20190883 Ver 1_USACE Correspondence_20190815

Strickland, Bev
From: Bailey, David E CIV USARMY CESAW (USA) < [e-mail] >
Sent: Thursday, August 15, 2019 10:11 AM
To: Diandra Hyman; Homewood, Sue
Cc: Mark Fisher; George Lankford; Terry Shelton ([e-mail])
Subject: [External] RE: Request for Additional Information: Eden Remediation Bridge Street
Basin sewer, Rockingham County; SAW -2019-01086 (UNCLASSIFIED)
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One other item:
It does not appear that Impact 11-W9 (Wetland BSW-4) was included in either Table 1b or C.2. Please update the tables
and totals accordingly. Thanks.
-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]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: http://corpsmapu.usace.army.mil/cm_apex/f?p=136:4:0
Thank you for taking the time to visit this site and complete the survey.
-----Original Message -----
From: Bailey, David E CIV USARMY CESAW (USA)
Sent: Wednesday, August 14, 2019 3:59 PM
To: Diandra Hyman <[e-mail]>; Homewood, Sue <[e-mail]>
Cc: Mark Fisher <[e-mail]>; George Lankford <[e-mail]>; Terry Shelton
([e-mail]) <[e-mail]>
Subject: RE: Request for Additional Information: Eden Remediation Bridge Street Basin sewer, Rockingham County;
SAW -2019-01086 (UNCLASSIFIED)
Hello Dee, and thank you for your response dated 7/31/2019 to our request for additional information. Based on my
review of this information there are a few additional items to resolve before proceeding with verifying the use of
Nationwide Permit 12 (http://saw-reg.usace.army.mil/NWP2017/2017NWP12.pdf <http://saw-
reg.usace.army.mil/NWP2017/2017NWP12.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consider your application withdrawn and close the file: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) Sheet 3.2 and Drawing 11-C27 show sewer replacement within the footprint of UT 2 to Dan River near Sta. 34+00,
however there are no impacts proposed and the profile does not show the existence of a channel here. Please explain
this discrepancy. If the sewer will be replaced within this stream channel, please update the PCN, figures, and drawing
accordingly.
2) Notes on the project drawings reference "Wetland Seed Mix', however there is no species list provided (even on
Drawings D-9 and D-10). Please provide the wetland seed mix proposed for use to restore temporary wetland impacts.
Please let me know if you have any questions.
-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]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: http://corpsmapu.usace.army.mil/cm_apex/f?p=136:4:0
Thank you for taking the time to visit this site and complete the survey.

-----Original Message -----
From: Diandra Hyman [mailto:[e-mail]]
Sent: Wednesday, July 31, 2019 3:34 PM
To: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>; Homewood, Sue
<[e-mail]>
Cc: Mark Fisher <[e-mail]>; George Lankford <[e-mail]>; Terry Shelton
([e-mail]) <[e-mail]>
Subject: [Non-DoD Source] RE: Request for Additional Information: Eden Remediation Bridge Street Basin sewer,
Rockingham County; SAW -2019-01086 (UNCLASSIFIED)
David & Sue ?
Please see responses in red below. All revised or new figures, tables and plan sheets referenced in the responses have
been attached for your review of Phase 11 ? Bridge Street Basin Sewer Rehabilitation and Replacement.
If you have any questions or need additional information, do not hesitate to call.
Thankyou!
Dee
Diandra (Dee) Hyman, PE
Project Manager I Water & Wastewater Services

WK Dickson & Co., Inc.
919.256.5656 (o) 1 267.229.4898 (m)
1929-2019 1 CELEBRATING 90 YEARS OF SERVICE
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Wednesday, June 19, 2019 3:23 PM
To: George Lankford <[e-mail]>; Terry Shelton ([e-mail]) <[e-mail]>
Cc: Homewood, Sue <[e-mail]>; Mark Fisher <[e-mail]>; Diandra Hyman
<[e-mail]>
Subject: Request for Additional Information: Eden Remediation Bridge Street Basin sewer, Rockingham County; SAW -
2019 -01086 (UNCLASSIFIED)
CLASSIFICATION: UNCLASSIFIED
WH
Thank you for your PCN and attached information, dated and received 5/23/2019, for the above referenced project. I
have reviewed the information and need clarification before proceeding with verifying the use of Nationwide Permit 12
(Blockedhttp://saw-reg.usace.army.miI/NWP2017/2017NWP12.pdf <http://saw-
reg.usace.army.mil/NWP2017/2017NWP12.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. Your PCN included impacts to streams and wetlands, however these and other potential jurisdictional
boundaries have not been verified by the USACE. A field verification site visit has been scheduled with Mr. George
Lankford (agent) on 6/26/2019 to verify the locations of potential waters of the US. Please note that revisions to the PCN
and plans may be necessary depending on the results of the field verification; Wetland areas identified in the site visit
(BSW-8, BSW-9, BSW-7, BSW-6 and BSW-5) have been added to the plans and figures. These revised sheets (, 11-C30,
11-C31) and figures (3.3 and 3.4) have been attached BSW-9 (Sheet 11-C3 Trogdon Drive Outfall) two separate wetland
areas were identified, there is a proposed temporary impact (11-W3 to BSW-8) to the smaller area due to sanitary sewer
replacement and the extents of the larger area of the wetland (BSW-9) is outside of our Limit of Disturbance and will
have no impact. Shown on figure 3.6
BSW-8 (Sheet 11-C21 Robin Road Outfall) a proposed temporary impact (11-W4) has been added to the plans due to
proposed sanitary sewer replacement. Added to figure 3.3
BSW-5 (Sheet 11-C31 Dan River Outfall) a temporary impact has been added due to the use of heavy-duty rig matting for
access along the Dan River Outfall. Shown on figure 3.5
11-58 (Sheet 11-C33) has been added to the plans as there is a stream crossing and replacement of sanitary sewer.
Figure 3.4
The field visit identified wetland areas (BSW-6 and BSW-7) which were not shown as impacts on the figures on Sheet 11-
C27 where existing manholes are being replaced in kind. Impact 11-W8 to BSW-6 have been added to the plan sheet and
figure 3.2. There are no impacts to BSW-7.
Impact 11-W1 (Sheet 11-C9) hatching has been updated as was noted during the field visit.
BSW-2, BSW-3 and BSW-4 (Sheet 11-C19 Robin Road Outfall) temporary impacts not previously shown have been added
to account for the use of heavy duty rig -matting the Contractor will need to use for access. Figure 3.8

