and an existing labor force; and is located in the
target market area. The project as proposed is the least damaging practical alternative
and meets the project purpose and needed.
Corps Comment #2 - During our onsite pre -application meeting on September 21, 2016,
Mr. Brian Hoaglund of Clearwater Paper Corporation stated that multiple offsite
alternatives within the market area were being considered for the proposed project.
However, the application only discusses using existing offsite facilities already owned by
the applicant and outside of the market area. Please explain the efforts that have been
taken by the Clearwater Paper Corporation to locate other offsite alternatives within the
market area. Please explain whether these alternatives are reasonable or practicable in
light of the siting criteria and the overall project purpose. It may be helpful to create a
map that shows the extent of the market area, the location of the proposed site, and the
location of other similar sites within the market area.
Clearwater has been considering an expansion in the southeast since 2014 when
CWP applied for and received the 401/404 permit from the Corps for (1,8821£ of
stream impact) adjacent to the existing facility. However, since that time CWP
business in the SE continues to grow along with the size of the planned expansion
(existing facility IMM SF, new facility 1.5MM SF with space to double that in
the future). Because it is critical to our business that our paper making facilities
not only have the utility infrastructure to support the operation (water, sewer, gas,
electricity) but also have access to interstates and rail, the available options are
very limited. The most efficient option for us is expansion on the existing site to
capitalize on existing infrastructure, administrative/supervisory staff, raw material
handling. However, using the existing permit and expanding on the existing site
was ruled out at this time because the space available was not adequate to support
the new production requirements. The next best option is to expand in as close
proximity to the current operation to leverage synergies to the extent possible.
Therefore, Clearwater selected the 236 -ac site across the street.
It is important to note that the Corps recently (2015) issued a 404 permit to CWP
authorizing impacts to streams adjacent to the new the existing mill which are
greater impacts than are now being proposed across the street.
See Attachment C for the Alternative Analysis Supplement

Mr. David Shaeffer
June 5,2017
Page 5 of 10
Corps Comment #3 - Please submit a consolidated set of plans that depict, in detail, all
proposed impacts to waters of the United States associated with the proposed project.
This includes all impacts associated with the proposed Clearwater Paper facility as well
as the impacts associated with the required utility improvements and expansions. The
plans should include all temporary and permanent impacts including rock dissipation
pads if applicable and all fills for temporary access and dewatering. The plans should be
sequentially numbered and dated.
The applicant has completed a more detailed site plan (Figure 6) and this includes
additional impacts associated with the placement of rip -rap. A set of updated
impacts plans is attached:
• AFW— Site Plan Figure 6 and SKT-0002- SKT-0010 (Attachment B)
• TGS Engineers- Entrance Road Figures 1-5 (Attachment D)
• McGill Associates — Gravity Sewer Line Figures - (Attachment E)
Impact 1 - TGS Engineers have completed the entrance road design from
Farmville Road into the site. This road crosses the unnamed tributary to Brushy
Creek. The permit application originally proposed 200 linear feet of impact.
However, after final design by TGS, stream impacts associated with this crossing
will be 250 ft. for the culvert impact and 20 feet of imbedded rip -rap (Attachment
C - Road Crossing Details: Sheets 1-5).
The culvert will be installed in accordance with DWR, Water Quality
Certification 3890 (Condition 13) and any conditions imposed by the US Army
Corps of Engineers (Corps). These conditions include requirements to cross
streams at perpendicular angles; and provisions for maintenance of stream
dimensions and aquatic life passage.
Impact 2 — AFW engineers have refined the site plan (Figure 6) and Impact 2 has
been reduced from 910 linear feet to 737 if. of fill impacts and 73 If. of imbedded
rip -rap for stream protection. Outlet protection detail are provided in the SMP
submitted by AFW (Figure SKT-0006).
Impact 3 — AFW engineers have refined the site plan (Figure 6) and Impact 3 has
increased from 468 linear feet to 473 if of fill and 25 if of imbedded rip -rap for
stream protection Outlet protection detail are provided in the SMP submitted by
AFW (Figure SKT -0005).
The gravity sewer line design plans have been completed by McGill Associates
and are included in Attachment D. Updated Figure 8 is also included in
Attachment D. Please note that during final design temporary impacts to streams
have been reduced from 214 If of temporary impact to 80 ]f. Stream impacts were
reduced at four location by shifting the alignment to avoid streams and by
designing 4 aerial crossings. Temporary impacts to wetlands have stayed the
same. Two existing 20 ft. culverts within the easement will be replaced following

Mr. David Shaeffer
June 5, 2017
Page 6 of 10
NWP 3 maintenance guidelines (Sheets C-102 and C-111). Wetland areas with
temporary impacts will be regraded to the original contour and covered with a
wetland seed mix (Sheet (C- 504). The stream bed and banks will be restored
(Sheet C-505) following temporary impacts.
The proposed gravity sewer line alignment was selected to be parallel to the
City's existing gravity sewer line so that the new sewer line can generally remain
within the existing utility easement and limit ground disturbance to within the
existing City right-of-way (ROW). This alignment also allows for the most
efficient sewer flow by minimizing turns in the sewer line that require additional
manholes. This parallel alignment also minimizes the width of the utility
easement. In the three location that the crossings are not within DWR's definition
of "approximately perpendicular," the crossings are in small streams and the
temporary impacts to the streams and bank stabilization should not be significant.
To change the alignment for these three crossing would require
purchase/condemnation of additional ROW and the addition of two new manholes
for each crossing.
Corps Comment #4 - "It appears that land outside of the boundaries of the preliminary
jurisdictional determination issued on January 23, 2017, has been added to the project
area. This land includes but is not limited to the parcel identified as parcel identification
number2528109438. "
CWP purchased 2 parcels (2528109438 and 2528201705) formerly owned by
Tampa Warehouse. These parcels include an existing warehouse which is owned
and occupied by CWP operations which will be incorporated into the expansion
facility. A jurisdictional delineation for this property was conducted on May 2,
2017 and it is the opinion of CEC that the entire site is uplands. A copy of the
delineation map and request for Preliminary Jurisdictional Determination are
included with this submittal (Attachment F).
Corps Comment #5 - We have determined that, if the permit is issued and credits are
purchased from the North Carolina Division of Mitigation Services, compensatory
mitigation at a ratio of 0.5:1 would be required for the low quality intermittent stream
impacts, a ratio of 2:1 for high quality perennial stream, a ratio of 1.75:1 for medium
quality perennial stream, and a ratio of 0.75:1 for medium quality intermittent stream.
Please revise the mitigation plan accordingly and submit a final mitigation proposal.
Below is an updated table indicating the required mitigation.

Mr. David Shaeffer
June 5, 2017
Page 7 of 10
Impact
Total New Impact
Revised Compensatory
Mitigation Ratio
(x: I)
Basic Mitigation
Requirement
Previous Impact
104 LF (perennial)2:1
208 LF
Impact #la
250 LF (perennial)1.75
437 LF
Impact lb outlet protection
20 (perennial)0
0
Impact #2a
737 LF(perennial)
1.75:1
1290 LF
Impact 2b outlet protection
94
0
0
Impact #3
410 LF(perennial)
1.75:1
717 LF
Impact 3b outlet protection
25
0
0
Impact #3
63 LF intermittent
0.75:1
47 LF
Total Perennial Impact
1-16-40- LF
Total Intermittent Impact
63 LF
Grand Total Im acts
1 703 LF
Total Mitigation Re uired
2,699 LF
The applicant is not proposing wetland mitigation due to the minimal amount of
wetland impacts.
Corps Comment #6 - "It appears that outbuildings and/or parking areas located at the
northeast corner of the main building could be moved to the southwest of the main
building to avoid or minimize impacts 3 and 4. Please revise the plans to avoid these
impacts or provide a detailed explanation of why it is not practicable to avoid or
minimize these impacts. "
The updated site plan has reduced overall prosed stream impacts for the site. The
office, main entrance, and employee parking areas are all located in the
northeastern section of the mill and are aligned with the converting operation
where roughly 2/3 of the mills employees work. The access road and parking for
300 employees is located in this area. In addition, there must be sufficient area in
the northeast comer for loading and unloading trucks, truck parking, and turning
radius for large trucks. This mill configuration is consistent with the design of the
current operation across the street. Figure SKT-0010 (Attachment 13) provides
cross section details of the building site in the northeast corner. Due to the
presence of the stream at proposed impact 3 the applicant is constructing an
approximately 22 -foot -high retaining wall to minimize slope fill, stream impact,
and still provide employee parking area and truck access for the mill. The access
road in the northeast corner begins almost 30 feet below the finished elevation of
the mill and employee parking areas.
The property will be developed in phases from north to south, so the "southwest
comer" will move to the southern boundary of the facility as the operation
expands. It should be noted that the initial plan for the site included 3 paper
machines with associated converting and warehouse operations. This plan was

Mr. David Shaeffer
June 5, 2017
Page 8 of 10
scaled back to 2 machines and the entire facility was moved as far south as
practical on the property to minimize stream and wetland impacts.
In the early stages (July 2011) of acquiring property for this project Cleveland
County engaged a real estate broker to assist with negotiations in an effort to
acquire and assemble property for future industrial development. Over the next
six months the County was able to acquire approximately 348 acres which
included the following parcels (40797, 32624, 32196, and 61941). During this
same period, the broker of record met with the owners of Parcel 73679 (35.68
acres), Parcel 28687 (33.469 acres) and Parcel 51545 (30.145 acres) on multiple
occasions in an effort to negotiate the acquisition of said property on behalf of
Cleveland County. All three of these parcels are located adjacent to and on the
south side of the project. Negotiations were unsuccessful as owners of the parcels
identified were not interested in selling the property. As a result, Cleveland
County suspended further negotiations and efforts to acquire additional adjacent
property for future industrial development. Ownership of the property has
remained unchanged except for the acquisition of right-of-way purchased by the
NC Department of Transportation necessary for the construction of the Hwy 74
Bypass. Given the land development constraints of gradings, roads, railroad
elevations and access, it is not possible to move the project any further to the
south and avoid additional streams.
The pre -application showed a conceptual future road connection from the project
site to the new US Highway 74 By-pass. However, this conceptual plan is not
possible because property to the south is not owned by CWP, Cleveland County
or DOT.
The applicant believes the information submitted in this package addresses all issues set
forth by the Corps in their letter dated April 24, 2017. Should you have any questions or
comments concerning this project please do not hesitate to contact me at 828-698-9800.
Sincerely,
61egtRJddle, P.W.S.
Principal
Attachment A - Corps Letter
Attachment B - AMEC Plan Figure 6
Attachment C - Alternative Analysis Supplement
Attachment D — TGS Engineers Road Figure 1-5
Attachment E — McGill Associates Gravity Sewer Line Figures
Attachment F — Tampa Warehouse JD Package

Attachment A
Corps Comments
(dated April 24, 2017)

Regulatory Division
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
151 PATTON AVENUE
ROOM 208
ASHEVILLE, NORTH CAROLINA 28801-5006
Action 1D: SAW -2010-00061
Mr. Jeff Richardson
County Manager
Cleveland County Government
Post Office Box 1210
Shelby, North Carolina 28151
Dear Mr. Richardson:
April 24, 2017
Please reference the application for an Individual Department of the Army (DA) Permit
submitted on your behalf on February 2, 2018, by Clearwater Environmental Consultants,
Incorporated to discharge fill material into 1,792 linear feet of stream and 0.062 acre of wetlands
associated with the expansion of the Clearwater Paper Shelby tissue manufacturing facility. The
proposed project includes the construction of a 2.5 million square foot building as well as the
installation and/or improvement of surrounding private and municipal utilities. Cleveland County
has elected to be the applicant for the proposed project because the project area is currently
owned by the County and the sewer and water lines will be owned and managed by the County.
The project site is located 0.5 miles southeast of the intersection of West Cabaniss Road and
Farmville Road in Shelby, Cleveland County, North Carolina.
The project was advertised by public notice on February 17, 2017. Comments in response to
the notice were received from the National Marine Fisheries Service, the U.S. Fish and Wildlife
Service (USFWS), the North Carolina Department of Cultural Resource, the North Carolina
Wildlife Resources Commission (NCWRC), the North Carolina Division of Water Resources
(NCDWR), and the U.S. Fish and Wildlife Service (USFWS). These comments are enclosed for
your information. Please provide written responses to the comments submitted by the NCDWR,
the NCWRC, and the USFWS.
In addition to conducting a public interest review which balances the reasonably expected
benefits against the reasonably foreseeable detriments, all Clean Water Act (CWA) Section 404
permits must meet guidelines for the specification of disposal sites for dredged or fill material
under CWA Section 404(b)(1). These comments are being submitted pursuant to the Clean
Water Act Section 404(b)(1) guidelines (40 CFR 230).

