20171527 Ver 1_Response Memo 073019_20190730

TIMMONS GROUP
YOUR VISION ACHIEVED THROUGH OURS.
July 30, 2019
Mr. Ross Sullivan
Regulatory Specialist
Raleigh Regulatory Field Office
U.S. Army Corps of Engineers - Wilmington District
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
5410 Trinity Road P 919.866.4951
Suite 102 F 919.859.5663
Raleigh, NC 27607 www.timmons.com
Ms. Sue Homewood
Division of Water Resources, Winston Salem Regional Office
North Carolina Department of Environmental Quality
450 West Hanes Mill Road, Suite 300
Winston Salem, North Carolina 27105
Re: Request for Additional Information - Person County Mega Site - (DWR: 20171527,
USACE: SAW -2016-02542, and NCSHPO: ER -14-1122)
Dear Mr. Sullivan & Ms. Homewood,
Please find responses to the items requested by the North Carolina Division of Water Resources
(DWR) in a letter dated February 19, 2019, by the U.S. Army Corps of Engineers (USACE) in a letter
dated May 21, 2019, and by the North Carolina Department of Natural and Cultural Resource, State
Historic Preservation Office (NCSHPO) in a letter dated February 4, 2019 for the Individual Permit
application of January 8, 2019 in association with the Person County Mega Site project located in
Person County, North Carolina.
Comments below from the DWR (in black) with responses (in red):
1) If the U.S. Army Corps of Engineers requests a response to any comments received as a result of
the Public Notice, please provide the Division with a copy of your response to the USACE. [15A
NCAC 02H.0502(c)]
A copy of the responses to the USACE is provided herein to the North Carolina Division of
Water Resources (DWR).
2) Please provide more details regarding avoidance and minimization ofimpacts for this project. It
appears that the circulatory roadway is for the purpose ofserving future ancillaryfeaturesand
future traffic needswhich are not partofthe purpose and needof this current application. Provide
detailed justification for the need, location, and roadway width/lanes for the circulatory
roadway. [15ANCAC 0211-0506(f)and(g)]
In the previous submittal, two phases were shown that required a more robust version of
road widening on the existing Edwin Robertson Road and a loop road that was a divided 4 -
lane median road which tied into Edwin Robertson Road.
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This submittal, which is only inclusive of one phase of construction, shows the loop road as a
2 -lane roadway in one portion, and a 4 -lane median divided road in another portion, with
minimal change to Edwin Robertson Road. A Traffic Impact Analysis (TIA) was performed in
2017 (included in the permit application) that determined the road network necessary to
meet the program needs for Phase I of this project, which is shown with this submittal.
3) Provide adetailedsiteplan onfullplan sheets atascale ofnosmaller than 1"= 50'with topographic
contours shown for the proposed project, all transportation improvements (including stormwater
management from roadway improvements) and utility improvements associated with this
project. Please re-submityoursiteplans onfullplan sheets atascale ofnosmaller than 1"=50'with
final topographic contours shown. [15A NCAC 02H.0502]
A revised, detailed site plan on full plan sheet at a scale of 1" = 50' with final topographic
contours shown is provided as Attachment A. The plan includes sheets related to the utility
design as well as stormwater design. The plan also includes the roadway improvements
required for Country Club Road. A grading and drainage plan (see Sheets C4.0 -C4.9) is also
within the construction document set that shows existing and proposed contours.
4) Pmvidea detailed engineering plan, profile view, and cross-section of all proposed impact areas.
These drawings must include details regarding proposed final contoursforfill/cut areas, stream
alignment in relation to pipe alignment, pipe slope, pipe burial, dissipater pad requirements, and
temporary dewatering design and impacts, adjacent sediment and erosion control measures, and
plans for restoration of any temporarily impacted areas. [15A NCAC 02H .0502(b)]
A detailed engineering plan, profile view, and cross-section of all proposed impact areas is
provided as Attachment B. Profiles have been shown that show the pipe outlet locations in
relation to the stream impacts. These profiles show pipe alignment, pipe slope, pipe burial
and dissipator pad requirements along with sediment and erosion control efforts. The
profiles also show temporary dewatering and temporary erosion control measures in
streams where there will not be permanent impacts. We have also provided culverts at road
crossings in strategic locations that will allow stream recharge to existing streams and
minimize flow reduction.
