20181552 Ver 1_more information received_20190206

Homewood, Sue
From:Barksdale, Flynt <[e-mail]>
Sent:Wednesday, February 6, 2019 8:34 AM
To:Homewood, Sue
Cc:Roden Reynolds, Bryan K CIV (US); DePalma, Alicia; Bailey, Stephen
Subject:RE: \[External\] SAW-2018-02133_Mill Creek Stream Restoration (Notice of Pre-
Construction Notification )
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Sue,

Thank you for taking time to speak with me last week. See below for my responses to your comments.

Feel free to give me a call if you would like to discuss further.

Flynt

W. Flynt Barksdale, PWS
Senior Scientist | Environmental Services

Pond | 3500 Parkway Lane | Suite 500
Peachtree Corners, GA 30092
p 678.336.7740 | f 678.336.7744 | direct: 678.459.2470 | mobile: [phone]
www.pondco.com

From: Homewood, Sue <[e-mail]>
Sent: Tuesday, January 15, 2019 8:52 AM
To: Barksdale, Flynt <[e-mail]>
Cc: Roden Reynolds, Bryan K CIV (US) <[e-mail]>
Subject: RE: \[External\] SAW-2018-02133_Mill Creek Stream Restoration (Notice of Pre-Construction Notification )

EXTERNAL EMAIL
Thank you Flynt,

I reviewed the documents this morning and have a few follow up questions before I can issue an approval.

1. Our General Certifications require that work be done in the dry. Please clarify if it is intended for the channels
(including Mill Creek) to be dewatered (pump around or other means) during construction activities. If you
propose working “in the wet” then we will need a justification for doing so and a discussion of what
special/additional measures will be taken to ensure protection of downstream waters. For any locations you
propose working in the dry we will need updated PCN impact tables and updated plans to show where there will
be temporary impacts from sandbag/pump around systems.
The proposed stream stabilization is to be constructed in the “wet”. However, construction has been scheduled
for mid to late summer. All work will be completed from top-of-bank and equipment will not be working from
within the creek. Additionally, constant review of weather conditions and forecasts will enable the Construction
Environmental Inspector to stop work should a rainfall event be imminent. A turbidity curtain will be added to
the ESPC plan and will be installed within the previously proposed work limits.
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The culverts are to be installed on the same schedule of mid-late summer. Rainfall events will be monitored and
the final schedule will be dictated for optimal conditions. Pond has confirmed that a pump-around system will
be able to fit within our USACE authorized permit area. Additional notes and details will be added to the plan
sheets to ensure the culverts are installed in the dry.

2. I have walked the ROW (both gas and sewer) multiple times over the last few years, and while there are
certainly wet areas that could be problematic for equipment during wet times, the channels are very low flow
and should be able to be forded/crossed by equipment during dry weather conditions without the need for
culverts. It is unclear why equipment cannot continue to access these areas without culverts. Maintenance
activities, including tree trimming should be able to be scheduled such that it could be done in dry seasons.
These areas are small and typically do carry low flow. However, this overall area is an active floodplain to Mill
Creek and contains multiple wetland areas. PNG has decided the best path forward for maintenance and
resource stability would be the installation of culverts. The installation of these culverts will provide for stable
crossing areas and will allow PNG routine access without the need to restore damaged creek banks. The current
method of crossing these areas generates temporary impacts and sedimentation to downstream waters. PNG is
committed to reducing the overall impacts and sedimentation to waters.

3. Culverts installed for equipment crossing/access for utility ROWs should be the minimum length necessary to
meet regulations which require that the applicant avoid and minimize to the maximum extent practical. Typical
culvert lengths seen for utility crossings are 10-20 feet in length. Please explain why the crossings are proposed
for 30’ pipe lengths.
The length of pipe was decided based on many factors. The main reason for a longer culvert is to provide for a
~14’ travel corridor (+5’ on either end) to ensure large, heavy equipment, as utilized in pipeline repair, does not
crush the end of the culverts causing the structures to fail. The additional length of pipe was due the angle at
which the culvert crosses the travel path.