-2 -
With respect to the project purpose, its analysis is a critical first step in the Corps permitting
process. The Corps is responsible in all cases for independently defining the project purposes
from both the applicant's and the public's perspective. Initially, the Corps evaluates a project's
"basic purpose" to assess whether the project is water dependent. Once the Corps has determined
the water dependency of the project, it no longer considers the basic project purpose, but
analyses practicable alternatives in light of the "overall project purpose". The overall project
purpose must be specific enough to define the applicant's need, but not so restrictive as to
preclude an analysis of reasonable alternatives.
The basic project purpose stated in the application is to make and convert tissue paper into
usable products for the home and commercial markets. The overall project purpose stated in the
application is to expand tissue paper making and converting capacity to meet market demands. In
considering the overall project purpose, we have determined that this project purpose is too
vague. Accordingly, we have determined that the overall purpose of this project is to expand
tissue paper making and converting capacity to meet the Southeastern United States market
demand.
We have completed our initial review of the application and determined that the following
additional information is necessary to expeditiously complete our permit decision:
The application states that Clearwater Paper Corporation was willing to consider sites
other than the proposed project site for the development of the proposed facility.
Multiple siting criteria are discussed in the application. However, the criteria is vague
and cannot reasonably be used to compare offsite alternatives to determine whether
they are reasonable or practicable. For example, the minimum property size
requirement necessary to fulfill the overall project purpose is not clear. In terms of
property availability, it is unclear how close the facility must be to the existing
facility to satisfy the overall project purpose. Additionally, it is not clear how far the
facility needs to be from railways, interstates, existing utilities, and the existing labor
force. In terms of cost efficiency, it is unclear what constitutes a reasonable cost for a
project of similar type, scope, and size. Please revise the siting criteria accordingly.
2. During our onsite pre -application meeting on September 21, 2016, Mr. Brian
Hoaglund of Clearwater Paper Corporation stated that multiple offsite alternatives
within the market area were being considered for the proposed project. However, the
application only discusses using existing offsite facilities already owned by the
applicant and outside of the market area. Please explain the efforts that have been
taken by the Clearwater Paper Corporation to locate other offsite alternatives within
the market area. Please explain whether these alternatives are reasonable or
practicable in light of the siting criteria and the overall project purpose. It may be
helpful to create a map that shows the extent of the market area, the location of the
proposed site, and the location of other similar sites within the market area.
Alternatives that are determined to be reasonable and practicable will be compared
with the applicants preferred alternative to determine the least environmentally
damaging practicable alternative as required by the 404(b)(1) guidelines.

-3-
3. Please submit a consolidated set of plans that depict, in detail, all proposed impacts to
waters of the United States associated with the proposed project. This includes all
impacts associated with the proposed Clearwater Paper facility as well as the impacts
associated with the required utility improvements and expansions. The plans should
include all temporary and permanent impacts including rock dissipation pads if
applicable and all fills for temporary access and dewatering. The plans should be
sequentially numbered and dated.
4. It appears that land outside of the boundaries of the preliminary jurisdictional
determination issued on January 23, 2017, has been added to the project area. This
land includes but is not limited to the parcel identified as parcel identification number
2528109438. Please revise the waters of the United States delineation to include the
entire project area.
We have evaluated the conceptual compensatory mitigation proposal included in the
application. We have determined that, if the permit is issued and credits are purchased
from the North Carolina Division of Mitigation Services, compensatory mitigation at
a ratio of 0.5:1 would be required for the low quality intermittent stream impacts, a
ratio of 2:1 for high quality perennial stream, a ratio of 1.75:1 for medium quality
perennial stream, and a ratio of 0.75:1 for medium quality intermittent stream. Please
revise the mitigation plan accordingly and submit a final mitigation proposal. A final
mitigation plan is required before we can make a decision on the individual permit
application.
6. It appears that outbuildings and/or parking areas located at the northeast comer of the
main building could be moved to the southwest of the main building to avoid or
minimize impacts 3 and 4. Please revise the plans to avoid these impacts or provide a
detailed explanation of why it is not practicable to avoid or minimize these impacts.
The NCDWR has also expressed this concern in their comment letter dated March 9,
2017 (item 3).
Additionally, if an individual DA permit is issued for the proposed project, the Individual DA
Permit issued on June 25, 2015, under the file number SAW -2010-00061 will no longer be valid
because the proposed project would satisfy the purpose of that project.
The information requested above is essential to the expeditious processing of the application; please
submit one consolidate response to all comments by May 31, 2017. If you do not submit this
information within the given timeframe, then the application will be administratively canceled.
Cancellation of the application does not preclude you from reopening the application at a later time,
provided you submit the required information.
If you have any questions regarding these matters, please contact me at [phone] or
David.L.Shaeffergusace.armL.

i�
Sincerely,
Digitally signed by
SHAEFFEF.DAVIDAEIGH.1]fi0750573
cS/� �+• �ON: c==US. Govemmen4 ou=DOD,
==EISA,
cn
cn=SHAEF1,ouSHAEFFEFDAVIO.LEIGH.12fi0750573
Dale: 2017.04.24 11 0739 -04'00'
David L. Shaeffer
Project Manager
Charlotte Field Office
Enclosures
cc (via Email):
Brian Hoaglund
Clearwater Paper
Brian.Hoael unda,,cl earwaternaner.com
Clement Riddle
Clearwater Environmental Consultants, Inc.
clement ..cwenv.com
Sue Homewood
NC Division of Water Resources
sue.homewooda.ncdenr. Qov