It is worth noting that the proposed loop road that surrounds the site acts as an outer
boundary of disturbance by the project site, with some exceptions. In most cases, there is no
stream inlet above the road crossings that would normally be encountered with a roadway
system. Therefore, most of the profiles do not have a typical upstream pipe inlet that would
generally be seen with a roadway stream crossing.
5) Please provide an updated acceptance letter from the Division of Mitigation Services (current
letter to expire 2/24/2019) or an alternative mitigation plan that conforms to the requirements
of 15A NCAC 0211.0500 and G.S. 143-214.11. [15A NCAC 02H.0502(h)]
An updated acceptance letter from the Division of Mitigation Services is provided as
Attachment C.
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6) In orderfor the Division to accurately determine the required amountofmitigation in accordance
with state statutes, provide documentation of intermittent and perennial stream callsasverified by
the Division ofWaterResourcesstaff. [15ANCACO211. 0502(h)]
Please refer to the Preliminary Jurisdictional Waters of the U.S. Impacts Map - Impacts Table
in Attachment D (Sheet 10 of 10) where the intermittent and perennial stream impacts are
broken out as R-4 and R-3, respectively. Also, the Cowardin classifications are included and
mitigation ratios are shown to aid in the calculation of the mitigation requirements.
7) Please provide a detailed qualitative indirect and cumulative impact analysis that clearly
follows the steps outlined in the Division's policy for guidance on our website at:
http://portal.ncdenr.orq/web/wq/swp/ws/401 [policies. (15A NCAC 02H .0506(b)(4)]
A detailed qualitative indirect and cumulative impact (ICI) analysis as outlined in the DWQ
Cumulative Impact Policy guidance (April 10, 2004) is included as Attachment E.
8) Provide acomplete Stormwater Management Plan. [15A NCAC 02H.0506(b)(5) and (c)(5)]
A complete Stormwater Management Plan, which is labeled as a Stormwater Impact Analysis
(SIA), is provided as Attachment F. The SIA lays out the calculations and stormwater control
measures (SCM's) that have been used to meet all Person County and State regulations in
regard to Stormwater Controls. The site has been designed such that there is no net increase
in peak flow leaving the site from pre -development conditions for the one-year, 24-hour
storm event. Also, wet ponds have been included such that nitrogen and phosphorus loads
contributed by the proposed new development shall not exceed the following unit -area mass
loading rates: 2.2 and 0.33 pounds per acre per year for nitrogen and phosphorus,
respectively.
Comments below from the USACE (in black) with responses (in red);
1) Please clarify if there will be any co -applicants for thisproject.
There will be no co -applicants; Person County Business and Industrial Center, Inc. is the
sole applicant for this project.
2) Additional site-specific information regarding the alternatives analysis is required to ensure
compliance with the National Environmental Policy Act (NEPA) and the Section 404(b)(1)
guidelines. This includes the following items:
a. Provide additional discussion/analysis for the Overall LayoutPlan (Sheet 1). Specifically,
please clearly label each feature (building, parking lot, component of the facility, etc.)
and provide details regarding the purpose of each feature (i.e., what the use of that
feature would be, reason for the size, etc.).
An updated Overall Layout Plan with clearly labeled features (building, parking lot,
facility component, etc.) is provided as Attachment A.
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A description of site programming requirements is as follows:
• The Bulk Gas Yard is needed to house Liquid Nitrogen, Argon, and other inert
gases in large capacity tanks.
• The Mechanical Central Utility Building houses boilers and chillers, and
processes cooling water and Ultra -pure water systems.
• The Hazardous Process Materials (HPM) houses hazardous materials such as
Silane, Ammonia, and Hydrogen.
• The Manufacturing building is 4 stories tall, consisting of a Class 100
cleanroom housing semiconductor process equipment on the 3rd level, and
support equipment on the 1St and 2nd levels. The 41h level houses the HVAC
equipment that provides the class 100 cleanliness levels.
