19990231 Ver 1_Complete File_19990425

NC Division of Water Quality
401 Oversight and Express Permitting Unit
April 10, 2007
Memorandum
To: File - DWQ # 19990231
From: Tammy Hill
Subject: Comments on Monitoring Report, Year 1 (post-remediation) - Nucor Plate Steel
Wetland Creation Site
Report prepared by Clearwater Environmental Consultants, Inc.
1) Background
a) Winston, NC
b) Associated impact: 2.32 acres of freshwater wetland due to construction of RR crossing
& stormwater management ponds
c) Target functions for replacement: stormwater storage, filtration, & transfer; habitat
resources
d) Mitigation activities:
i) 7 ac creation of bottomland HW wetland (receives overflow from stormwater ponds
via diffuser)
ii) 2.68 ac creation of littoral shelves along edges of stormwater ponds
iii) 150 ac preservation of swamp forest along Chowan River
iv) 14.68 OR 14.87 (different values in report) ac preservation of wetlands on-site
e) Mitigation history:
i) As-built monitoring: May 2002
ii) Preservation as-built: July 2002
iii) 1St fall monitoring: October 2002 (*not a full GS*)
iv) Veg failure: fall 2004 (inundation 4 poor oak survival)
v) Remedial plan submitted & approved by USACE
vi) Supplemental planting of 3300 trees: Feb 2006
vii) New well installation: July 2006
f) Remediation for wetland mitigation
i) Trees planted: water tupelo, bald cypress, green ash, laurel oak.
ii) New wells installed: 5 in created wetland, 1 in reference
2) Hydrology
a) 5 gauges, continuous
b) Success criteria: saturation or inundation for consecutive 12.5% of GS
c) 2006 data
i) Note: only monitored from July installation to end of GS
ii) max consecutive saturated days: 37 - 112 (16 - 50% of GS); 32% in reference
d) Well #4 almost always inundated; others fluctuate
3) Vegetation
a) 3 transects, total of 7 plots, 30' radius for trees, 10' radius for herbs)
North Carolina Division of Water Quality; 401 Oversight and Express Permitting Unit
1650 Mail Service Center; Raleigh, NC 27699-1650
2321 Crabtree Blvd., Raleigh, NIC 27604-2260
Telephone: [phone]; Fax: [phone]
http://ncwaterquality.org/wetlands
NC Division of Water Quality
401 Oversight and Express Permitting Unit
b) Success criteria
i) Minimum mean density of 320 characteristic (planted or volunteer hydrophytic) tree
species/acre at 3 years
ii) Sweet gum & red maple will not be counted toward success criteria
c) 2006 results = As-built for remediation activity; all planted trees surviving (Table 2)
i) Some concern about low diversity of trees (4 species planted; red maple moving in),
but species planted probably have better likelihood of survival in wet conditions than
oaks originally planted.
4) Photos
a) Site is quite wet, but veg is growing, esp. herb/shrub
Additional Issues & Questions:
1) DWQ to do
.a) Verify identity of tall veg in most photos (grassy with heavy seed heads) - looks like
Scirpus cyperinus (wool grass, OBL).
2) For Letter
a) The Year 1 (post-remediation) monitoring report for the Nucor Plate Steel Wetland
Creation Site was received and reviewed by DWQ staff. Remediation efforts to correct
problems with hydrology and vegetation survival have been completed and appeared to
be successful as of the end of the 2006 growing season. We look forward to future
reports detailing development of the mitigation site over the next several years.
b) In future reports, include results for each vegetation sampling point for all monitoring