Attachment B
Updated Figure 6
Amec Foster Wheeler

©
Attachment C
Alternative Analysis Supplement

Attachment C
Clearwater Paper Corporation – Alternatives Analysis Supplement

Off-Site Options
Five tracts (Figure 1) of land equal to or greater than 200 acres in Cleveland County were identified
as potential site alternatives. A property threshold of 200 acres was selected in accordance to
parcel size requirements necessary for the expansion of current paper production operations and
to increase conversion capacity at CWP. This acreage is consistent with the current, proposed
CWP expansion site in Shelby, North Carolina, which totals approximately 261 acres.
Tracts identified as potential off-site options include: Albert Greene (Parcel 30728), John Gentry
(Parcel 27130), The Blanton Farm (Parcel 30492), Mildred W. Lattimore, Site A (Parcel 31371),
and Mildred W. Lattimore, Site B (Parcel 31355). Each property is discussed below with regards
to the “Siting Criteria” listed above and in the alternatives analysis.
1. Albert Greene (Parcel 30728)
a. Property Size – The Albert Greene parcel is approximately 480 acres and meets the
property size requirements outlined in the siting criteria.
b. Property Availability – The Albert Greene parcel is a privately-owned residential
parcel that is not currently available for purchase. This property does not meet the
availability criteria.
c. Access to Rail – The Albert Greene parcel does not have direct rail access, a
component that is vital to the routine and efficient delivery of pulp to CWP. The
nearest train track is located approximately 2.4 miles southwest of the property.
This property does not meet the rail access criteria.
d. Access to Interstate – The Albert Green parcel is located approximately 5 miles
north of US-74. This property meets the interstate access criteria.
e. Access to Utilities – Sewer service is not currently located at the site. New sewer
line and easements would have to be built and obtained for approximately 3.5 miles
in addition to the proposed upgrades for the preferred alternative. Municipal water
is available at the site; however, lines would likely need to be upgraded to meet
demand. The existing CWP mill is served by a 100kv transmission line. Most of
the area within Cleveland County is served by 44kv transmission lines which are
not capable of handling the megawatt load increase. This site does not have access
to 100kv line. New lines and ROW would have to be constructed and obtained for
1.4-mile new transmission line. Natural gas is not available at the site and would
have to be brought considerable distance past the preferred site to this location.
f. Access to an Existing Labor Force - The Albert Greene parcel is located
approximately 2.8 miles northwest from the proposed CWP facility. CWP’s
management, operations and maintenance personnel will have to travel to cover
multiple sites spread apart or duplicate positions at a cost to regain efficiency. This
property does not meet the access to existing labor force criteria.
g. Proximity to Target Market – The Albert Greene parcel is located approximately
2.8 miles northwest from the proposed CWP facility. Use of this parcel is not likely
to cause a disruption of service within the target market. This property meets the
proximity to target market criteria.
h. Cost Efficiency – CWP will also need to transfer products between the existing
facility and the new facility by way of a Hostler shuttle service. Transferring to the
adjunct site across the road can be done quickly with minimal added overhead.
Current estimates indicate having to shuttle more than two miles between facilities
will require additional drivers and equipment to keep the flow of material at an
acceptable level. In addition, hostler vehicles can travel on a DOT road but only
with a bill of laden. For internal transfers (i.e. across the street) this time-
consuming paperwork is not generated and managed for internal transfer.
2. John Gentry (Parcel 27130)
a. Property Size – The John Gentry parcel is approximately 348 acres and meets the
property size requirements outlined in the siting criteria.
b. Property Availability – The John Gentry parcel is a privately-owned residential
parcel that is not currently available for purchase. This property does not meet
the availability criteria.
c. Access to Rail - The John Gentry parcel does not have direct rail access. The
nearest train track is located approximately 2.2 miles south and 1.7 miles southeast
of the property. This property does not meet the rail access criteria.
d. Access to Interstate – The John Gentry parcel is located approximately 2.4 miles
north of US-74. This property meets the interstate access criteria.
e. Access to Utilities – Sewer service is not currently located at the site. New sewer
line and easements would have to be built and obtained for approximately 2 miles.
Municipal water is available at the site; however, lines would likely need to be
upgraded to meet demand. This site does not have access to 100kv line. New lines
and ROW would have to be constructed and obtained for an approximately 5-mile
new transmission line. Natural gas is not available at the site and would have to be
brought considerable distance.
f. Access to an Existing Labor Force – The John Gentry parcel is located
approximately 3.3 miles northeast from the proposed CWP facility. CWP’s
management, operations and maintenance personnel will have to travel to cover
multiple sites spread apart or duplicate positions at a cost to regain efficiency. This
property does not meet the access to existing labor force criteria.
g. Proximity to Target Market – The John Gentry parcel is located approximately 3.3
miles northeast from the proposed CWP facility. Use of this parcel is not likely to
cause a disruption of service within the target market. This property meets the
proximity to target market criteria.
h. Cost Efficiency – CWP will also need to transfer products between the existing
facility and the new facility by way of a Hostler shuttle service. Transferring to the
adjunct site across the road can be done quickly with minimal added overhead.
Current estimates indicate having to shuttle more than two miles between facilities
will require additional drivers and equipment to keep the flow of material at an
acceptable level. In addition, hostler vehicles can travel on a DOT road but only
with a bill of laden. For internal transfers (i.e. across the street) this time-
consuming paperwork is not generated and managed for internal transfer.
3. The Blanton Farm (Parcel 30492)
a. Property Size – The Blanton Farm parcel is approximately 714 acres and meets the
property size requirements outlined in the siting criteria.
b. Property Availability – The Blanton Farm parcel is a privately-owned residential
parcel that is not currently available for purchase. This property does not meet the
availability criteria.
c. Access to Rail – The Blanton Farm parcel has direct rail access along the north and
northeastern portions of the property. This property meets the rail access criteria.
d. Access to Interstate – The Blanton Farm parcel is bisected by US-74, providing
direct interstate access to the northern and southern portions of the property. This
property meets the interstate access criteria; however, the continuity of the parcel
is disrupted due to US-74. As a result, CWP would either have to develop on both
e. Access to Utilities – Access to Utilities – Sewer service is located at the site. Some
upgrades would be necessary. Municipal water is available at the site; however
lines would likely need to be upgraded to meet demand. This site does not have
access to 100kv line. New lines and ROW would have to be constructed and
obtained for an approximately 2-mile new transmission line. Natural gas is
reasonable close to the site. However, new lines would be installed an/or upgraded
to bring gas to the site, similar to the preferred alternative.
f. Access to an Existing Labor Force – The Blanton Farm parcel is located
approximately 1.2 miles southeast from the proposed CWP facility. CWP’s
existing labor force could be retained during the facility expansion and would not
be disproportionately affected by this alternate location. This property meets the
access to existing labor force criteria.
g. Proximity to Target Market – The Blanton Farm parcel is located approximately
1.2 miles southeast from the proposed CWP facility. Use of this parcel is not likely
to cause a disruption of service within the target market. This property meets the
proximity to target market criteria.
h. Cost Efficiency – CWP will also need to transfer products between the existing
facility and the new facility by way of a Hostler shuttle service. Transferring to the
adjunct site across the road can be done quickly with minimal added overhead. In
addition, hostler vehicles can travel on a DOT road but only with a bill of laden.
For internal transfers (i.e. across the street) this time-consuming paperwork is not
generated and managed for internal transfer.
4. Mildred W. Lattimore, Site A (Parcel 31371)
a. Property Size – The Mildred W. Lattimore, Site A parcel is approximately 261 acres
and meets the property size requirements outlined in the siting criteria.
b. Property Availability – Mildred W. Lattimore, Site A parcel is a privately-owned
residential parcel that is not currently available for purchase. This property does not
meet the availability criteria.
c. Access to Rail – The Mildred W. Lattimore, Site A parcel has limited direct access
to rail only within a small, northwestern section of the property. This portion of rail
would not be sufficient for pulp delivery operations at CWP. The purchase of
additional, privately-owned, adjacent properties would be required to meet rail
access needs. As a result, the Mildred W. Lattimore, Site A parcel does not meet
the rail access criteria.
d. Access to Interstate - The Mildred W. Lattimore parcel is located approximately
0.6 mile north of US-74. This property meets the interstate access criteria.
e. Access to Utilities – Sewer service is not currently located at the site. New sewer
line and easements would have to be built and obtained for approximately 3.5 miles.
Municipal water is available at the site; however, lines would likely need to be
upgraded to meet demand. This site does not have access to 100kv line. New lines
and ROW would have to be constructed and obtained for 2.7-mile new transmission
line. Natural gas is not available at the site and would have to be brought
considerable distance past the preferred site to this location.
f. Access to an Existing Labor Force – The Mildred W. Lattimore, Site A parcel is
located approximately 3.8 miles southwest from the proposed CWP facility. CWP’s
management, operations and maintenance personnel will have to travel to cover
multiple sites spread apart or duplicate positions at a cost to regain efficiency. This
property does not meet the access to existing labor force criteria.
g. Proximity to Target Market – The Mildred W. Lattimore, Site A parcel is located
approximately 3.8 miles southwest from the proposed CWP facility. Use of this
parcel is not likely to cause a disruption of service within the target market. This
property meets the proximity to target market criteria.
h. Cost Efficiency – CWP will also need to transfer products between the existing
facility and the new facility by way of a Hostler shuttle service. Transferring to the
adjunct site across the road can be done quickly with minimal added overhead.
Current estimates indicate having to shuttle more than two miles between facilities
will require additional drivers and equipment to keep the flow of material at an
acceptable level. In addition, hostler vehicles can travel on a DOT road but only
with a bill of laden. For internal transfers (i.e. across the street) this time-
consuming paperwork is not generated and managed for internal transfer.
5. Mildred W. Lattimore, Site B (Parcel 31355)
a. Property Size – The Mildred W. Lattimore, Site B parcel is approximately 260 acres
and meets the property size requirements outlined in the siting criteria.
b. Property Availability – The Mildred W. Lattimore, Site B parcel is a privately-
owned residential parcel that is not currently available for purchase. This property
does not meet the availability criteria.
c. Access to Rail – The Mildred W. Lattimore, Site B parcel has limited direct access
to rail only within a small, southern section of the property. This portion of rail
would not be sufficient for pulp delivery options at CWP. The purchase of
additional, privately-owned, adjacent properties would be required to meet rail
access needs. As a result, the Mildred W. Lattimore, Site B parcel does not meet
the rail access criteria.
d. Access to Interstate – The Mildred W. Lattimore, Site B parcel is located
approximately 1.4 miles north of US-74. This property meets the interstate access
criteria.
e. Access to Utilities – Sewer service is not currently located at the site. New sewer
line and easements would have to be built and obtained for approximately 3.3 miles.
Municipal water is available at the site; however, lines would likely need to be
upgraded to meet demand. This site does not have access to 100kv line. New lines
and ROW would have to be constructed and obtained for 2.7-mile new transmission
line. Natural gas is not available at the site and would have to be brought
considerable distance past the preferred site to this location.
f. Access to an Existing Labor Force – The Mildred W. Lattimore, Site B parcel is
located approximately 3.5 miles northwest from the proposed CWP facility. CWP’s
management, operations and maintenance personnel will have to travel to cover
multiple sites spread apart or duplicate positions at a cost to regain efficiency. This
property does not meet the access to existing labor force criteria.
g. Proximity to Target Market – The Mildred W. Lattimore, Site B parcel is located
approximately 3.5 miles northwest from the proposed CWP facility. Use of this
parcel is not likely to cause a disruption of service within the target market. This
property meets the proximity to target market criteria.
h. Cost Efficiency – CWP will also need to transfer products between the existing
facility and the new facility by way of a Hostler shuttle service. Transferring to the
adjunct site across the road can be done quickly with minimal added overhead.
Current estimates indicate having to shuttle more than two miles between facilities
will require additional drivers and equipment to keep the flow of material at an
acceptable level. In addition, hostler vehicles can travel on a DOT road but only
with a bill of laden. For internal transfers (i.e. across the street) this time-
consuming paperwork is not generated and managed for internal transfer.
Presence of Streams (Criteria I)
The applicant believes that it has been determined that other properties of similar size located in
North Carolina would likely contain comparable streams…presenting similar engineering and land
planning challenges and opportunities. For discussion purposes, GIS was utilized to calculate the
linear footage of streams using available USGS stream data for each alternative site option
identified, as well as the current, proposed CWP expansion location. Based on this method (which
should not be misconstrued as a stream delineation), the sites contain the following amounts of
stream channels.

Site Streams (LF)*
Albert Greene (Parcel
30728)
11,363
John Gentry (Parcel
27130)
8,647
The Blanton Farm
(Parcel 30492)
19,364
Mildred W. Lattimore,
Site A (Parcel 31371)
6,810
Mildred W. Lattimore,
Site B (Parcel 31355)
8,255
As-Proposed-CWP 7,996

The average linear footage of streams on these properties is approximately 10,405 linear feet (30%
more than the amount of streams present at the As-Proposed-CWP location). The median linear
footage of streams on these properties is approximately 8,451 linear feet (5% more than the amount
of streams present at the As-Proposed-CWP location). Based on the sites evaluated, CWP does not
have a disproportionately high amount of stream resources when compared to other tracts of a
similar size. Additionally, this data shows that similarly sized properties contain comparable
streams.
Summary
The following table summarizes the sites and criteria discussed above.

Criteria I
Site Criteria A Criteria B Criteria C Criteria D Criteria E Criteria F Criteria G Criteria H Streams (LF)*
Albert Greene (Parcel 30728)Ο X X Ο X X Ο X 11,363
John Gentry (Parcel 27130)Ο X X Ο X X Ο X 8,647
The Blanton Farm (Parcel 30492)Ο X Ο Ο X Ο Ο Ο 19,364
Mildred W. Lattimore, Site A (Parcel 31371)Ο X X Ο X X Ο X 6,810
Mildred W. Lattimore, Site B (Parcel 31355)Ο X X Ο X X Ο X 8,255
As-Proposed-CWP Ο Ο Ο Ο Ο Ο Ο Ο 7,996
Ο = Meets Criteria
X = Does Not Meet Criteria
* Based on GIS for discussion purposes only. Actual jurisdictional waters present on-site may be different.
Clearwater Paper - Off-Site Alternatives
Ü
0 1 20.5 Miles
Legend
Off-Site Alternatives
Clearwater Paper Boundary
32 Clayton StreetAsheville, North Carolina 28801
Off-Site AlternativesFigure 1Cleveland County,North Carolina
Drawn by: KAY 5.15.17; CEC Project# 890
Parcel 27130 Gentry
Parcel 30492The Blanton Farm
Parcel 31371 Lattimore
Parcel 31355 Lattimore
Parcel 30728Greene
Proposed Clearwater PaperBoundary
Existing Clearwater Paper Facility
Attachment C
TGS Engineers
Road Crossing Details (Sheets 1-5)

811.64
812.88
814.06
815.93
816.04
816.80
817.88
818.82
819.03
819.32
820.79
822.28
822.42
822.59
824.05
826.80827.00
827.35
827.59
828.22
829.76
831.95
832.92
834.04
RIP RAP
HEADWALL
PROPOSED
(BURIED 1 FT.)
L~ 168 LF
PROPOSED 60" RCP
DIKE
IMPERVIOUS
DIKE
IMPERVIOUS
TO MAINTAIN STREAM FLOW.
OPERATIONS AS DIRECTED BY THE ENGINEER
CONTRACTOR IS TO USE PUMP AROUND
CONSTRUCTION SEQUENCE:
1.Install perimeter erosion control devices as shown on EC-XX.
2.Install stilling basin as directed by the Engineer.
3.Construct impervious dikes to restrain stream and begin pump
around operations.
4.Construct proposed pipe and channel improvements.
5.Remove impervious dikes and return flow back to creek channel.
6.Remove stilling basin.
7.Complete roadway construction.
CONSTRUCTION AND MAINTENANCE ACTIVITIES MANUAL.
NCDOT BEST MANAGEMENT PRACTICES FOR
INSTALL PIPE(S) IN JURISDICTIONAL AREAS ACCORDING TO
BASIN
STILLING
PUMP AROUND
GRAPHIC SCALE
0’40’40’
PROJECT REFERENCE NO.