• The Utility Building houses boilers and chillers, and processes cooling water
and Ultra -pure water systems.
• The Electrical Substations provide needed electricity to service the site
programming needs.
Note that the second sentence of the second paragraph of the Executive Summary
for the Person County Mega Park Individual Permit Request states that "The
proposed Project layout is comprised of an approximate 3.5 million square feet
central operations facility to house the clean room, manufacturing spaces, office
spaces, mechanical yard, vehicular load deck areas and associated parking. " Please
clearly identify the above -referenced project components on the site plans and
provide a written explanation describing the need for and arrangement of the
specific buildings and components within the framework of the overall project.
The site plans have been revised to show the approximate 2.35 million square
foot central operations facility with clean room, manufacturing spaces, office
spaces, mechanical yard, vehicular load deck areas, and associated parking, and
is provided as Attachment A. The facility is designed for 4,000 employees for
which associated parking is provided per the Site Plan in the construction
drawings on Sheet C3.0. To minimize footprint, two (2) four story parking decks
have been utilized to achieve some of this parking requirement. The components
of the site plan in the service yard area are placed and designed to be comparable
to an existing plant in Malta, New York; an aerial of this site is provided as
Attachment G. The spacing of the exterior components within the site plan allow
for the movements and maneuvering of trucks and machinery during plant
operations. Spacing of components in the mechanical yard allows for needed
circulation.
ii. Clearly describe the capacity of the proposed parking lot layout for each of the
alternatives. Is the proposed parking layout sufficient to meet the needs of the
estimated labor force (4,000 employees) at the proposedfacility?
The parking layout, which is a mixture of traditional parking spaces along with
two (2) parking decks that are 4 stories tall, provides 4,000+ spaces to
accommodate the 4,000 employees at the proposed facility. This is consistent for
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each of the alternatives. Ingress, egress, and turning radii for large trucks,
including semi -trailers, would be accommodated in the rear yard, which includes
a gravel truck parking yard.
The on-site alternatives do not include an analysis for impacts associated with the
proposed utility lines and transportation improvements. Please explain how the
preferred alternatives for the utility lines and transportation improvements would
affect the total impacts for the on-site alternatives.
The proposed waterline and electrical lines will utilize existing right of ways
(roadways) which would negate the need for additional impacts. This is true for
the preferred alternative as well as the on-site alternatives.
All of the on-site alternatives would require the transportation improvements
(i.e., loop road system) just as the preferred site option would. The other
alternatives, however, place the site in areas where more streams and wetlands
are impacted, in addition to the loop road system, therefore making them
unfavorable. Roadways have been designed per NCDOT standards, which require
certain vertical and horizontal radii and guidelines that drive the geometry of the
road. Cut and fill slopes have also been designed per NCDOT standards to
maintain stability and avoid erosion and slope failure.
The sewer plan and profiles, which in some cases do not follow the roadways due
to the sewer being a gravity system, minimize impacts to the streams as much as
possible. The sanitary sewer profiles are shown in the construction drawings on
Sheet C3.14 in Attachment A.
iv. Please provide additional information and a detailed discussion regarding the
methods used to determine the layout of the Overall Layout Plan (Sheet 1). Please
indicate if other current or former semiconductor chip manufacturing plants were
used to determine the number, size, use ofeach building and surface lot (and if so,
which facilities?) and methods used to arrive at the currentproposed configuration.
Please explain how this was determined to be a requirement of all semiconductor
chip manufacturing plants.
The site was designed using an existing site in Malta, New York, that is a sister
facility to the proposed Project. An aerial of the sister site is included as
Attachment G. We also have consulted with those familiar with these facilities
and processes during the layout that has allowed us to describe the processes that
are detailed below and laid out in the Overall Site Plan on Sheet C3.0 in
Attachment A:
The Bulk Gas Yard is needed to house Liquid Nitrogen, Argon, and other inert
gases in large capacity tanks.
The Mechanical Central Utility Building houses boilers and chillers, and
processes cooling water and Ultra -pure water systems.
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• The Hazardous Process Materials (HPM) houses hazardous materials such as
Silane, Ammonia, and Hydrogen.