years. Please provide separate tables for planted and volunteer species. This will help
with evaluating distribution of vegetative success and plant community development.
North Carolina Division of Water Quality; 401 Oversight and Express Permitting Unit
1650 Mail Service Center; Raleigh, NC 27699-1650
2321 Crabtree Blvd., Raleigh, NC 27604-2260
Telephone: [phone]; Fax: [phone]
hftp://ncwaterquality.org/wetlands
CLEARWATER ENVIRONMENTAL CONSULTANTS, INC.
December 27, 2006
Ms. Tracy Wheeler
US Army Corps of Engineers
Washington Regulatory Field Office
107 Union Street, Suite 202
Washington, NC 27889
RE: As-built report for additional mitigation activities
Nucor Plate Steel
Winton, NC
USACE Permit No. 199811324
Dear Ms. Wheeler,
Q?c?P.od??
JAN s _ 2007
DEWR - WATER QUALITY
WETLANDS AND STORMW.ATER BRANCH
Per the approved wetland mitigation remediation plan additional trees were planted and new
groundwater monitoring wells have been installed. Details of the activities that have taken place
are contained herein.
Vegetative Plantings
In February 2006, a total of 3,300 trees were planted of varying species and size. Each tree was
planted utilizing a fertilizer pack to maximize survival potential. Copies of invoices for trees and
fertilizer packs are attached. A table indicating the breakdown of species, size, and quantity can
be found below.
Scientific Name Common Name Size Quantity
Tubeling 1010
Nyssa aquatica Water tupelo 1-gallon 100
3-gallon 200
T
di
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ld 1 -gallon 590
axo
um
um
s
c a
cypress 3-gallon 800
Fraxinus pennsylvanica Green ash 3-gallon 200
Quercus laurifolia Laurel oak 1-gallon 400
TOTAL 3300
718 Oakland Street
Hendersonville, North Carolina 28791
Phone: [phone] Fax: [phone]
www.cwenv.com
Groundwater Monitoring
A total of six (6) new Ecotone WM Water Level Monitors from Remote Data Systems, Inc were
installed July 19, 2006 per ERDC TN-WRAP-00-02 entitled Installing Monitoring
Wells/Piezometers in Wetlands, dated July 2000. Five (5) new water level monitors were located
within the created wetland area. One (1) new reference water level monitor was installed
approximately 3,000 feet to the west-northwest of the created wetland. Each well hole was dug
using a hand auger. After monitor placement, the remaining space .was backfilled with clean
premium playground-grade sand to prevent clogging of the screens. The tops of the holes were
sealed with bentonite clay (Shur-Plug by Drillers Service, Inc.) so that surface water would not
infiltrate the space around the water level monitor. The elevations of the calibration points on
the monitors were surveyed with a Topcon laser level and compared to a common benchmark so
that any potential vertical movement of the water level monitors in the future could be taken into
consideration. Horizontal positioning of the water level monitors was recorded to sub-meter
accuracy with a Trimble GeoXT handheld GPS unit. Recorded data is downloaded via a Palm
handheld provided by the manufacturer. A location map indicating the placements of the new
water level monitors within the created wetland area is included for your review.
Thank you for your assistance in this matter. If you have any questions, please do not hesitate to
contact me at [phone].
Sincerely,
12-
R. C1 m nt Riddle, P.W.S.
Principal
Cc: Terry Hairston, Nucor Plate Steel
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mo NUCOR STEEL