CORP. LICENSE NO.: C-0275
PH [phone]
SHELBY, NC 28150
804-C N. LAFAYETTE ST
TGS ENGINEERS

N
A
D

8
3
/

2
0
1
1
PERMANENT
TEMPORARY
LENGTH TYPE DESCRIPTION
FILL
PROPOSED CULVERT: 1 @ 60" RCP
NEW ROADWAYUT TO BRUSHY CREEK STREAM IMPACTS
270
’

ALONG
STREAM
270 FT
DEWATERING
TEMPORARY IMPERVIOUS DIKES
(APPROXIMATE)
SHOULDER (TYP.)
(APPROXIMATE)
TOE OF FILL SLOPE
(APPROXIMATE)
TOE OF FILL SLOPE
290 FT
RIP RAP AT OUTLET
PROPOSED CULVERT & CLEVELAND COUNTY
IMPACT SITE #1
CLEARWATER PAPER
UT TO BRUSHY CREEK
UT TO BRUSHY CREEK
AND STILLING BASIN DETAILS.
SEE SHEET 5 FOR TEMPORARY IMPERVIOUS DIKE4.
CULVERT LENGTH SHOWN ARE APPROXIMATE.
ROADWAY ALIGNMENT, FILL SLOPES, AND3.
FROM SURVEY.
STREAM CENTERLINE ELEVATIONS ARE
CONTOURS SHOWN ARE FROM LIDAR DATA.2.
RIVER BASIN.
UT TO BRUSHY CREEK IS IN THE BROAD 1.
NOTES:
SHEET 1 OF 5
PERMIT DRAWINGPRELIMINARY
WSR_Hyd_prm_pln.dgn 4/12/2017 3:00:07 PM TGS
820
825
8
2
5
830
8
3
0
835
8
3
5
840
8
4
0
8
4
5
811.64
812.88
814.06
815.93
816.04
816.80
817.88
818.82
819.03
819.32
820.79
822.28
822.42
822.59
824.05
826.80827.00
827.35
827.59
828.22
829.76
831.95
832.92
834.04
RIP RAP
HEADWALL
PROPOSED
(BURIED 1 FT.)
L~ 168 LF
PROPOSED 60" RCP
DIKE
IMPERVIOUS
DIKE
IMPERVIOUS
TO MAINTAIN STREAM FLOW.
OPERATIONS AS DIRECTED BY THE ENGINEER
CONTRACTOR IS TO USE PUMP AROUND
CONSTRUCTION SEQUENCE:
1.Install perimeter erosion control devices as shown on EC-XX.
2.Install stilling basin as directed by the Engineer.
3.Construct impervious dikes to restrain stream and begin pump
around operations.
4.Construct proposed pipe and channel improvements.
5.Remove impervious dikes and return flow back to creek channel.
6.Remove stilling basin.
7.Complete roadway construction.
CONSTRUCTION AND MAINTENANCE ACTIVITIES MANUAL.
NCDOT BEST MANAGEMENT PRACTICES FOR
INSTALL PIPE(S) IN JURISDICTIONAL AREAS ACCORDING TO
BASIN
STILLING
PUMP AROUND
GRAPHIC SCALE
0’40’40’
PROJECT REFERENCE NO.

CORP. LICENSE NO.: C-0275
PH [phone]
SHELBY, NC 28150
804-C N. LAFAYETTE ST
TGS ENGINEERS

N
A
D

8
3
/

2
0
1
1
PERMANENT
TEMPORARY
LENGTH TYPE DESCRIPTION
FILL
PROPOSED CULVERT: 1 @ 60" RCP
NEW ROADWAYUT TO BRUSHY CREEK STREAM IMPACTS
270
’

ALONG
STREAM
270 FT
DEWATERING
TEMPORARY IMPERVIOUS DIKES
(APPROXIMATE)
SHOULDER (TYP.)
(APPROXIMATE)
TOE OF FILL SLOPE
(APPROXIMATE)
TOE OF FILL SLOPE
290 FT
RIP RAP AT OUTLET
PROPOSED CULVERT & CLEVELAND COUNTY
IMPACT SITE #1
CLEARWATER PAPER
UT TO BRUSHY CREEK
UT TO BRUSHY CREEK
AND STILLING BASIN DETAILS.
SEE SHEET 5 FOR TEMPORARY IMPERVIOUS DIKE4.
CULVERT LENGTH SHOWN ARE APPROXIMATE.
ROADWAY ALIGNMENT, FILL SLOPES, AND3.
FROM SURVEY.
STREAM CENTERLINE ELEVATIONS ARE
CONTOURS SHOWN ARE FROM LIDAR DATA.2.
RIVER BASIN.
UT TO BRUSHY CREEK IS IN THE BROAD 1.
NOTES:
SHEET 2 OF 5
PERMIT DRAWINGPRELIMINARY
WSR_Hyd_prm_pln.dgn 4/12/2017 3:00:44 PM TGS
DIVISION OF HIGHWAYS
NCDOT
PROFILE ALONG ROADWAY
810
5+00 6+00 7+00 8+00 9+00
815
820
825
830
835
840
845
850
855
860
865
870
10+00 11+00 12+00
VARY FROM FINAL DESIGN.
CULVERT SIZE SHOWN IS PRELIMINARY AND APPROXIMATE AND MAY 2.
PURPOSE OF PRELIMINARY PERMIT DRAWINGS ONLY.
PROPOSED ROADWAY GRADE IS APPROXIMATE AND DRAWN FOR1.
NOTES:
FIELD VISIT (4-4-2017)
ELEVATION ON DATE OF
APPROX. WATER SURFACE
(APPROXIMATE*)
PROPOSED GRADE
(LIDAR)
EX. GRADE
(BURIED 1 FT.)
PROPOSED 60" RCP
PROP. GRADE= T.B.D.*
PROP. 1 @ 60" RCP
C/L -Y2- STA. 9+30.27
(APPROX., FROM FIELD MEASUREMENTS)
CHANNEL SECTION
CLEVELAND COUNTY
UT TO BRUSHY CREEK
NEW ROADWAY OVER
IMPACT SITE #1
CLEARWATER PAPER
SHEET 3 OF 5
PERMIT DRAWING
PRELIMINARY
WSR_Hyd_prm_pfl.dgn 4/11/2017 1:16:29 PM TGS
DIVISION OF HIGHWAYS
NCDOT
810
1+00
815
820
825
830
835
840
845
850
855
860
865
870
PROFILE ALONG STREAM
C/L 2+00 3+00-1+00-2+00-3+00
VARY FROM FINAL DESIGN.
CULVERT SIZE SHOWN IS PRELIMINARY AND APPROXIMATE AND MAY 2.
PURPOSE OF PRELIMINARY PERMIT DRAWINGS ONLY.
PROPOSED ROADWAY GRADE IS APPROXIMATE AND DRAWN FOR1.
NOTES:
FIELD VISIT (4-4-2017)
ELEVATION ON DATE OF
APPROX. WATER SURFACE
EXISTING STREAM BED PROFILE
HEADWALL
CONCRETE
(APPROXIMATE)
EXISTING TOP OF BANK
PROPOSED 60" RCP
CULVERT SLOPE~0.036 FT/FT
2:12:1
PROP. GRADE= T.B.D*
PROP. 1 @ 60" RCP
C/L -Y2- STA. 9+30.27
BURY INVERTS 1 FT. (TYP.)
CLEVELAND COUNTY
UT TO BRUSHY CREEK
NEW ROADWAY OVER
IMPACT SITE #1
CLEARWATER PAPER
OUTLET PROTECTION
RIP RAP
SHEET 4 OF 5
PERMIT DRAWING
PRELIMINARY
WSR_Hyd_prm_pfl.dgn 4/11/2017 1:16:08 PM TGS
DIVISION OF HIGHWAYS
NCDOT
CLEVELAND COUNTY
UT TO BRUSHY CREEK
NEW ROADWAY OVER
IMPACT SITE #1
CLEARWATER PAPER
TEMPORARY IMPERVIOUS DIKE DETAIL
STILLING BASIN DETAIL
FLOW
8 FT. (MAX.)
~3 FT.
(AS DIRECTED BY ENGINEER)
SAND BAGS OR SIMILAR
BED
STREAM
SHEET 5 OF 5
PERMIT DRAWING
PRELIMINARY
WSR_Hyd_prm_det.dgn 4/12/2017 2:46:24 PM TGS
Sheet 2
Sheet 1
Approximate Sewer Line Upgrades & New Parallel Gravity Sewer Line
Ü
0 1,000 2,000500Feet
Legend
Approximate Sewer Line Upgrades Easement (40 FT ROW)
New Parallel Gravity Sewer Line Easement (40 FT ROW)
32 Clayton StreetAsheville, North Carolina 28801
Approximate Sewer Line Upgrades New Parallel Gravity Sewer Line Impact Map Figure 8
Cleveland County,North Carolina
Drawn by: KAY 3.20.17; Updated 4.17.17; Project# 890
W etlan d (A C)Stream (LF)
UW 1 0.001 US1 No Imp act
UW 2 0.02 US2 No Imp act
UW 3 0.001 US3 20
UW 4 0.01 US4 No Imp act
US5 No Imp act
US6 No Imp act
US7 20
US8 20
US9 No Imp act
US10 20
Total 0 .0 3 2 Total 8 0
Temporary Impact Tabl e
Approximate Sewer Line Upgrades & New Parallel Gravity Sewer Line
Ü
0 500 1,000250Feet
Legend
Stream
Linear Wetland
Wetland
Approximate Sewer Line Upgrades Easement (40 FT ROW)
New Parallel Gravity Sewer Line Easement (40 FT ROW)
32 Clayton StreetAsheville, North Carolina 28801
Approximate Sewer Line Upgrades New Parallel Gravity Sewer Line Impact Map Figure 8, Sheet 1
Cleveland County,North Carolina
Drawn by: KAY 3.20.17; Updated 4.17.17; Project# 890
US1No Impact
US2 No ImpactUW1, 0.001 ACTemporary Impact
US3, 20 LFTemporary Impact
US4 No Impact
W etlan d (A C)Stream (LF)
UW 1 0.001 US1 No Imp act
UW 2 0.02 US2 No Imp act
UW 3 0.001 US3 20
UW 4 0.01 US4 No Imp act
US5 No Imp act
US6 No Imp act
US7 20
US8 20
US9 No Imp act
US10 20
Total 0 .0 3 2 Total 8 0
Temporary Impact Tabl e
Approximate Sewer Line Upgrades & New Parallel Gravity Sewer Line
Ü
0 500 1,000250Feet
Legend
Stream
Linear Wetland
Wetland
Approximate Sewer Line Upgrades Easement (40 FT ROW)
New Parallel Gravity Sewer Line Easement (40 FT ROW)
32 Clayton StreetAsheville, North Carolina 28801
Approximate Sewer Line Upgrades New Parallel Gravity Sewer Line Impact Map Figure 8, Sheet 2
Cleveland County,North Carolina
Drawn by: KAY 3.20.17; Updated 4.17.17; Project# 890
US5 No Impact
UW2, 0.02 ACTemporary Impact
UW3, 0.001 ACTemporary Impact
US7, 20 LFTemporary Impact
US8, 20 LFTemporary Impact
US10, 20 LFTemporary Impact
UW4, 0.01 Temporary Impact
US6No Impact
US9No Impact
W et lan d (A C)St ream (LF)
UW 1 0.001 US1 No Imp act
UW 2 0.02 US2 No Imp act
UW 3 0.001 US3 20
UW 4 0.01 US4 No Imp act
US5 No Imp act
US6 No Imp act
US7 20
US8 20
US9 No Imp act
US10 20
Total 0 .0 3 2 Total 8 0
Temporary Impact Table
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DESIGNED BY:
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DATE:
CADD BY:
CONST. REVIEW: _____
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EROSION CONTROL NOTES NORTH CAROLINA LAND QUALITY SECTIONREVISION DATE - MARCH, 2016NATIVE SEEDING:NATIVE PLANT SEEDING MIX FOR STREAM OR RIVERBANK STABILIZATIONNPDES PERMITS - NOTE -FOR PROJECTS REQUIRING NPDES PERMITS, THEFOLLOWING STABILIZATION SCHEDULE SHALL APPLY:
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VW
16.00359
APRIL 26, 2017
VW
16.00359 CWE Impacts.dwg
2017 WESTSIDE
SEWER SYSTEM IMPROVEMENTS
GRAVITY SEWER LINE
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VW
16.00359
APRIL 26, 2017
VW
16.00359 CWE Impacts.dwg
2017 WESTSIDE
SEWER SYSTEM IMPROVEMENTS
GRAVITY SEWER LINE
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16.00359 CWE Impacts.dwg
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CLEVELAND COUNTY, NORTH CAROLINA
VW
16.00359
APRIL 26, 2017
VW
16.00359 CWE Impacts.dwg
2017 WESTSIDE
SEWER SYSTEM IMPROVEMENTS
GRAVITY SEWER LINE
P
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SEWER LINE
PLAN AND PROFILE
55+00 - 70+00
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16.00359 CWE Impacts.dwg
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CLEVELAND COUNTY, NORTH CAROLINA
VW
16.00359
APRIL 26, 2017
VW
16.00359 CWE Impacts.dwg
2017 WESTSIDE
SEWER SYSTEM IMPROVEMENTS
GRAVITY SEWER LINE
P
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PLAN AND PROFILE
70+00 - 85+00
P
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16.00359 CWE Impacts.dwg
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MATCH LINE 70+00
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CLEVELAND COUNTY, NORTH CAROLINA
VW
16.00359
APRIL 26, 2017
VW
16.00359 CWE Impacts.dwg
2017 WESTSIDE
SEWER SYSTEM IMPROVEMENTS
GRAVITY SEWER LINE
P
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7
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SEWER LINE
PLAN AND PROFILE
85+00 - 100+00
P
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16.00359 CWE Impacts.dwg
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MATCH LINE 85+00
MATCH LINE 100+00
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VW
16.00359
APRIL 26, 2017
VW
16.00359 CWE Impacts.dwg
2017 WESTSIDE
SEWER SYSTEM IMPROVEMENTS
GRAVITY SEWER LINE
P
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SEWER LINE
PLAN AND PROFILE
130+00 - 145+00
P
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16.00359 CWE Impacts.dwg
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MATCH LINE 130+00
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VW
16.00359
APRIL 26, 2017
VW
16.00359 CWE Impacts.dwg
2017 WESTSIDE
SEWER SYSTEM IMPROVEMENTS
GRAVITY SEWER LINE
P
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L
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P
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SEWER LINE
PLAN AND PROFILE
145+00 - 155+00
P
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16.00359 CWE Impacts.dwg
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MATCH LINE 145+00
MA
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NO SPILLAGE OF SEWER FLOW WILL BE ALLOWED AT ANY TIME
CLEVELAND COUNTY, NORTH CAROLINA
VW
16.00359
APRIL 26, 2017
VW
16.00359 CWE Impacts.dwg
2017 WESTSIDE
SEWER SYSTEM IMPROVEMENTS
GRAVITY SEWER LINE
P
R
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L
I
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„„„„
0
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„„„„„„„„„„„„„„„„
P
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SEWER LINE
PLAN AND PROFILE
155+00 - 170+00
P
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16.00359 CWE Impacts.dwg
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MATCH LINE 155+00
MATCH LINE 170+00
NO SPILLAGE OF SEWER FLOW WILL BE ALLOWED AT ANY TIME
CLEVELAND COUNTY, NORTH CAROLINA
VW
16.00359
APRIL 26, 2017
VW
16.00359 CWE Impacts.dwg
2017 WESTSIDE
SEWER SYSTEM IMPROVEMENTS
GRAVITY SEWER LINE
P
R
E
L
I
M
I
N
A
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P
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A
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SEWER LINE
PLAN AND PROFILE
170+00 - 185+00
P
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16.00359 CWE Impacts.dwg
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DATE:
CADD BY:
CONST. REVIEW: _____
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FILE NAME:
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MATCH LINE 170+00
M
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CLEVELAND COUNTY, NORTH CAROLINA
VW
16.00359
APRIL 26, 2017
VW
16.00359 CWE Impacts.dwg
2017 WESTSIDE
SEWER SYSTEM IMPROVEMENTS
GRAVITY SEWER LINE
P
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L
I
M
I
N
A
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P
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SEWER LINE
PLAN AND PROFILE
185+00 - 200+00
P
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16.00359 CWE Impacts.dwg
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DESIGN REVIEW: _____
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APRIL 26, 2017
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2017 WESTSIDE
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FILE NAME:
CLEVELAND COUNTY, NORTH CAROLINA
VW
16.00359
APRIL 26, 2017
VW
16.00359 CWE Impacts.dwg
2017 WESTSIDE
SEWER SYSTEM IMPROVEMENTS
GRAVITY SEWER LINE
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FILE NAME:
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APRIL 26, 2017
VW
16.00359 CWE Impacts.dwg
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VW
16.00359
APRIL 26, 2017
VW
16.00359 CWE Impacts.dwg
2017 WESTSIDE
SEWER SYSTEM IMPROVEMENTS
GRAVITY SEWER LINE
P
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Attachment F
Tampa Warehouse Tract JD Request Package