• The Manufacturing building is 4 stories tall, consisting of a Class 100
cleanroom housing semiconductor process equipment on the 3rd level, and
support equipment on the 1St and 2nd levels. The 4th level houses the HVAC
equipment that provides the class 100 cleanliness levels.
• The Utility Building houses boilers and chillers, and processes cooling water
and Ultra -pure water systems.
• The Electrical Substations provide needed electricity to service the site
programming needs.
v. Please provide additional discussion regarding the Overall Layout Plan (Sheet 1). As
this plan appears to be a typical semiconductor chip manufacturing plantsite plan,
please provide additional details/discussion regarding the mechanism and methods
the applicant would take to ensure that any potential end user would not request to
re -design the proposed campus to their own specifications and would ultimately
build the proposed design as indicated. We believe it is important to reiterate that
in the event a permitis issued for this project, it must be built exactly as depicted in
the plans you have submitted and for the purpose and need expressed in your
application, unless a modification to the proposed project is authorized by the
DistrictEngineer.
The permit requested and described in the permit application for the Person
County Mega Park Individual Permit Request would only be valid for a
semiconductor chip manufacturing plant, as proposed. It is understood that the
Purpose and Need statement in the application describes the specific needs of the
semiconductor industry, and any use changes (ex. Walmart distribution facility)
or design modifications not authorized by the District Engineer would not be
permissible. Once permitted for microchip facility design, any other uses
proposed for the site would not be valid and it would be necessary to restart the
permitting process. The applicant will actively solicit potential end users who are
willing to build the proposed design as indicated.
In addition to meeting the minimum need for 200 acres of available land with
compatible zoning for a semiconductor chip manufacturing plant, the site has
direct routes to interstates and multiple points of access from two roadways. The
site meets a semiconductor project's need for large demands of high-quality and
easily accessible uninterrupted electrical power and includes uniquely available
service from multiple directions and redundant sources less likely to experience
power disruption. This site is located away from potential sources of vibration
(rail) which might further disrupt utility power. In addition, existing excess
capacity for water and wastewater is available in the area, as well as a natural gas
and a robust fiber network with multiple providers to ensure fiber redundancy.
The purpose of the project is to develop a semiconductor chip manufacturing
plant at the project site and bring significant economic relief to the citizens of
Person County, including approximately 4,000 jobs. The necessary rezoning,
environmental, and utility infrastructure studies have been completed, and
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agency coordination with North Carolina Department of Environment and
Natural Resources, North Carolina Natural Heritage Program, United States Fish
and Wildlife Service, North Carolina Department of Cultural Resources, North
Carolina Department of Natural and Cultural Resources have been conducted.
Should a new use or substantial design changes be proposed for the site, these
studies and agency coordination efforts would become invalid, requiring that
they are repeated as the permitting process is restarted.
Therefore, due to the site's unique suitability for semiconductor chip
manufacturing, the due diligence that has already been completed for this facility,
and the site plan that has been developed for the use as specified in the permit
application, the site will be attractive to potential end users who desire a
streamlined approval process. A contract between applicant and end user will be
required to specify that only the proposed design as indicated in the permit will
be built.
b. Provide an alternatives analysis for each of the utility line and transportation
improvement projects associated with the proposed project. Specifically explain how
and why the preferred alternative was chosen for thefollowing:
The alternatives analysis has been updated to show the utility lines and the
transportation improvements associated with the proposed project. The alternatives
analysis showing alternate site plan layouts is provided in Attachment H.
i. The proposed water utility line that extends south from the proposed semiconductor
chip man ufacturingfacility,
The proposed waterline extending south from the plant continues beyond the site
down existing Country Club Road. Utilizing the site, which is already being graded
due to programming requirements, and utilizing the existing right of way corridor
of County Club Road, there will be no additional impacts associated with the water
line specifically. As for the alternatives, the waterline would essentially make its
way to the same source for connection (Country Club Road). The preferred
alternative was chosen due to its minimization of total proposed impacts, which
include those that could be attributed to the waterline connection. The proposed
water utility line is shown in the Overall Utility Plan on Sheet C3.10 in Attachment
A.