p d ° zz a PLATE MILL FACILITY ® HERTFORD COUNTY
II A y NN z ° ,?
? s 1505 RIVER ROAO COFIELD, N.C. 27922

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n n (..? m o `p R° LAYOUT FOR MONITORY WELLS & PLOTS NSHC-0100 OVERALL TOPOGRAPHICAL PLANT SITE KEY YAP (NUCOR PLANT COORDINATE SYSTEM) A 7/19/02 ISSUED FOR REFERENCE.
PLOT DATE: 18-XL-02 DEPT. CIVIL CAD FILE No.: NSHC0383 DwD. No. DESCRIPTIONS: No. DATE: REVISIONS:
Jan•11. 2006 10:39AM CFLTN LLC
CUSTOMER QUOTE
Central FL Lands & Timber Nursery, LLC
3087111. County Road 53
Mayo, FL 32066
No-0864 P- 2
DATE 1/11/2006
PROJECT CofZeld, NC
NAME & ADDRESS
Clearwater Environmental Consultants
224 S. Grove Street
Suite F
Hendersonville, NC 28792 P.O. NO. TERMS FILE #

DESCRIPTION QUANTITY COST TOTAL
3 G. Green Ash 200 4.50 900.00
1 G. Bald Cypress 100 1.50 150.00
3 G. Bald Cypress 800 4.50 3,600.00
1 G. Water Tupelo Gum 100 1.50 150.00
3 G. Water Tupelo Gum 200 4.50 900.00
1 G. Laurel Oak 400 1.50 600.00
Shipping & Handling 1 1,000.00 1,000.00
Subtotal $7,300.00
Phone # I Fax #
E-mail
1-386-294-1211 1-386-294-3416 .. e0at@aUtelmet
Sales Tax (0.00/6) $0.00
TOTAL $71300.00
COASTAL PLAIN CONSERVATION NURSERY, INC.
3067 Conners Drive Edenton, North Carolina 27932
252-482-5707 (office) 252-333-7009 (cellular) 252-482-4987 (fax)
Terry Hairston
Nucor Steel - Hertford Attn: Accounts Payable
PO Box 279
Winton NC 27986 XO(
phone [phone] fax
code
2/22/06 9:13:39 AM
3504 INVOICE #
2/14/2006 SHIP DATE
BOTTOMLAND REPLANTING PROJECT
NC230386 PO#
# each total
JYAQ Nyssa aquatica Water Tupelo Tubeling 1010 1.380 1,393.8(
'ADI Taxodium distichum Bald Cypress One Gallon 290 4.950 1,435.5(
'ADI Taxodium distichum Bald Cypress One Gallon 200 4.950 990.0(
DELIVERED
total for plants $3.819.30
delivery by nursery at no charge
TOTAL $3,819.30
CURRENT BALANCE THIS ORDER $3,819.
Anna Salzberg
From: [e-mail]
Sent: Thursday, January 26, 2006 4:43 PM
To: [e-mail]
Subject: TreeQuest Order Confirmation
Importance: High
Thank you for ordering from TreeQuest.com. This message confirms receipt of your order.
Your credit card will not be charged until your order is shipped. Your order is summarized
below for your reference.
TreeQuest Order Number: 1830
7 "Nutri-pak > Box of 100" at $22.00 = $154.00
4 "Nutri-Pak > Box of 1000" at $200.00 = $800.00
Subtotal: $954.00
North Carolina Sales Tax: $0.00
Shipping (UPS - Ground): $117.50
-----------------------------
Total: $1,071.50
1

"C3M
' PLATE MILL
ANNUAL MITGATION REPORT FOR 2006
7-ACRE WETLAND CREATION
December 2006
1
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' Prepared for: Prepared by:
Nucor Steel C1earWater Environmental Consultants, Inc
1505 River Road 718 Oakland Street
Cofield, NC 27922 Hendersonville, NC 28791
[phone]
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TABLE OF CONTENTS
LIST OF FIGURES ............................................................................................................................3
1
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I
LIST OF PHOTOGRAPHS ...............................................................................................................4
1.0 INTRODUCTION ........................................................................................................................ 7
EXECUTIVE SUMMARY ................................................................................................................5
1 2.0 PURPOSE .................
1 3.0 METHODS ..................................................................................................................................10
4.0 PROJECT HISTORY ................................................................................................................11
1 5.0 HYDROLOGY ........................................................................................................................... 12
5.1 Success Criteria .............................................................................................................. 12
' 5.2 Hydrologic Description .................................................................................................. 12
5.3 Results of Hydrologic Monitoring ................................................................................ 13
5.4 Conclusions .................................................................................................................... 14

6.0 FALL 2006 VEGETATION ...................................................................................................... 15
6.1 Success Criteria ............................................................................................................... 15
' 6.2 Description of Species .................................................................................................. 16
6.3 Vegetation Data ............................................................................................................. 16
6.4 Created Wetland Vegetation Conclusions .....................................................................17
1 7.0 SUMMARY 2006 ........................................................................................................................18
' 8.0 LITERATURE CITED .............................................................................................................19
1 PHOTOGRAPHS ..............................................................................................................................20