Jurisdictional Determination Request
0
US Army Corps
of Engineers
Wilmmglm DmIno
This form is intended for use by anyone requesting a jurisdictional determination (]D) from the
U.S. Army Corps of Engineers, Wilmington District (Corps). Please include all supporting
information, as described within each category, with your request. You may submit your request
to the appropriate Corps Field Office (or project manager, if known) via mail, electronic mail, or
facsimile. A current list of county assignments by Field Office and project manager can be
found on-line at: http•//www saw usace.anny.mil/Missions/Rel>_ulatoryPermitProgram.aspx , by
telephoning: 910-2514633, or by contacting any of the field offices listed below:
ASHEVILLE REGULATORY FIELD OFFICE
US Army Corps of Engineers
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
General Number: [phone]
Fax Number: [phone]
RALEIGH REGULATORY FIELD OFFICE
US Army Corps of Engineers
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
General Number: (919) 5544884
Fax Number: [phone]
WASHINGTON REGULATORY FIELD OFFICE
US Army Corps of Engineers
2407 West Fifth Street
Washington, North Carolina 27889
General Number: [phone]
Fax Number: [phone]
WILMINGTON REGULATORY FIELD OFFICE
US Army Corps of Engineers
69 Darlington Avenue
Wilmington, North Carolina 28403
General Number: 910-2514633
Fax Number: (910) 2514025
Version: December 2013 Page 1

Jurisdictional Determination Request
INSTRUCTIONS:
All requestors must complete Parts A, B, C, D, E and F.
NOTE TO CONSULTANTS AND AGENCIES: If you are requesting a JD on behalf of a
paying client or your agency, please note the specific submittal requirements in Part G.
NOTE ON PART D — PROPERTY OWNER AUTHORIZATION: Please be aware that all JD
requests must include the current property owner authorization for the Corps to proceed with the
determination, which may include inspection of the property when necessary. This form must be
signed by the current property owner to be considered a complete request.
NOTE ON PART D - NCDOT REQUESTS: Property owner authorization/notification for JD
requests associated with North Carolina Department of Transportation (NCDOT) projects will be
conducted according to the current NCDOT/USACE protocols.
NOTE TO USDA PROGRAM PARTICIPANTS: A Corps approved or preliminary JD may not
be valid for the wetland conservation provisions of the Food Security Act of 1985. If you or
your tenant are USDA Program participants, or anticipate participation in USDA programs, you
should also request a certified wetland determination from the local office of the Natural
Resources Conservation Service, prior to starting work.
Version: December 2013 Page 2

Jurisdictional Determination Request
A. PARCEL INFORMATION
Street Address: 662 Washburn Switch Road
City, State: Shelby, North Carolina
County: Cleveland County
Directions:
Parcel Index Number(s) (PIN): 32623
62696
B. REQUESTOR INFORMATION
Name: ClearWater Environmental Consultants, Inc.
Mailing Address: 32 Clayton Street Asheville, North Carolina 28801
Telephone Number: 828-698-9800
Electronic Mail Address': [e-mail]
Select one:
❑ I am the current property owner.
✓❑ 1 am an Authorized Agent or Environmental Consultant
❑ Interested Buyer or Under Contract to Purchase
❑ Other, please explain.
C. PROPERTY OWNER INFORMATION
Name: Clearwater Paper Go James Jordan
Mailing Address:
Telephone Number:
Electronic Mail Address3:
662 Washburn Switch Road
Shelby, NC 28150
704473-8266
[e-mail]
❑✓ Proof of Ownership Attached (e.g. a copy of Deed, County GIS/Parcet/rax Record data)
1 If available
z Must attach completed Agent Authorization Form
3 If available
Version: December 2013 Page 3

Jurisdictional Determination Request
D. PROPERTY OWNER CERTIFICATION"
1, the undersigned, a duly authorized owner of record of the property/properties identified herein,
do authorize representatives 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 jurisdiction
under Section 404 of the Clean Water Act and/or Section 10 of the Rivers and Harbors Act of
1899.
Property Owner (please print)
Property Owner Signature
E. JURISDICTIONAL DETERMINATION TYPE
Select One:
Date
❑✓ 1 am requesting that the Corps provide a preliminary JD for the property identified herein.
This request does include a delineation.
❑ I am requesting that the Corps provide a preliminary JD for the property identified herein.
This request does NOT include a delineation.
❑ I am requesting that the Corps investigate the property/project area for the presence or
absence of WoUS5 and provide an approved JD for the property identified herein. This
request does NOT include a request for a verified delineation.
ElI am requesting that the Corps delineate the boundaries of all WoUS on a property/project
area and provide an approved JD (this may or may not include a survey plat).
❑ I am requesting that the Corps evaluate and approve a delineation of WoUS (conducted
by others) on a property/project area and provide an approved JD (may or may not
include a survey plat).
° For NCDOT requests following the current NCDOT/USACE protocols, skip to Part E.
s Waters of the United States
Version: December 2013 Page 4

Jurisdictional Determination Request
F. ALL REQUESTS
❑✓ Map of Property or Project Area (attached). This Map must clearly depict the boundaries
of the area of evaluation.
Size of Property or Project Area +_22
acres
F-71 1 verify that the property (or project) boundaries have recently been surveyed and marked
by a licensed land surveyor OR are otherwise clearly marked or distinguishable.
G. JD REQUESTS FROM CONSULTANTS OR AGENCIES
(1) Preliminary JD Requests:
Completed and signed Preliminary Jurisdictional Determination Formb.
35.318138 -81.607337
Project Coordinates: Latitude Longitude
Maps (no larger than 11x17) with Project Boundary Overlay:
❑✓ Large and small scale maps that depict, at minimum: streets, intersections, towns
❑✓ Aerial Photography of the project area
❑✓ USGS Topographic Map
❑✓ Soil Survey Map
F1Other Maps, as appropriate (e.g. National Wetland Inventory Map, Proposed Site
Plan, previous delineation maps, LIDAR maps, FEMA floodplain maps)
6 See Appendix A of this Form. From Regulatory Guidance Letter No. 08-02, dated June 26, 2008
Version: December 2013 Page 5

