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North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary Susi H. Hamilton
Match 14, 2018
Bradley Luckey
Pilot Environmental
PO Bos 128
Kernersville, NC 27285
bluckey� I?Hoten_y ,ito.com
RE: Egger Woods Products Manufacturing Facility, Belmont Road, Linwood,
Davidson County, ER 18-0115
Dear Mr. Luckey:
Office of Archives and History
Deputy Secretary Kevin Cherry
Thank you for your February 20, 2018, email providing additional maps and information concerning the above -
referenced project that requires a permit from the US Army Corps of Engineers. We appreciate the excellent
set of maps and copies of emails from Davidson County that better outline and explain the Egger Wood
Products project and location within the Davidson County Corporate Industrial Site.
Based on the information provided, we are able to find that the proposed undertaking will not adversely affect
the historic and relocated Beallmont Plantation House as the project site is well removed from the house and
the county's regulations require landscaping along Belmont Road as the industrial park is further developed.
The above comments are made in accord with Section 106 of the National Historic Preservation Act and the
regulations of the Advisory Council on Historic Preservation at 36 CFR 800. If you have any questions
concerning them, please contact me at 919-807-6579 or renee.gledhill-earley@ncdcr.gov
Sincerely,
Renee Gledhill-Eatley
Environmental Review Coordinator
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/F=:(919)807-6570/807-6599
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Post Construction Stormwater Table
Criteria
State/Local Standard
As Designed
Exceeded Amounts
Surface Area (SF)
107,782
116,538
8%
Volume (CF)
486,999
559,375
13%
1Yr. event — 85%
1Yr. event — 85%
peak flow rate
peak flow rate
reduction
reduction
2 Yr. event — 78%
2 Yr. event — 78%
peak flow rate
peak flow rate
Pre -Post
reduction
reduction
Detention/Reduction
No Requirement
of Peak Run-off
10 Yr. event — 53%
10 Yr. event — 53%
peak flow rate
peak flow rate
reduction
reduction
100 Yr. event — 41%
100 Yr. event — 41%
peak flow rate
peak flow rate
reduction
reduction
Strickland, Bev
From: Brad Luckey <bluckey@pilotenviro.com>
Sent: Monday, March 19, 2018 10:16 AM
To: Jones, M Scott (Scott) CIV USARMY CESAW (US)
Cc: Roden Reynolds, Bryan K CIV (US); Homewood, Sue; Vorreiter Bernhard
Subject: [External] RE: 20180316 Site Meeting Follow -Up - Egger Wood Products - Davidson
County
Attachments: ER 18 0115 -5 -final letter.pdf, SW Table FINAL.PDF; Dublin Wet Overlay Site Plan.pdf;
Orangeburg Wet Overlay Site Plan.pdf
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an
attachment to Report Spam.<mailto:report.spam@nc.gov>
Scott,
Thank you for taking the time to meet with me and providing us this information in Bryan's absence. Please accept the
below applicant responses and attachments to address the USACE comments provided in your e-mail dated 3.15.18.
USACE Comment 1: We acknowledge the ongoing consultation efforts with NCSHPO regarding the Beallmont House
(DV0007). Please keep us informed of this effort in order to comply with Section 106 / historic properties requirements.
We will need to conclude this effort and incorporate any resulting terms and conditions prior to issuing Department of
the Army authorization.
Applicant Response: PEI provided information to SHPO detailing exact location of the proposed project and County
zoning requirement for vegetative screens for the proposed Egger Parkway, being completed by others. The USACE was
copied on this e-mail correspondence dated 2.2.18. According to the attached SHPO response letter, dated 3.14.18, the
SHPO has reviewed this new information and made the determination that the proposed project will not adversely
affect the relocated Beallmont House (DV0007).
USACE Comment 2: The submitted plans show a proposed rail yard and spur lines along the southern and western
portion of the tract. Will this track infrastructure connect to the existing railroad line and switchyard located to the
south (off-site the industrial park)? If so, who is responsible for obtaining authorization for this work off site? Railroad?
Egger? As we discussed, any impacts associated with a connecting rail line will be considered cumulative to the project.
Applicant Response: The proposed rail spur on the Egger proposed project area is the responsibility of Egger. Egger is
not responsible for any work outside of the proposed Egger project area. Egger is not aware of impacts to WoUS
occurring as a result of improvements that may be necessary for the rail road to provide rail service to the Egger project
location. Egger is aware that any impacts outside of the Egger project area that could occur as a result of the proposed
project would be considered cumulative in accordance with a single and complete project as defined in the federal Code
of Federal Regulations (CFR) at 33 CFR 330.2(i).
USACE Comment 3: Regarding the alternatives analysis, the Corps requires additional documentation about the three
finalist sites - specifically, the conceptual site plans and potential impacts to Waters of the United States. The applicant's
Off -Site Analysis provided with the initial application package provided only summarized information (Table 3 and
Section 2.1). While your response dated March 7, 2018, provided some clarification, submission of the conceptual plans
for each of the three finalist sites and any supporting wetland / stream information for those sites is requested to
support the conclusions in the alternatives analysis. We understand the applicant's position that this information is
sensitive in nature and will regard the submitted materials as confidential and/or proprietary if requested.