ii

LIST OF FIGURES
Figure 1 Site Location Map ........................................................................26
Figure 2 Site Plan ....................................................................................27
Figure 3 Wetland Creation Area .............................................. ..................28
Figure 4 Rainfall 30 - 70 Percentile Graph (Hertford County 30 Year WETS data) .... ...29
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LIST OF PHOTOGRAPHS
Photograph 1. Overview of Creation Area, Fall 2006 ...................................................................... 21
Photograph 2. Overview of Creation Area, Fall 2006 ..................................................................... 21
Photograph 3. Creation Area, Transect No. 1, Plot 1, 2006 ............................................................. 22
Photograph 4. Creation Area, Transect No. 1, Plot 2, 2006 ............................................................. 22
Photograph 5. Creation Area, Transect No. 1, Plot 3, 2006 ............................................................. 23
Photograph 6. Creation Area, Transect No. 2, Plot 4, 2006 ............................................................. 23
Photograph 7. Creation Area, Transect No. 2 Plot 5, 2006 .............................................................. 24
Photograph 8. Creation Area, Transect No. 3, Plot 6, 2006 ............................................................. 24
Photograph 9. Creation Area, Transect No. 3, Plot 7, 2006 ............................................................. 25
iv
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1

EXECUTIVE SUMMARY
Nucor Steel (Nucor) was issued a Department of the Army Permit (No. 199811324), a N.C.
Division of Water Quality 401 Certification (990231), and a Division of Coastal Management
Permit (79-99) to construct a railroad crossing and stormwater management ponds in unnamed
intermittent tributaries of the Chowan River and wetlands adjacent to Brooks Creek in Hertford
County, North Carolina. As a special condition to these permits, Nucor is required to implement
mitigation measures outlined in the Revised Compensatory Wetlands Mitigation Plan Plantation for
Nucor Steel Plate Recycling Mill, Hertford County, November 8, 1999. The Mitigation Plan
includes creation of a seven acre bottomland hardwood wetland and creation of 2.68 acres of littoral
shelves along the periphery of four stormwater ponds, as well as the preservation of 150 acres of
swamp forest along the Chowan River and 14.68 acres of wetlands on-site. These mitigation
efforts are required to offset unavoidable impacts to 2.32 acres of jurisdictional freshwater
wetlands. The as-built monitoring was conducted in May 2002, after construction and planting of
the mitigation areas. The first annual fall monitoring was conducted in October 2002. As
documented in the Fall of 2004, the tree mortality had fallen below the designated vegetation
success criteria. In 2004, a remedial wetland mitigation plan was submitted to the U.S. Army
Corps of Engineers (USACE). This plan stated that the created wetland was been semi-
permanently flooded over the past three years and the planted oaks have not survived well, the
mean density of trees per acre has fallen to 231 which does not meet the required 320 trees per
acre outlined in the original mitigation plan. However, it is important to note that tree survival
rates for more water tolerant species of Taxodium, Nyssa, and Fraxinus, have remained high (79-
89% average). This leads us to conclude that the most significant issue with Quercus tree
mortality is long hydroperiods.
This plan was approved by the USACE on February 15, 2005. In February of 2006, Nucor Steel
planted 3,300 trees (Taxodium, Nyssa, Fraxinus, and fewer Quercus in the highest areas) in the
wetland creation area. Nucor also installed five new hydrology monitoring wells within the
creation area and one new well in the reference wetland in July 2006. This is the first annual report
of the remedial wetland activities.
Based on the approved remediation plan, Nucor will continue to monitor the mitigation site and
v
report the results annually, for the next four years, to the USAGE, N.C. Division of Water Quality
' (DWQ), and the N.C. Division of Coastal Management (LAMA).
i

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t vi

1.0 INTRODUCTION
Nucor Steel (Nucor) was issued a Department of the Army Permit (No. 199811324), a N.C.
Division of Water Quality 401 Certification (990231), and a Division of Coastal Management
Permit (79-99) to construct a railroad crossing and stormwater management ponds in unnamed
intermittent tributaries of the Chowan River and wetlands adjacent to Brooks Creek in Hertford
County, North Carolina (Figure 1). As a special condition to these permits, Nucor is required to
implement mitigation measures outlined in the Revised Compensatory Wetlands Mitigation Plan
Plantation for Nucor Steel Plate Recycling Mill, Hertford County, November 8, 1999 and the
Remedial Wetland Mitigation Plan approved on February 15, 2005.
The Mitigation Plan schedules activities to offset unavoidable impacts to 2.32 acres of jurisdictional
freshwater wetlands/Waters of the U.S. Jurisdictional wetlands are defined by 33 CFR Part
328.3(b) and are protected by The Clean Water Act (33 CFR 1344) which is administered and
enforced by the U.S. Army Corps of Engineers (USAGE). Mitigation efforts for the project include
the following:
• 7-acre wetland creation area