ii. The proposed gas utility line that extends south from the proposed semiconductor
chip manufacturing facility; and
The proposed gas line extending south from the plant continues beyond the site
down existing Country Club Road. Utilizing the site, which is already being graded
due to programming requirements, and utilizing the existing right of way corridor
of County Club Road, there will be no additional impacts associated with the gas
line specifically. As for the alternatives, the gas line would essentially make its
way to the same source for connection (Country Club Road). The preferred
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alternative was chosen due to its minimization of total proposed impacts, which
include those that could be attributed to the gas line connection. The proposed
gas utility line is shown in the Overall Utility Plan on Sheet C3.10 in Attachment
A.
iii. The proposed transportation improvements along Edwin Robertson Road and
Shiloh Church Road.
The proposed transportation improvements associated with the preferred
alternative, which creates the loop road around the site, would be needed for all
of the alternatives. Given that this project now excludes Phase II, there will be no
required improvements needed for Shiloh Church Road, and very minimal work
needed for Edwin Robertson Road. The work needed for Edwin Robertson Road
would be minimal turn lanes and road widening and would not impact any
streams or wetlands. Due to the transportation needs and requirements for the
site, the preferred alternative was chosen over the other alternatives because the
placement of the roadway network and the site created far less stream and
wetland impacts with the preferred alternative. The proposed transportation
improvements are shown in the Overall Site Plan on Sheet C3.0 in Attachment A.
c. The Person County Megasite Traffic Impact Analysis, dated September 20, 2017, was
written with the assumption that the proposed project was a six (6) million square foot
(SF) plus semi -con ductorfacility along with ancillary, supporting land uses." However,
the current application only considers an approximately 3.5 million square feet
semiconductor ship manufacturing plant. Please explain how the Traffic Impact
Analysis mentioned above still applies to the proposed project in light of the reduction
in size and scope of the proposed project? If the Traffic ImpactAnalysis no longer applies
due to changes in the scope of the proposed project, please revise the analysis
accordingly to match the currently proposed scope ofthe project.
The TIA from September 20, 2017 still applies to the proposed project. The TIA was
based on the development of a semi -conductor facility in two build phases. Phase I
was anticipated to be 2.35 million square feet, and Phase II (Full Build) was
anticipated to be approximately 3 million square feet for a total of 5.5 million square
feet constructed over the course of ten years. However, the project no longer
proposes the Phase II development on both the north and south sides of Edwin
Robertson Road. Phase I still proposes an approximately 2.35 million square foot
semiconductor chip manufacturing plant. In addition, the semiconductor plant's
project boundary has been reconfigured to maximize space, create less impervious
surface, and minimize impacts to streams to the greatest extent possible. This
reconfigured facility footprint still accounts for the same number of employees and
associated parking (4,000 for each) as discussed in the TIA and permit application, as
well as the trip generation analyzed in the TIA.
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d. The project is proposed to be constructed in two phases. It appears that Phase 1 would
effectively disconnect Country Club Road from Edwin Robertson Road. Is there a plan to
route traffic through or around the site during and following the implementation of
Phase 1 of the proposed project?
The existing portion of County Club Road that will eventually be demolished as part
of Phase I will remain in service until the loop road system is fully built and
serviceable. Once the loop road portion of Phase I is built, the traffic on Country Club
Road will travel down the new loop road portion of roadway to connect to Edwin
Robertson Road. At that point, the portion of Country Club Road within Phase I can
be demolished to make room for the proposed site.
e. There is no accounting for any temporary impacts associated with the transportation
component of this project. Typically, temporary impacts are necessary for dewatering
activities associated with culvert installation. Please provide and/or distinguish
between temporary and permanent impacts associated with the transportation portion of
this project. Additionally, please itemize permanent impactsbytype offill (e.g. culvertfill
versus outletstabilization via rip rap dissipater pad).