4. The channels proposed for culverts are very small with a mostly pervious watershed and low flow
conditions. Typical installation of culvert crossings along utility ROWs do not require extensive riprap aprons as
are being proposed for this project. In addition, the riprap aprons are being proposed to be installed on the
City’s sewer ROW. The photographs provided do not indicate excessive erosion within the channels and the
channels within the sewer ROW were recently restored after sewer installation so are likely to be in a stable
condition. Please provide justification for the addition of large riprap aprons below the proposed culverts.
The outlet stabilization structures (rip-rap aprons) are designed and specified based on the State Erosion Control
manual. The length of the structure is determined based on engineering calculations. Based on these
calculations and the state manual, outlet stabilization is required as the calculated discharge velocity exceeds
the permissible velocity of the receiving channel.

Thanks,

Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality

336 776 9693 office
336 813 1863 mobile
[e-mail]
2

450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Barksdale, Flynt <[e-mail]>
Sent: Monday, January 14, 2019 7:19 PM
To: Homewood, Sue <[e-mail]>
Cc: Roden Reynolds, Bryan K CIV (US) <[e-mail]>
Subject: Re: \[External\] SAW-2018-02133_Mill Creek Stream Restoration (Notice of Pre-Construction Notification )

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Sue,
I apologize. Coming your way shortly.
Flynt
Get Outlook for Android

From: Homewood, Sue <[e-mail]>
Sent: Monday, January 14, 2019 5:45:34 PM
To: Barksdale, Flynt
Cc: Roden Reynolds, Bryan K CIV (US)
Subject: RE: \[External\] SAW-2018-02133_Mill Creek Stream Restoration (Notice of Pre-Construction Notification )

EXTERNAL EMAIL
Flynt,

I just went to start my review of this project and realized that I only have part 1 of 3 of your response to Bryan. Would
you please forward the other documents/emails to me also.

Thanks,

Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality

336 776 9693 office
3

336 813 1863 mobile
[e-mail]

450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Barksdale, Flynt <[e-mail]>
Sent: Monday, December 10, 2018 11:59 AM
To: Homewood, Sue <[e-mail]>; Roden Reynolds, Bryan K CIV (US)
<[e-mail]>
Cc: [e-mail]
Subject: RE: \[External\] SAW-2018-02133_Mill Creek Stream Restoration (Notice of Pre-Construction Notification )

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Sue,

I am not sure how you were not CC’d on my reply.

Please see the attached response to Bryan. If you would like, I could send you the follow pieces of the PCN as well.

So sorry for the omission.

W. Flynt Barksdale, PWS
Senior Scientist | Environmental Services

Pond | 3500 Parkway Lane | Suite 500
4

Peachtree Corners, GA 30092
p 678.336.7740 | f 678.336.7744 | direct: 678.459.2470 | mobile: [phone]
www.pondco.com

From: Homewood, Sue <[e-mail]>
Sent: Monday, November 26, 2018 11:37 AM
To: Roden Reynolds, Bryan K CIV (US) <[e-mail]>; Barksdale, Flynt
<[e-mail]>
Cc: [e-mail]
Subject: RE: \[External\] SAW-2018-02133_Mill Creek Stream Restoration (Notice of Pre-Construction Notification )

Gentlemen,

Please copy me on your response to Bryan.

Thanks,

Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality

336 776 9693 office
336 813 1863 mobile
[e-mail]

450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Roden Reynolds, Bryan K CIV (US) <[e-mail]>
Sent: Wednesday, November 14, 2018 11:24 AM
To: [e-mail]
Cc: [e-mail]; Homewood, Sue <[e-mail]>
Subject: \[External\] SAW-2018-02133_Mill Creek Stream Restoration (Notice of Pre-Construction Notification )
Importance: High
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attachment to Report Spam.