Jurisdictional Determination Request
Delineation Information (when applicable)]:
Wetlands:
❑ Wetland Data Sheets8
Tributaries:
❑ USACE Assessment Forms
✓❑ Upland Data Sheets ❑ Other Assessment Forms
(when appropriate)
❑ Landscape Photos, if taken
❑ Field Sketch overlain on legible Map that includes:
• All aquatic resources (for sites with multiple resources, label and identify)
• Locations of wetland data points and/or tributary assessment reaches
• Locations of photo stations
■ Approximate acreage/linear footage of aquatic resources
(2) Approved JDs including Verification of a Delineation:
❑ Project Coordinates:
Latitude Longitude
Maps (no larger than 1 1x17) with Project Boundary Overlay:
❑ Large and small scale maps that depict, at minimum: streets, intersections, towns
❑ Aerial Photography of the project area
❑ USGS Topographic Map
❑ Soil Survey Map
❑ Other Maps, as appropriate (e.g. National Wetland Inventory Map, Proposed Site Plan,
previous delineation maps)
1987 Manual Regional Supplements and Data forms can be found at:
http://www.usace.army.mil/Missions/CivilWorks/RegulatoryProgramandPermits/reg supp.aspx
Wetland and Stream Assessment Methodologies can be found at:
http://Portal.ncdenr.org/c/document library/pet file?uuid=76f3c5gb-dab8-4960-ba43-45b7faf06f4c&groupld=38364 and,
htto://www.saw.usace.armv.mil/Portals/59/docs/reRulatory/publicnotices/2013/NCSAM Draft User Manual 130318.odf
a Delineation information must include, at minimum, one wetland data sheet for each wetland/community type.
Version: December 2013 Page 6

Jurisdictional Determination Request
Delineation Information (when applicable):
Wetlands:
1-1 Wetland Data Sheets9
X
a
Upland Data Sheets
Landscape Photos, if taken
Tributaries:
F] USACE Assessment Forms
F] Other Assessment Forms
(when appropriate)
Field Sketch overlain on legible Map that includes:
• All aquatic resources (for sites with multiple resources, label and identify)
• Locations of wetland data points and/or tributary assessment reaches
• Locations of photo stations
• Approximate acreage/linear footage of aquatic resources
Supporting Jurisdictional Information (for Approved JDs only)
Approved Jurisdictional Determination Form(s) (also known as "Rapanos
Form(s)")
❑ Map(s) depicting the potential (or lack of potential) hydrologic connection(s),
adjacency, etc. to navigable waters.
9 Delineation information must include, at minimum, one wetland data sheet for each wetland/community type.
Version: December 2013 Page 7

Jurisdictional Determination Request
1. REQUESTS FOR CORPS APPROVAL OF SURVEY PLAT
Prior to final production of a Plat, the Wilmington District recommends that the Land
Surveyor electronically submit a draft of a Survey Plat to the Corps project manager for
review.
Due to storage limitations of our administrative records, the Corps requires that all hard-
copy submittals include at least one original Plat (to scale) that is no larger than 11"xl7"
(the use of match lines for larger tracts acceptable). Additional copies of a plat, including
those larger than 1 I"x17", may also be submitted for Corps signature as needed. The
Corps also accepts electronic submittals of plats, such as those transmitted as a Portable
Document Format (PDF) file. Upon verification, the Corps can electronically sign these
plats and return them via e-mail to the requestor.
(1) PLATS SUBMITTED FOR APPROVAL
ElMust be sealed and signed by a licensed professional land surveyor
❑ Must be to scale (all maps must include both a graphic scale and a verbal scale)
R Must be legible
ElMust include a North Arrow, Scale(s), Title, Property Information
Must include a legible WoUS Delineation Table of distances and bearings/metes
and bounds/GPS coordinates of all surveyed delineation points
❑ Must clearly depict surveyed property or project boundaries
Must clearly identify the known surveyed point(s) used as reference (e.g. property
corner, USGS monument)
1-1 When wetlands are depicted:
• Must include acreage (or square footage) of wetland polygons
• Must identify each wetland polygon using an alphanumeric system
Version: December 2013 Page 8

Jurisdictional Determination Request
❑ When tributaries are depicted:
• Must include either a surveyed, approximate centerline of tributary with
approximate width of tributary OR surveyed Ordinary High Water Marks
(OH W M) of tributary
• Must identify each tributary using an alphanumeric system
• Must include linear footage of tributaries and calculated area (using approximate
widths or surveyed OHWM)
• Must include name of tributary (based on the most recent USGS topographic
map) or, when no USGS name exists, identify as "unnamed tributary"
F] all depicted WoUS (wetland polygons and tributary lines) must intersect or tie -to
surveyed project/property boundaries
❑ Must include the location of wetland data points and/or tributary assessment
reaches
Must include, label accordingly, and depict acreage of all waters not currently
subject to the requirements of the CWA (e.g. "isolated wetlands", "non -
jurisdictional waters"). NOTE: An approved JD must be conducted in order to
make an official Corps determination that a particular waterbody or wetland is not
jurisdictional.
❑ Must include and survey all existing conveyances (pipes, culverts, etc.) that
transport WoUS
Version: December 2013 Page 9

Jurisdictional Determination Request
(2) CERTIFICATION LANGUAGE
RWhen the entire actual Jurisdictional Boundary is depicted:
include the following Corps Certification language:
"This certifies that this copy of this plat accurately depicts the boundary of the jurisdiction
of Section 404 of the Clean Water Act as determined by the undersigned on this date.
Unless there is a change in the law or our published regulations, the determination of
Section 404 jurisdiction may be relied upon for a period not to exceed five (5) years from
this date. The undersigned completed this determination utilizing the appropriate Regional
Supplement to the 1987 U.S. Army Corps of Engineers Wetlands Delineation Manual."
Regulatory Official:
Title:
Date:
USACE Action ID No.:
FWhen uplands may be present within a depicted Jurisdictional Boundary:
include the following Corps Certification language:
"This certifies that this copy of this plat identifies all areas of waters of the United States
regulated pursuant to Section 404 of the Clean Water Act as determined by the
undersigned on this date. Unless there is change in the law or our published regulations,
this determination of Section 404 jurisdiction may be relied upon for a period not to exceed
five years from this dote. The undersigned completed this determination utilizing the
appropriate Regional Supplement to the 1987 U.S. Army Corps of Engineers Wetlands
Delineation Manual."
Regulatory Official:
Title:
Date:
USACE Action ID No.:
Version: December 2013 Page 10

Jurisdictional Determination Request
(3) GPS SURVEYS
For Surveys prepared using a Global Positioning System (GPS), the Survey must include
all of the above, as well as:
❑ be at sub -meter accuracy at each survey point.
❑ include an accuracy verification:
One or more known points (property corner, monument) shall be located with the
GPS and cross-referenced with the existing traditional property survey (metes and
bounds).
❑ include a brief description of the GPS equipment utilized.
Version: December 2013 Page 11

ATTACHMENTA
PRELIMINARY JURISDICTIONAL DETERMINATION FORM
BACKGROUND INFORMATION
A. REPORT COMPLETION DATE FOR PRELIMINARY JURISDICTIONAL
DETERMINATION (JD): May 52017
B. NAME AND ADDRESS OF PERSON REQUESTING PRELIMINARY JD:
Brian Haoglund
601 W Riverside Ave Suite 1100 Spokane WA 99201
C. DISTRICT OFFICE, FILE NAME, AND NUMBER:
Wilmington District, Corps of Engineers, Clearwater Paper, SAW - 2011 - 02398
D. PROJECT LOCATION(S) AND BACKGROUND INFORMATION:
662 Washburn Switch Road Shelby, NC 28150; across the road from the Clearwater Paper Co. main
(USE THE ATTACHED TABLE TO DOCUMENT MULTIPLE WATERBODIES AT DIFFERENT
SITES)
State: NC
County/parish/borough: Cleveland county City; Shelby
Center coordinates of site (lat/long in degree decimal format):
Lat. 35.318138 °N; Long. -81.607337
Universal Transverse Mercator: NAD83
Name of nearest waterbody: Brushy Creek HUC: 030501050701
°W.
Identify (estimate) amount of waters in the review area:
Non -wetland waters:
0 linear feet: 0 width (ft) and/or 0 acres.
Cowardin Class: NIA
Stream Flow: NIA
Wetlands:0 acres.
Cowardin Class: NIA
Name of any water bodies on the site that have been identified as Section 10
waters:
Tidal: NIA
Non -Tidal: NIA

E. REVIEW PERFORMED FOR SITE EVALUATION (CHECK ALL THAT
APPLY):
❑ Office (Desk) Determination. Date:
❑✓ Field Determination. Date(s): May 22017
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
applicant/consultant.
Office concurs with data sheets/delineation report.
❑ Office does not concur with data sheets/delineation report.
❑ Data sheets prepared by the Corps:
❑ Corps navigable waters' study:_
❑ U.S. Geological Survey Hydrologic
❑ USGS NHD data
❑ USGS 8 and 12 digit HUC maps
❑✓ U.S. Geological Survey map(s). Cite scale & quad name: 1:15" Shelby Quad
❑ USDA Natural Resources Conservation Service Soil Survey.
Citation:
❑ National wetlands inventory map(s). Cite
❑ State/Local wetland inventory map(s):_
❑ FEMA/FIRM
a
100 -year Floodplain Elevation is:
(National Geodectic Vertical Datum of 1929)
✓❑ Photographs: ❑ Aerial (Name & Date): or
❑✓ Other (Name & Date): IMG -0823 - IMG_0828
❑ Previous determination(s). File no. and date of response letter:
❑✓ Other information (please specify): USDA soil Map

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)
Signature and date of
person requesting preliminary JD
(REQUIRED, unless obtaining
the signature is impracticable)

