20170905 Ver 2_ External Request for Additional Information SAW-2017-01582_20180509

Strickland, Bev
From: Bailey, David E CIV USARMY CESAW (US) < [e-mail] >
Sent: Wednesday, May 09, 2018 10:45 AM
To: wyatt brown
Cc: Homewood, Sue
Subject: [External] Request for Additional Information: Graham Drive -In PCN, Alamance
County; SAW -2017-01582
Attachments: NCWAM - Wetland D.pdf
Mr. Brown,
Thank you for your PCN and attached information, dated and received 5/3/2018, for the above referenced project. I
have reviewed the information and need clarification before proceeding with verifying the use of Nationwide Permit 39
(http://saw-reg.usace.army.mil/NWP2017/2017NWP39.pdf). Please submit the requested information below (via e-mail
is fine) within 30 days of receipt of this Notification, otherwise we may deny verification of the use of the Nationwide
Permit or consider your application withdrawn and close the file:
1) Plan Sheet 2/2 states (and the PCN indicates) that no fill or permanent structures are proposed within the 100 -
year floodplain. However, the National Flood Hazard map indicated that Crossing 1 would occur within Flood
Zone AE. Please explain this discrepancy and add the 100 -year floodplain line to the plansheet(s). Note that
NWP 39 cannot be used to authorize above grade fills within the mapped FEMA 100 -year floodplain (NWP 39
Regional Condition 4.1.4). If proposed activities related to Crossing 1 occur within the mapped FEMA 100 -year
floodplain, we recommend that you request to use NWP 14 for these impacts;
2) The Typical Culvert Crossing Illustration shown on Plansheet 2/2 is too generic to allow compliance inspections
of this project. Please provide zoomed -in detail and plan view sheets of each road crossing, clearly showing the
following:
a. stream and wetland boundaries;
b. different hatching for the footprint of wetland and stream impacts, including impacts due to fill (in
wetlands), impacts due to culverts, impacts due to rip rap pads (clearly showing the rip rap will be
imbedded), and temporary impacts outside of the permanent impact areas needed for construction
access/dewatering;
c. footprint of the existing culverts;
d. footprint of the proposed culverts;
3) Please confirm that the existing stream beds at Crossings 1 and 2 are wide enough to fit the proposed twin
culvert pipes (42" and 30", respectively), so as to fit NWP 14 Regional Condition 3.6.4. Further, how will the
crossings fit NWP Regional Condition 3.6.2?
4) Wetland AA at Crossing 1 extends beyond the crossing corridor and should be noted as such on the plan sheet.
Also, the downstream end of Wetland AA does not appear to extend all the way to the end of the fill slope. This
correction should be made on the plansheet and the wetland impacts updated on the PCN;
5) Impacts to Wetland D include only a portion of the total wetland area, with the remaining wetland proposed to
total 615 square feet. Since this remaining wetland is very small, and it's location between two roads would
eliminate any remaining wetland function, this remaining wetland area should be considered a loss of wetlands.
This loss should be shown on the plan sheet and accounted for on the PCN. Note that, if this additional loss of
wetlands causes the total wetland impact amount to reach 0.1 acre, and if no compensatory mitigation is

proposed, you will need to include a justification based on Wetland D's low aquatic function (see attached
NCWAM form for Wetland D);
6) Impacts to Wetland B appear to be proposed at the downstream end of Crossing 2, although they are not
accounted for on the Plans or the PCN.
Please let me know if you have any questions.
Sincerely,
Dave Bailey
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE -SAW -RG -R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Phone: [phone], Ext. 30.
Fax: [phone]
Email: David. [e-mail]
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