Mr. Barksdale,

On November 13, 2018, we received the Pre-Construction Notification you submitted on behalf of Duke Energy on a
property located in Forsyth County, North Carolina. I have completed my initial review of the report and I have
determined that it is incomplete. The following information is necessary before I will issue a Nationwide Permit:

a. The Pre-Construction Notification was not signed and dated. For the Pre-Construction Notification to be considered
valid and complete the applicant or agent, acting for the applicant, must sign and date the Pre-Construction Notification
package. Please see reference screenshot below for where signature and date is needed.

b. You requested a Nationwide Permit 14 (Linear Transportation Projects) for some of the proposed permanent stream
and wetland impacts. However, this project does not qualify for a Nationwide Permit 14; as a Nationwide Permit 14
clearly states “Activities required for crossings of waters of the United States associated with the construction,
expansion, modification, or improvement of linear transportation projects (e.g. roads, highways, railways, trails, airport
runways, and taxiways) in waters of the United States.” The proposed impacts you associated with a Nationwide Permit
14 could be permitted under a Nationwide Permit 12 (Utility Line Activities). Under a Nationwide Permit 12, it states the
following “…authorizes the discharges of dredged or fill material into waters of the United States and structures or work
in navigable waters for crossings of those waters associated with the construction, maintenance, or repair of utility
lines…” In addition this permit authorizes access roads and states “… the construction of access roads for the
construction and maintenance of utility lines…” I have attached Nationwide Permits 12 and 14 for your reference.
Please revise your Pre-Construction Notification package accordingly.

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c. You requested a Nationwide Permit 27 (Aquatic Habitat Restoration, Enhancement, and Establishment Activities) for
some portion of stream impacts. Nationwide Permit 27 states “To be authorized by this Nationwide Permit, the aquatic
habitat restoration, enhancement, or establishment activity must be planned, designed, and implemented so that it
results in aquatic habitat that resembles an ecological reference.” In your Pre-Construction Notification package you did
not provide a restoration plan which typically includes natural stream channel design. Your Pre-Construction Notification
lacked sufficient detail to justify permitting portions of this proposed project under Nationwide Permit 27. The only
detail that was provided stated “The stream restoration activities will include erosion and sediment control, bank
stabilization, instream installation of run, riffle, pool complex,…” This statement does not qualify as a stream restoration
plan. You need to develop this plan to include, but not limited to, types of natural materials used, amount of natural
material used, type of channel designs/improvements, etc. Therefore, please include a detailed Stream Restoration Plan
as part of the revised Pre-Construction Notification package.

d. In Part C(3)(a), you listed the 635 linear feet of stream impacts to Mill Creek as temporary. However, these stream
impacts would be considered permanent. Please revise the Pre-Construction Notification package accordingly.

e. In the Pre-Construction Notification package, you state “Three culverts are to be installed for permanent crossings of
PNG right-of-way.” Please justify why these additional crossings are needed for the utility line right-of-way and why
current maintenance access for this existing utility line is not and will not be utilized, thus requiring the additional
permanent stream impacts. As currently presented, these permanent stream impacts to install culvert crossings do not
demonstrate avoidance and minimization.

f. Have you considered temporary stream impacts for maintenance crossings in the form of articulated grouted mats
instead of culvert crossings?

Please provide the information requested above in ONE consolidated response within 30-days of the date of this
correspondence. If you do not respond within 30-days, the request will be administratively canceled. Please contact me
via telephone or e-mail if you have any questions.

Thanks,

Bryan Roden-Reynolds, WPIT
Regulatory Project Manager
U.S. Army Corps of Engineers
Charlotte Regulatory Office
7

8430 University Executive Park Drive
Charlotte, NC 28262
Office: [phone]

The Wilmington District is committed to providing the highest level of support to the public. To help us ensure we
continue to do so, please complete the Customer Satisfaction Survey located at
http://corpsmapu.usace.army.mil/cm_apex/f?p=136:4:0

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