Applicant Response: Please find the attached conceptual site plans overlaid on the stream/wetland surveys for the
other Orangeburg, SC and Duplin, GA finalist sites. Please note, as previously detailed information submitted to the
USACE, the USACE JD for the Orangeburg, SC site has expired and that these are conceptual site plans without final
designed impact amount of WoUS. The attached conceptual plans provide justification to estimated impact amounts to
WoUS that were previous provided to the USACE. The applicant requests that the attachments contain confidential
information and/or financial information. Confidential treatment of the conceptual site plans is requested by Egger
Wood Products LLC. Do not release under FOIA without prior authorization from Egger Wood Products LLC. Additionally,
the applicant requests that these attachments be redacted from NCDEQ-DWR publically available records.
USACE Comment 4: Provide a comparison table of the post -construction stormwater treatment system depicting local
and state minimum standards to actual treatment standards of the system.
Applicant Response: Please find the attached request table.
USACE Comment 5: Based on PEI's involvement with this industrial park for more than a decade, provide a summary of
the park's development history and/or timeline including prior grading activities, discharges of fill, road construction,
utility line construction, etc.
Applicant Response: PEI personnel visited the larger industrial park in early 2014, prior to delineating the larger tract in
2015. During the visit, Pilot observed the vicinity of the non -jurisdictional pond, centrally located on the Egger project
site. At that time, the non -jurisdictional pond was being lowered by pumping to a diversion ditch which discharged
approximately 500 feet up -gradient of the jurisdictional open water pond on the Egger project area. The diversion ditch
appeared to be freshly excavated, did not contain hydric soils or soil wetness indicators of a seasonal high water table
(i.e. mottles of Chroma 2 or less), did not contain stream characteristics (meanders, substrate sorting, riffle -pool
complexes, etc.) and was not hydrologically connected to the non -jurisdictional pond or other down -gradient
jurisdictional waters. The diversion ditch was located immediately adjacent to a wooded hedgerow in uplands. PEI did
not observe any evidence of any discharges of fill or excavation in jurisdictional waters in the observed portions of the
larger industrial park during the early 2014 site visit.
During the visit in early 2014, a former landowner reported to PEI that that the non -jurisdictional pond was constructed
in uplands for irrigation purposes. The previous landowner stated that the pond did not discharge and water level was
controlled by pumping only. The farmer indicated that due to their irrigation practices, the pond was rarely pumped to
prevent water level from over topping the pond dam. Additionally, the landowner reported to PEI that portions of the
larger industrial park were historically used for borrowing and wasting activities most recently with a DOT project, but
also with utility line and railroad projects in the past. The previous landowner did not indicate any information to PEI
that would suggest that there had been any potential previous discharges of fill to jurisdictional waters in the larger
industrial park.
Sincerely,
Bradley S. Luckey, PWS
336.708.4997 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
www.pilotenviro.com
bluckey@pilotenviro.com
-----Original Message -----
From: Jones, M Scott (Scott) CIV USARMY CESAW (US) [mailto:Scott.Jones@usace.army.mil]
Sent: Thursday, March 15, 2018 10:55 AM
To: Brad Luckey <bluckey@pilotenviro.com>
Cc: Roden Reynolds, Bryan K CIV (US) <Bryan.Roden-Reynolds@usace.army.mil>
Subject: 20180316 Site Meeting Follow -Up - Egger Wood Products - Davidson County
Brad -
Thanks for scheduling time to meet me on-site this past Friday in Linwood, NC. As we discussed, Bryan is TDY this week
at a training class and I wanted to give you a jump start on some additional information / clarification the Corps needs in
order to continue moving forward on the Egger application. Bryan may have some additional comments upon his
return.
1. We acknowledge the ongoing consultation efforts with NCSHPO regarding the Beallmont House (DV0007). Please
keep us informed of this effort in order to comply with Section 106 / historic properties requirements. We will need to
conclude this effort and incorporate any resulting terms and conditions prior to issuing Department of the Army
authorization.
2. The submitted plans show a proposed rail yard and spur lines along the southern and western portion of the tract.
Will this track infrastructure connect to the existing railroad line and switchyard located to the south (off-site the
industrial park)? If so, who is responsible for obtaining authorization for this work off site? Railroad? Egger? As we
discussed, any impacts associated with a connecting rail line will be considered cumulative to the project.
3. Regarding the alternatives analysis, the Corps requires additional documentation about the three finalist sites -
specifically, the conceptual site plans and potential impacts to Waters of the United States. The applicant's Off -Site
Analysis provided with the initial application package provided only summarized information (Table 3 and Section 2.1).
While your response dated March 7, 2018, provided some clarification, submission of the conceptual plans for each of
the three finalist sites and any supporting wetland / stream information for those sites is requested to support the
conclusions in the alternatives analysis. We understand the applicant's position that this information is sensitive in
nature and will regard the submitted materials as confidential and/or proprietary if requested.
4. Provide a comparison table of the post -construction stormwater treatment system depicting local and state minimum
standards to actual treatment standards of the system.
5. Based on PEI's involvement with this industrial park for more than a decade, provide a summary of the park's
development history and/or timeline including prior grading activities, discharges of fill, road construction, utility line
construction, etc.
Thanks again.
Scott Jones
CESAW-RG-Asheville & Charlotte
151 Patton Avenue, Room 208
Asheville, NC 28801-5006
Office - 828.271.7980, ext. 4222
Facsimile- 828.281.8120