Parcel Information

6/6/2017
USER ALAN
Cleveland County NC Property Card
FOR YEAR 2017
TAMPA WAREHOUSE LLC PARCEL ID.. 32623 PIN.... 3293 1 121
A NC LMTD LIABILITY CO LOCATION... 662 WASHBURN SWITCH RD
DEED YEAR/BOOK/PAGE.. 2015 1696 0845 ASSESSMENT NONE
20940 BETHELWOOD LN PLAT BOOK/PAGE.. OWNER ID.. 1307294
LEGAL DESC:24.348AC RD 1313 DISTRICT.. 16 LATTIMORE FIRE DIST
TOWNSHIP... 7 SANDY RUN
CORNELIUS NC 23031- NBRHOOD... PPG INDUSTRIAL -WASH SWITCH -07
DESCRIPTION INDUSTRIAL
MAINTAINED.. 7/26/2016 BY MAYES VALUED.. 9/14/2016 BY MAYES ROUTING#..
VISITED..... 9/25/1998 BY CATEGORY.. Real & Personal
PARCEL STATUS... ACTIVE
____________________________________________
SALES HISTORY ____________________________________________________
DEED BK/PAGE SALE DATE SALES INSTRUMENT DISQUALIFIED SALE AMOUNT STAMP AMOUNT DEED NAME
1696 0845 4/27/2015 DEED QUALIFIED 4,000,000 8,000.00 TAMPA WAREHOUSE LLC A NC LMTD
1667 1285 5/27/2014 PARENT PARCEL PARENT PARCEL ROCKTENN CP LLC
1667 1285 10/28/2013 DEED AFFILIATED COMP ROCKTENN CP LLC
1667 1285 10/28/2013 DEED AFFILIATED COMP SMURFIT -STONE CONTAINER CORPOR
1667 1285 10/28/2013 DEED AFFILIATED COMP SMURFIT -STONE CONTAINER ENTERP
1667 1285 10/28/2013 DEED AFFILIATED COMP JEFFERSON SMURFIT CORPORATION
33N 429 1/01/1966 SALE QUALIFIED
________________________________ LAND SEGMENTS -___________________________________________________
LND
STRAT
LAND
#
ZONE CODE
TYPE/CODE
1
05
AC CBS
2
05
AC OPEN
3
05
AC WOODS
9,724
TOTAL ACRES..
----------------------------------
MAIN FIN AREA.. 6,662.00
STRAT.......... 05
MAIN PERIM......... 1.00
LOCATION #..... RD 1313
COMPONENT TYPE/CODE/DESC PCT
------------------------------
MA 32M OFFICE -MASONRY FRAME 100
EW 03 CONCRETE BLOCK 100
- HC 57 PACKAGED HEATING/C00100
- PL C COMMER PLUMB -EXTRA Flee
- SP 01 WET 100
TOT CURRENT
LAND QTY LAND RATE DPT% 5HP% LOC% SIZ% OTH% TOP% ADJ FMV
16.000 25,000.00 .00 .00 100.00 .00 .00 .00 .00 400,000
2.848 4,500.00 .00 .00 .00 110.00 .00 .00 110.00 14,097
5.506 4,500.00 .00 .00 .00 110.00 .00 .00
.00LAN110.00 441,322
27,225
24.348
IMPROVEMENT # 1 MAJOR IMPR-M -------------------------------------------------
ACT/EFF YR/AGE.. 1967 1979 37 VISITED.. BY
DESCRIPT.... OFFICE -MASONRY FRAME MAINTAINED.. 7/20/2016 BY MAYES
MAIN GROUND SF.... 6,662.000
RCN...
QUAL.. QG C3
DEPR.. D4
__FMV...
MAIN FIN AREA.. 153,164.00
STRAT.......... 05
MAIN PERIM......... 1.00
LOCATION #..... RD 1313
COMPONENT TYPE/CODE/DESC PCT
-----------------------------
AC 04 CANOPY 100
AC 07 DOCK 100
AC 18 INDUSTRIAL OVERHEAD 100
AC 28 AVERAGE INTERIOR FIN 106
AC 28 AVERAGE INTERIOR FIN 100
AC 29 MEZZANINE UNFINISHED 100
MA 25M INDUSTRIAL -MASONRY F 100
EW 03 CONCRETE BLOCK 100
UNITS RATE
STR# STR% SIZ% MGT% PER% CDS%
__________________________________
COST %CMPL
--------------- _--------------------
6662.00 53.94
_____________
1.00 102.08
366,529
1.00 .000
19,519
6662.00 2.93
9,724
13.00 748.00
7,394
6662.00 1.11
_______________
PCT COMPLETE
100 x
403,168
403,168
C+-
37 YEARS OLD
100.00 x
54.00 - 217,709
217,709 T
185,459
IMPROVEMENT # 2 MAJOR IMPR-M
ACT/EFF YR/AGE.. 1967 1979 37 VISITED.. BY
DESCRIPT.... INDUSTRIAL -MASONRY FRAME MAINTAINED.. 7/20/2016 BY MAYES
MAIN GROUND SF.... 153,164.000
UNITS RATE STR# STR% SIZ% HGT% PER% CDS% COST %CMPL
________________________________________
2040.00 ------- _5.73_________________69.00
8,064
2040.00 11.48 69.00 16,158
9.00 1311.00 11,799
3450.00 17.10 91.00 53,685
720.00 17.10 94.00 11,573
720.00 10.91 94.00 7,383
153164.00 29.52 1.00 130.00 5,877,821
1.00 .00 0
1/4
httplAvww.webgi s.mVnc/clevel and/Pr operyC ar d.php?pi d= 32623

61512017 Cleveland County NC Property Card
DATE 4/24/17 CLEVELAND COUNTY PAGE 2
PROPERTY CARD PROG# AS2006
TIME 7:44:32
USER ALAN FOR YEAR 2017
TAMPA WAREHOUSE LLC PARCEL ID.. 32623 PIN... 3293 1 121
__________________________________ IMPROVEMENT # 2 MAJOR IMPR-M_______________-_-_______________________________
COMPONENT TYPE/CODE/DESC PCT UNITS RATE STR# STR% SIZ% HGT% PER% CDS% COST %CMPL
- HC 56 UNIT HEATERS 100 153164.00 .62 94,961
- PL C COMER PLUMB -EXTRA FIBS 29.00 748.00 21,692
171,712
- SP 01 WET 101 154695.64 1.11
_______________
RCN... PCT COMPLETE 108 x 6,274,849
QUAL.. QG C3 C+- 100.00 x 6,274,849
DEPR.. D4 37 YEARS OLD 54.00 - 3,388,417 3,388,417 T
--FMV... 2,886,432
__________________________________ IMPROVEMENT # 3 MAJOR IMPR-M________--_______________________________________
MAIN FIN AREA.. 22,400.00 ACT/EFF YR/AGE.. 1974 1979 37 VISITED.. BY
STRAT.......... 05 DESCRIPT.... WAREHOUSE -MASONRY FRAME MAINTAINED.. 7/20/2016 BY MAYES
MAIN PERIM......... 1.00 MAIN GROUND SF.... 22,400.000
LOCATION #..... RD 1313
COMPONENT TYPE/CODE/DESC PCT UNITS RATE STR# STR% SIZ% HGT% PER% CDS% COST ___%CMPL
____
________________________________________________________
________________________________________________________
AC 08 ENCLOSED FRAME PORCH 100 252.00 19.66 93.00 4,607
AC 18 INDUSTRIAL OVERHEAD 100 1.00 1311.00 1,311
MA 40M WAREHOUSE -MASONRY FR 100 22400.00 18.85 1.00 130.00 548,912
EW 03 CONCRETE BLOCK 100 1.00 .00 0
- HC 56 UNIT HEATERS 100 22400.00 .62 13,888
SP 01 WET 100 22406.00 1.11 24,864
_______________
RCN... PCT COMPLETE 100 x 593,582
QUAL.. QG C3 C+- 100.00 x 593,582
DEPR.. D4 37 YEARS OLD 54.00 - 320,534 320,534 T
--FMV... 273,048
__________________________________ IMPROVEMENT # 4 MISC IMPR_V______-____-_________-_____-________________-____
VISITED.. BY
MAIN FIN AREA.. ACT/EFF YR/AGE.. 1967 1984 32 MAINTAINED.. 7/20/2016 BY MAYES
LOCATION
05 DESCRIPT....
LOCATION #..... RD 1313
COMPONENT TYPE/CODE/DESC PCT UNITS RATE STR# STR% SIZ% HGT% PER% CDS% COST %CMPL
____
__________________________________________________________________________________________________________
_________
MS 61 ASPHALT PAVING 70000.00 0
QUAL.. QG 100 MISC IMPR QUALITY 10 100.00 x
DEPR.. D OVERRIDE DEPRECIATIO 100.00 0 T
COND.. D 50 DEPRECIATION OVERRID x 50.00 50.00 - 0
PCT COMPLETE 100 12,600
__FMV...
__________________________________ IMPROVEMENT # 5 MISC IMPR_Y -------------------- ----------------------------
MAIN FIN AREA.. ACT/EFF YR/AGE.. 1967 1984 32 MAINTAINED.. 7/20/2016 BY MAYES
STRAT.......... 05 DESCRIPT....
LOCATION #..... RD 1313
COMPONENT TYPE/CODE/DESC PCT UNITS RATE STR# STR% SIZ% HGT% PER% CDS% COST %CMPL
____
____________________________________________________________________________________________________ ______
_________
MS 06 CONCRETE PAVING 16000.00 0
QUAL.. QG 100 MISC IMPR QUALITY 10 100.00 x
DEPR.. D OVERRIDE DEPRECIATIO 100.00 0 T
COND.. D 50 DEPRECIATION OVERRID x 50.00 50.00 - 0
PCT COMPLETE 100 4,640
__FMV...
__________________________________
IMPROVEMENT # 6 MISC IMPR-V -------------------------------------------------
MAIN FIN AREA.. ACT/EFF VR/AGE.. 1967 1984 32 VISITED.. BY
MAINTAINED.. 7/20/2016 BY MAYES
STRAT.......... 05 DESCRIPT....
htlpJwww.webgis.n tlnc/cleveland/PropertyCard.php7pid=32623 614

httplAw .webgis.net/nc/clevelard/PFopertyCard.php?pid=32623 314
Cleveland County NC Property Card
615/2017
DATE 4/24/17
CLEVELAND COUNTY
PAGE 3
PROG# AS2006
TIME 7:44:32
PROPERTY CARD
USER ALAN
FOR YEAR 2017
TAMPA WAREHOUSE LLC PARCEL ID.. 32623
PIN... 3293 1 121
__________________________________
IMPROVEMENT # 6 MISC IMPR_Y_________________________________________________
LOCATION #..... RD 1313
COMPONENT TYPE/CODE/DESC PCT
UNITS RATE STR# STR%
SIZ% HGT% PER%
CDS%
______
________-----
COST %CMPL
______
__________________________________________________________________________________________
KS 22 RAILROAD SIDING
QUAL.. QG
1200.00
100 MISC IMPR QUALITY 10
100.00 x
0
DEPR.. D
OVERRIDE DEPRECIATIO 100.00
0
0 7
COND.. D
50 DEPRECIATION OVERRID x 50.00
50.00 -
PCT COMPLETE
100
10,080
__FMV...
__________________________________
IMPROVEMENT # 7 MISC IMPR-Y -------------------------------------------------
MAIN FIN AREA..
ACT/EFF YR/AGE.. 1974 1990 26
MAINTAINED.. 7/20/20BY
BY MAYES
STRAT.......... 05
DESCRIPT....
LOCATION #..... RD 1313
COMPONENT TYPE/CODE/DESC PCT
UNITS RATE STR# STR%
SIZ% HGT% PER%
CDS%
COST %CMPL
_________________________________________________________________________________________________________________
MS 39007 TANK OVR
QUAL.. QG
300.00
100 MISC IMPR QUALITY 10
100.00 x
0
DEPR.. D
OVERRIDE DEPRECIATIO 100.00
0
0 T
COND.. D
50 DEPRECIATION OVERBID x 50.00
50.00 -
PCT COMPLETE
100
675
__FMV...
__________________________________
IMPROVEMENT # 8 MISC IMPR_Y
_________________________________________________
MAIN FIN AREA..
ACT/EFF YR/AGE.. 1967 1984 32
CB
VISITED..
MAINTAINED..
BY
7/20/2016
BY MAYES
STRAT.......... 05
DESCRIPT.... 8'H
LOCATION #..... RD 1313
COMPONENT TYPE/CODE/DESC PCT
UNITS RATE STR# STR%
SIZ% HGT% PER%
CDS%
COST___ %CMPL___
MS 99024 MISC BUILDING OVR $2
QUAL.. QG
60.00
100 MISC IMPR QUALITY 10
100.00 x
0
DEPR.. D
OVERRIDE DEPRECIATIO 100.00
0 T
COND.. D
50 DEPRECIATION OVERBID x 50.00
00 -
0
PCT COMPLETE
100
260
__FMV...
TOTAL PARCEL VALUES---- LAND / OVR IMPROVEMENTS / OVR TOTAL
LAND/IMPROVE
3,814,516
2016 VALUE
3,814,516
FMV...... 441,322 3,373,194
APV...... 441,322 3,373,194
3,814,516
3,814,516
httplAw .webgis.net/nc/clevelard/PFopertyCard.php?pid=32623 314