Plan, Profile, and Outlet Condition Impact Maps, Sheets 1-9 included in Attachment B,
have been provided that show temporary impacts such as dewatering activities
associated with culvert installation. These maps distinguish between permanent and
temporary impacts. Some of the permanent impacts along the roadways are
associated with the entire site and are not listed as permanent impacts within these
sheets but are included in the overall impact maps and defined there. The fill
associated with the roadways and the outlet conditions have been defined as
permanent impacts up to the end of the flared end sections of proposed culverts and
as temporary impacts beyond that, which include toed -in or buried rip rap energy
dissipators and additional temporary dewatering efforts.
f. The Preliminary jurisdictional Waters of the U.S. Impacts Maps (Sheets 5 and 6) do not
accurately show the limits of waters within the project corridor. Therefore, the impact
totals to streams and wetlands are not accurate on the above referenced impacts maps
and in the permit application. Please reference the revised delineation maps entitled
"Figure 6: Waters of the U.S. Delineation Map (Sheets 2 and 3 of 3) that were submitted
to the Corps on September 24, 2018, as part of the Preliminary jurisdictional
Determination Request, these features were field verified by Mr. Ross Sullivan with the
Corps on May 3 2018. Please revise the permit application to correctly account for all
impacts to Waters of the U.S.
The Preliminary Jurisdictional Waters of the U.S. Impacts Maps (Sheets 5 and 6)
referenced against Figure 6: Waters of the U.S. Delineation Map (Sheets 2 and 3 of 3)
are located in Phase II, west of Phase I along Shiloh Church Road, and will be corrected
at a later date. Only the impacts for Phase I are now included in the revised
Preliminary Jurisdictional Waters of the U.S. Impacts Maps - Impacts Table (Sheet 10
of 10 in Attachment D).
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g. The permit application andsupporting documentation highlights the proposed project's
needs for redundant power supplies and highlights the availability of multiple 230 W
lines and 115 W lines that currently cross the property. However, the plans do not
clearly identify the location of these utility lines or show how they would tie into each of
the proposed project alternatives. Please clearlydisplay and explain how the proposed
project alternatives would connect to the existing utility lines and indicate whether or
not any impacts to waters of the US. would occur as a result of these utilityconnections.
Redundant power does exist and cross through the project site, making this an
attractive site for the proposed Project. The power supply will connect to the site by
way of existing right of way along Country Club Road as shown on the Overall Utility
Plan of the construction drawings (Sheet C3.10) in Attachment A. There will be no
additional impacts to the waters of the US as a result of these utility connections.
3) Provide additional discussion/analysis for the Overall Layout Plan (Sheet 1). Specifically, please
clearly label each feature (building, parking lot, component of the facility, etc.) and provide
details regarding the purpose of each feature (i.e., what the use of that feature would be, reason
for the size, etc.).
Please see comment responses to question 2.a.
4) Your offsite alternatives analysis should also include the transportation and utility components
when assessing the environmental impacts in order to compare it to the preferred alternative.
Offsite alternatives have been provided in Attachment H, and the utility components and
impacts for the alternatives have been explained above in comment 2.b. Attachment H breaks
down the impacts associated with these alternatives.
5) Provide the Corps with a copy ofyour responses to Items 2-7listed in the Request forAdditional
Information from the NCDWR, dated February 19,2019.
A copy of the responses to Items 2-7 listed in the Request for Additional Information from the
NCDWR is provided herein to the Corps.
6) A more detailed compensatory mitigation proposal is needed once you have a final site plan.
Note that any impacts where the proposed mitigation is not locatedwithin the same 8 -digit HUC
may be subject to higher compensatory mitigation ratios.
A more detailed compensatory mitigation proposal will be provided with the final site plan.
The NCDEQ Division of Mitigation Services (DMS) In -Lieu Fee Acceptance Letter dated
October 24, 2018 expired on February 24, 2019. DMS has provided a renewal letter dated
July 22, 2019, which will now expire on January 22, 2020; see Attachment C. DMS proposes
to provide credit in the Roanoke River Basin in HUCs 03010103, 03010104, or 03010102.
Should no mitigation sites be available for credit in the Roanoke Basin, we will coordinate
with DMS and the Corps for other available mitigation bank locations. It is understood that
impacts may be subject to higher compensatory mitigation ratios should the proposed
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mitigation be located outside of HUCs 03010103, 03010104, or 03010102.
