20050289 Ver 1_More Info Received_20081020

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I N C O R P O R A T E D
October 20, 2008
Ms. Cyndi Karoly
N.C. Department of Environment and Natural Resources
401 Oversight Unit
2321 Crabtree Boulevard
Raleigh, NC 27604-2260
RE: Action ID # SAW 2004-00-210
Central Carolina Tire 4041401 Permit
Harnett County, North Carolina
Dear Ms. Karoly:
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On behalf of our client, Central Carolina Tire (CCT), we respectfully request that
the mitigation component of the 401 DWQ certification be modified. The purpose
of this request is two-fold. First, despite our best efforts we have failed to find a
third party conservation easement holder. Secondly, after nearly two full growing
seasons of monitoring the ground water table at the proposed wetland creation
area on-site, we have discovered that the groundwater' table stays mostly (out of
range) of our 48" monitoring wells. Since the designated wetland creation area
was the best choice within our project site, we have concluded that should we
proceed with the initial mitigation proposal; sustaining the success criteria would
be questionable at best.
We have been working with Ronnie Smith of the U.S. Army Corps of Engineers
to develop an alternative mitigation plan. The plan consists of protecting the
remaining undisturbed wetlands and associated upland buffer on-site by placing
a Declaration of Restrictive Covenants on them to ensure that they remain in
their natural condition in perpetuity. The physical protection of the mitigation
area on-site would be augmented by the erection of a fence around the outside
perimeter of the entire mitigation area. Our experience has been that fencing is
much more effective than simply posting signs around the perimeter. The fence
will serve as a physical barrier to keep all the activities occurring on the adjacent
tire monofill from ever encroaching upon the on-site mitigation area. We have
enclosed figures detailing the location of the proposed fence line and the type of
fence to be utilized for your review and information.
WWW.TliEbRIC,MANCOMPANY.COM
P.O. Box 1532 - CONWAY, SC 29528 - [phone] - FAX [phone]
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Ms. Cyndi Karoly
Page 2
To compensate for the loss of resources the applicant proposes to acquire
mitigation from EEP on a one-to-one basis.
We have attached a copy of correspondence from the NC EEP which verifies
availability of the credits along with a copy of an email correspondence to Ronnie
Smith stating the mitigation on a one-to-one ratio will suffice. We are hereby
requesting that the current 401 DWC certification be modified to reflect this
proposal.
Should you have any questions, please advise. Thank you in advance for your
assistance and support with this matter.
Sincerely,
Joseph C. Floyd
Project Manager
JCF/alj
Enclosures
cc: Tammy Hill - NC Division of Water Quality
Ronnie Smith - USACOE
MAJOBS1200710112M72421Agency CorespondlCyndi Karoly.doc

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CCT SAW 2004-00-210
Subject: CCT SAW 2004-00-210
From: "Amy Johnson" <[e-mail]>
Date: Mon, 20 Oct 2008 12:43:12 -0400
To: <[e-mail]>, <[e-mail]>,
<[e-mail]>
CC: "Joe Floyd" <[e-mail]>
Please see the attached letter from Joe Floyd.
Thanks!
AMY L. JOHNSON
BI&C,MAN
COMPANY
Office Manager
0 800 Legion Street
Conway, SC 29526
Phone: [phone]
Fax: [phone]
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I O N 11/3/2008 11:53 AM