Cleveland County NC Property Card
DATE 4/24/17 CLEVELAND COUNTY
PAGE
hdp:/Avww.webgis.mt/rc/clevelarKUPropertyCard.php?pid=32623 414

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Cleveland County, CLear\,Nater Site Vicinity Map
North Carolina Figure 1
32 Clayton Street
Asheville, North Carolina 28801

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Project Boundary �o
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------- 1,000 500 0 1,000 2,000
Project Boundary Feet.:'
lawn by: RPR 0 03\ ' EC Project#890 t 1 .i ' `• I. -`,;Y--- = it
CLearWater USGS Topographic Map
Cleveland County, - Shelby Quad
North Carolina 32 Clayton Street Figure 2
Asheville, North Carolina 28801

uearwater raper k -r/- LL mu)
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.d►\�s Property Boundary =
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_ 0 100 200 400 r
;Project Boundary { Feet
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'by: R P 05.03.17'
Cleveland County, CLearWater Aerial Map
North Carolina Figure 3
32 Clayton Street
Asheville, North Caroline 28801

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PbB2 - Paco let -Bethlehem Complex
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Cleveland County, CLearWater USDA Soils Map
North Carolina Figure 4
32 Clayton Street
Asheville, North Carolina 29801

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x
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e Jurisdictional wetlands and waters identified on this map have been located within sub. potentially Jurisdictional Water
meter accuracy utilizing a Trimble mapping grade Global Positioning System (GPS) and
r the subsequent differential correction of that data. GPS points may demonstrate i Wetland (AC) Stream (LF)
uncorrectable errors due to topography, vegetative cover, and/or mullipath signal error. �.
Note: The illustrated wetland and stream locations are approximate. These areas have
been gagged in the field; however, they have not been surveyed. Although Clearwater
Environmental Consultants, Inc. (CEC) is confident in our assessment, the US Army Corps - �,' Total 0 Total 0
of Engineers (Corps) is the only agency that can make final decisions regarding
jurisdictional wetland and waters of the US delineations. Therefore, all preliminary '�
determinations are subject to change until written verification is obtained. CEC strongly yr i� _ . ,.,.,
recommends that written verification be obtained from the Corps prior to closing on the �- -:, •�!'�:,Qr11CD, T
property, beginning any site work, or making any legal reliance on this determination. ,
This map was prepared by CEC using the best information available to CEC at the time of `+`�-'��♦ . '•
production. This map is for informational purposes only and should not be used to ,�._,�• •�; i_ �. � 'r3} �;
determine precise boundaries, roadways, property boundary lines, nor legal descriptions. - '"u •: rz?'
This map shall not be construed to be an official survey of any data depicted.
_a
Source Data: Cleveland County GIS e
/
Property Boundary
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Legend f _ / ,. N
Data Form
Contours
0 100 200 400
Project Boundary ; `,!' Feet
L---'
�-
LearWaLler Stream and Wetland
Cleveland County, Delineation Map
North Carolina 32 Clayton Street Delineated May 2, 2017
Asheville, Nonh Carolina 28801 Figure 5

gWETLAND DETERMINATION DATA FORM — Eastern Mountains and Piedmont Region
Project/Site: V����IL�t/ I'✓A}E� Pn�E/ City/County: SHP���i ��Irl/P�Gr ✓Id fid• Sampling Date:/
Applicant/Owner: State: Sampling Point: ;7L -
Investigator(s): YCAYI+ T Prn rYIP��V1 Section, Township, Range:
Landform (hillslope, terrace, etc.): 7ell"t, Local pre'lief (concave, convex, none): �n(of, ✓C( Slope I%): 2
Subregion(LRR or MLRA): IIZKN Let: 35, 310/30 Long: -91,07337 Datum: NpD C
Soil Map Unit Name: Pb92 fir olp i -&3 V lekevv\ (otr (Ie)( NWl classification: Nor'e-
Are climatic I hydrologic conditions on the site typical for this time of year? Yes _' No (If no, explain in Remarks.)
Are Vegetation Soil or Hydrology significantly disturbed? Are "Normal Circumstances" present? Yes No
Are Vegetation . 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.
Hydrophytic Vegetation Present?
Hydric Soil Present?
Wetland Hydrology Present?
- UPL
HYDROLOGY
Yes X No Is the Sampled Area
Yes No --X_ within a Wetland? Yes No
Yes No_
Wetland Hydrology Indicators:
Secondary Indicators (minimum of two recruited)
Primary Indicators (minimum of one is reouired: check all that aoolvl
_ Surface Soil Cracks (86)
_ Surface Water (A1)
_ True Aquatic Plants (B14)
_ Sparsely Vegetated Concave Surface (88)
_ High Water Table (A2)
_ Hydrogen Sulfide Odor (Cl)
_ Drainage Patterns (B10)
_ Saturation (A3)
_ Oxidized Rhizospheres on Living Roots (C3)
_ Moss Trim Lines (B16)
_ Water Marks (Bl)
_ Presence of Reduced Iron (C4)
_ Dry -Season Water Table (C2)
_ Sediment Deposits (B2)
_ Recent Iron Reduction in Tilled Soils (C6)
_ Crayfish Burrows (C8)
_ Drift Deposits (B3)
_ Thin Muck Surface (0)
_ Saturation Visible on Aerial Imagery (C9)
_ Algal Mat or Crust (B4)
_ Other (Explain in Remarks)
_ Stunted or Stressed Plants (D1)
_ Iron Deposits (B5)
_ Geomorphic Position (D2)
_ Inundation Visible on Aerial Imagery (B7)
_ Shallow Aquitard (D3)
_ Water -Stained Leaves (Bg)
_ Microtopographic Relief (134)
_ Aquatic Fauna (813)
_ FAC -Neutral Test (D5)
Field Observations:
Surface Water Present? Yes _
No -L Depth (inches):
Water Table Present? Yes _
No _X Depth (inches):
Saturation Present? Yes _
No X Depth (inches):
Wetland
Hydrology Present? Yes— NI-
includes capillary fringe)
Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:
Remarks:
US Army Corps of Engineers Eastern Mountains and Piedmont - Version 2.0

VEGETATION (Four Strata) — Use scientific names of plants.
Sampling Point: UPL
Tree Stratum (Plot size:
%Cover
Soecies?
izi
Number of Dominant Species
1. P rn r w fr, pdr
-7o_
x 3 =
FA
That Are OBL, FACW, or FAC: (A)
2. Fr V(I V S t/I ilnn
1
IV
SPL
Total Number of Dominant
6
3. C)Ve(ivr pi No,'
5
A
FL
Species Across All Strata: (B)
5
156-
4. Vu! ✓5 Percent of Dominant Species
S. That Are OBL, FACW, or FAC: BY, (A/8)
7. --
q = Total Cover
50% of total cover: 4 ), 20% of total cover: 19
SaolinelShrub Stratum (Plot size: I r) ) _
1. A0.14 Ito
2. TO> il-I_ n —I-
7
A= Total Cover
50% of total cover: %i 20% of total cover: 12 -
Herb
LHerb Stratum (Plot size: �i )
2. P ! f!- F 1)! '�, vt orr ,ro(r,f,e, I U A
7
Total % Cover of:
Multi by:
OBL species
x 1 =
FACW species
x 2 =
FAC species
x 3 =
FACU species
x 4 =
UPL species
x 5 =
Column Totals:
(A) (B)
Prevalence Index = BIA =
_ 1 - Rapid Test for Hydrophylic Vegetation
,, 2 - Dominance Test is >50%
_ 3 - Prevalence Index is 53.0'
4 - Morphological Adaptations' (Provide supporting
data in Remarks or on a separate sheet)
_ Problematic Hydrophytic Vegetation' (Explain)
'Indicators of hydric soil and wedand hydrology must
be present, unless disturbed or problematic.
Tree - Woody plants, excluding vines, 3 in. (7.8 cm) or
more In diameter at breast height (DBH), regardless of
height.
Sapling/Shrub - Woody plants, excluding vines, less
than 3 in. DBH and greater than or equal to 3.28 it 0
m) tall.
11. Herb - All herbaceous (non -woody) plants, regardless
S� = Total Cover of size, and woody plants less than 3.28 it tall.
50% of total cover: Z �J 20% of total cover: ) L)
Woody vine -All woody vines greater than 3.28 it in
Woody Vine Stratum (Plot size: Q ) I S qY�L height.
1. TO (7V %1 Yr%/lrii,�l rf �7 VIANC
2.
Hydrophylic
rr Vegetation
"J = Total Cover Present? Yes X No
50% of total cover: 7, 20% of total cover: 3
rs here or on a separate sheet.)
US Army Corps of Engineers Eastern Mountains and Piedmont - Version 2.0

SOIL
Sampling Point: UPL- I
Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.)
Depth Matrix
Redox Features
(inches) Color (moist) %
Color (moist) Tvoe Loc
Texture Remarks
0-1-L 7. 5 A 516100
'Type: C=Concentration, D=De letion, RM=Reduced
Matrix, MS=Masked Sand Grains.
Location: PL=Pore Lining, M=Matrix.
Hydric Soil Indicators:
Indicators for Problematic Hydric Soils':
_ Histosol (Al)
_ Dark Surface (S7)
_ 2 cm Muck (A10) (MLRA 147)
_ Histic Epipedon (A2)
_ Polyvalue Below Surface (SB) (MLRA 147, 148) _ Coast Prairie Redox (At 6)
_ Black Histic (A3)
_ Thin Dark Surface (S9) (MLRA 147, 148)
(MLRA 147, 148)
_ Hydrogen Sulfide (A4)
_ Loamy Gleyed Matrix (F2)
_ Piedmont Floodplain Soils (1`19)
Stratified Layers (A5)
_ Depleted Matrix (0)
(MLRA 136, 147)
_ 2 cm Muck (A10) (.RR N)
_ Redox Dark Surface (F6)
_ Very Shallow Dark Surface (TF1 2)
_ Depleted Below Dark Surface (All)
_ Depleted Dark Surface (F7)
_ Other (Explain in Remarks)
_ Thick Dark Surface (Al2)
_ Redox Depressions (F8)
_ Sandy Mucky Mineral (S7) (.RR N,
_ Iron -Manganese Masses (F12) (LRR N,
MLRA 147, 148)
MLRA 136)
_ Sandy Gleyed Matrix (S4)
_ Umbric Surface (F73) (MLRA 136, 122)
'Indicators of hydrophytic vegetation and
_ Sandy Redox (S5)
_ Piedmont Floodplain Soils (1719) (MLRA 146) wetland hydrology must be present,
_ Stripped Matrix (S6)
_ Red Parent Material (F21) (MLRA 127, 147)
unless disturbed or problematic.
Restrictive Layer (if observed):
Type:
Depth (inches):
Hydric Soil Present? Yes No
Remarks:
US Army Corps of Engineers Eastern Mountains and Piedmont - Version 2.0