7) Please provide a more detailed indirect impacts analysis with regards tostreams and wetlands
that existjust outside of the fill footprintfor the proposed project. In particular, will anystreams
lose their watershed through rerouting of stormwater? Will any wetlands lose their recharge
area due to fill/rerouting of stormwater? If so, please quantify these indirect impacts and
include them in the compensatory mitigation proposal?
Construction drawings have been provided that show plans and profiles of the proposed
project as well as limits of disturbance that define the outer limits of the stream impacts. Plan,
Profile, and Outlet Condition Impact Maps, Sheets 1-9 included in Attachment B, have also
been provided that show the direct impacts of the streams at road crossing locations and at
pipe outlet locations. Cross pipes have been strategically placed during the design of the
project to recharge flow to all stream locations that are just downstream of our construction
limits. Therefore, there will not be any indirect impacts associated with the fill near these
streams.
Comments below from NCSHPO (in black) with response (in red):
The area of disturbance for the semiconductor chip manufacturing plant site has already been
surveyed for archaeological resources and cleared for use. Most of the area covered by the proposed
utility and transportation improvement sites are low probability for intact, significant archaeological
resources. However, we note the presence of three cemeteries on the topographic quad maps: one
along the proposed transportation corridor (Shiloh Primitive Baptist Church Cemetery, Shiloh
Church Road, Roxboro, NC 27574), one along the proposed waste water line (3919 Chub Lake Road,
Roxboro, NC 27573), and one along the PSNC gas pipeline (705 McGhees Mill Road, Roxboro, NC
27574). These cemeteries have not been previously recorded with our office, and online information
gives conflicting accounts of how well they are marked.
Prior to any earth -moving activities, these cemeteries should be delineated, recorded with our office,
and the boundaries marked to ensure that human skeletal remains are not inadvertently impacted.
We recommend pedestrian reconnaissance (visual inspection) and probing for any evidence of
additional burials in the immediate vicinity of the cemeteries by an experienced archaeologist, and
at least a 25 -ft buffer to be established around the cemetery and a fence placed to ensure its
protection. Please note that our office now requests consultation with the Office of State Archaeology
Environmental Review Archaeologist to discuss appropriate field methodology prior to the
archaeological field investigation.
If an archaeological field investigation is conducted, one paper copy and one digital file (PDF on disc)
of each report, and one digital copy (PDF on disc) of each site form should be submitted to the OSA
for review and comment as soon as they are available and well in advance of any earth moving
activities. PDF -A (Archival format) is preferred but a high-quality standard PDF file is also acceptable.
The above comments are made pursuant to Section 106 and 110 of the National Historic Preservation
Act and the Advisory Council on Historic Preservation's Regulations for Compliance with Section 106
codified at 36 CFR Part 800.
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A response letter dated July 22, 2019 was provided to the Office of State Archaeology and is included
as Attachment I.
Please feel free to contact Robin Maycock Perez at (919)-532-3245, or robin.perezOtimmons.com if
you have any questions.
Sincerely,
Timmons Group
kvr fz M. Iw&z�
Robin Maycock Perez
Environmental Group Leader
Attachments:
A. Construction Drawings
B. Plan, Profile and Outlet Condition Impact Maps
C. DMS In -Lieu Fee Acceptance Letter
D. Preliminary Jurisdictional Waters of the U.S. Impacts Map
E. Indirect and Cumulative Impact Analysis
F. Stormwater Impact Analysis and Design Calculations
G. Malta, NY Microchip Site Aerial
H. Alternative Site Locations Maps with Preliminary Jurisdictional Waters of the U.S.
Impacts
I. Response Letter to SHPO
Cc (by e-mail):
Michael Solomon, PE, Timmons Group
Brian Breissinger, Timmons Group
Chris Dodson, Timmons Group
Sherry Wilborn, Economic Development Director, Person County Government
Blake Hall, Principal, Timmons Group
CIVIL ENGINEERING I ENVIRONMENTAL I SURVEYING I GIS I LANDSCAPE ARCHITECTURE I CONSTRUCTION SERVICES