2. Per NWP General Condition 23(a) and (b) regarding avoidance and minimization of impacts to the maximum
extent practicable, could proposed stream crossings in sewer re -alignment areas be re -aligned to cross the stream at
closer to perpendicular within the existing easement? Stream impacts proposed at crossings 11-S2, 11-S3, 11-S4, 11-S7,
and 11-S11 are longer than impacts typically proposed for utility crossings;
The design objective at each of these crossings was to minimize any additional sanitary sewer pipe as well as avoid areas
with rock and/or which required deeper excavation, to the extent possible as not to increase construction cost more
than necessary for the City of Eden. In some of these crossings it was the most desirable option to replace the existing
sanitary sewer pipe in the same horizontal alignment (11-S2 & 11-S11). In other areas, such as 11-S3 the design was laid
out in order to retain the alignment of the existing sanitary sewer both to the west and to the north which intercept at
manhole BSW-009. Then by replacing manhole BSW-009 and adjusting the alignment slightly we were able to avoid any
impact to the existing 24" and 30" culverts prior to tying back into the existing alignment at BSW_034.
In other cases such as 11-S4 and 11-S7 the proposed alignment was relocated slightly to avoid impact to storm drainage
as well as existing building structures.
3. Note 7 on Plan Sheet 11-C7 indicates that rip rap will be placed at stream Crossing 11-S7. If this rip rap is to be
placed below the ordinary high water mark of this stream, then we would consider the impacts permanent rather than
temporary. Although we would not typically consider these impacts to be a permanent loss of waters, we need to
ensure that any rip rap placed in the stream bed would not be placed above the existing stream bed grade. Further, the
impacts would need to be changed from temporary to permanent on the PCN;
An ordinary high-water mark was not obtained at this location and the ditch currently exists as a fully lined rip -rap ditch.
The Contractor will be required to restore the ditch to original grade, and this has been noted on the plans.
4. It appears that new manholes (BSE 0449, possibly BSE0450, and maybe others) are proposed to be placed
within Wetland BSW-5. These impacts are considered permanent discharges of fill material and permanent losses of
waters of the US. Given that NWP 12 cannot be used to authorize permanent above -grade fill for utility lines, NWP 18
would be required to authorize them. However, these impacts must also be itemized separately on the PCN form, along
with reasons why they cannot be located outside of wetlands (avoidance and minimization);
These manholes are currently existing manholes that are part Eden's sanitary sewer system that are deteriorated and
need to be replaced, they are being removed and replaced in the same location.

5. Plan Sheet 11-C2 and others reference "DWG No. D9" in relation to the proposed stream crossing. However,
this drawing was not included in the PCN and attachments. Further, Plan Sheet 11-C30 references "Wetland Seed Mix',
however, there is no species list provided. Please provide any relevant detail sections and specification, including stream
impact restoration and stabilization details, seeding specifications, pump around methodology, etc;
Sheets D-9 and D-10 have been included for your review.
6. Plan Sheet 11-C30 includes a proposed wetland impact the extends to the edge of the plan sheet at Matchline
Sta 65+00. However the plan set does not appear to include the plansheet that matches the matchline to show the
remainder of the proposed wetland impact;
Sheet 11-C31 has been included.
7. Please ensure that the symbology used on the plan sheets for wetlands and streams is consistent throughout
the plan set. For example, the symbology for Wetland BSW-5 shown on Plan Sheet 11-C30 is different than for Wetland
BSW-1 shown on Plan Sheet 11-C9.
This has been corrected and Sheet 11-C30 has been included.
8. Given the proximity of known occurrences of Roanoke logperch and James spinymussel, as well as potentially
suitable habitat for the smooth coneflower within the project area, we have initiated informal consultation with the
USFWS pursuant to Section 7 of the Endangered Species Act. Please note that the Corps cannot verify the use of a NWP
until Section 7 consultation is complete.
The survey for the smooth coneflower was submitted on July 16, 2019 by George Lankford, but has been attached to
this email for convenience.

Please let me know if you have any questions.
-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]<maiIto: David. [e-mail]>

We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: Blockedhttp://corpsmapu.usace.army.miI/cm_apex/f?p=136:4:0
Thank you for taking the time to visit this site and complete the survey.
CLASSIFICATION: UNCLASSIFIED