1

1

• Pond C1 includes 0.604-acres of littoral shelf.
• Pond B 1 includes a 0.917-acres littoral shelf.
• Pond Al includes 0.839-acres littoral shelf.
• Pond A3 includes a 0.504-acres littoral shelf.
• 14.87-acres of Preserved Wetlands on-site
• 150 acres of preserved wetlands off-site
The remedial planting of hydrophytic tree species was conducted at the seven acre wetland creation
7
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1
area (Figure 3) in the winter of 2006. Hardwood saplings include the following species bald
cypress (Taxodium distichum), green ash (Fraxinus pennslyvanica), laurel oak (Quercus laurifolia),
water tupelo (Nyssa Mora), willow oak (Quercus phellos), and water oak (Quercus nigra). Wax
myrtle (Myrica cerifera) was planted along the transition area between the wetland area and the
upland area. Herbaceous species planted on the littoral shelves included pickerel weed (Pontedaria
cordata), arrow arum (Peltandra virginica), soft rush (Juncus effusus), lizard's tail (Saururus
cernuus), shallow sedge (Carex lurida) and uptight sedge (Carex stricta).
Planting of hardwood saplings at the creation area was conducted in winter of 2002. Per the
approved remediation plan, additional planting of hardwood saplings was conducted in February
2006. Planting of herbaceous species was conducted in Pond B 1 in the spring of 2001 and ponds
C 1, A3, and half of pond A 1 were planted in spring 2002. The remainder of Pond A 1 was planted
in June of 2002. A total of 5,150 seedling tree species as described above were planted on at least 6
x 10-foot center spacings (or 726 trees per acre) and approximately 51,885 herbaceous species were
planted on 18-inch spacings per the Revised Compensatory Wetlands Mitigation Plan for Nucor
Steel Plate Recycling Mill (1999). An additional 3,300 hardwood trees were planted in 2006.
Monitoring of wetlands will be carried out for five years (2010), with a regulatory review after the
fifth year to determine success. This report summarizes the remedial actions for the mitigation site.
The fall Mitigation monitoring was conducted on September 18 and 19, 2006
Details of the wetland preservation on-site and off-site were provided in the As-Built report dated
July 16, 2002.
8

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2.0 PURPOSE
In order to demonstrate successful mitigation, the Nucor Steel wetland creation area must be
monitored for both hydrology and vegetation for a minimum of five years or until success criteria
are fulfilled. Success criteria are based on federal guidelines for wetland mitigation. The
following report details the results of hydrologic and vegetative monitoring during the 2006
growing season at the Nucor Steel Hertford County site as well as local climate conditions
throughout the growing season.
The purpose of the long term monitoring program is to quantify the developing structure of the
created bottomland hardwood. Data collected will be used to determine the regeneration and
survivability of planted wetland vegetation, as well as the success of wetland mitigation efforts.
Also a qualitative analysis will be formulated through observations of vegetative growth and
wildlife usage throughout the mitigation areas. The goal of the proposed mitigation is to offset
impacts to on-site wetlands by replacing lost functions and values with equal or higher functions
and values. The primary target functions to be replaced are stormwater storage and filtration
capacities, stormwater transfer, and habitat resources.
9

' 3.0 METHODS
' As described in the Revised Compensatory Wetlands Mitigation Plan Plantation for Nucor Steel
Plate Recycling Mill, Hertford County (November 1998) prepared for Nucor, monitoring of
' wetland vegetation and hydrology was conducted on the mitigation areas. Photographs are taken
annually to document conditions occurring within the wetlands mitigation sites for future
' comparison.
1 The site was constructed over a year period beginning in the spring of 2001 and finishing in the
winter of 2002. Prior to excavation beginning, spot elevations within existing wetland "W/X" were
' taken to set the target elevation for the creation area. The target elevation as set forth in the Revised
Compensatory Wetlands Mitigation Plan Plantation for Nucor Steel Plate Recycling Mill, Hertford
' County, November 8, 1999 was 30.5 feet msl. A copy of the as-built topographic survey conducted
by the Bissell Group (attached) indicates that the site close to design elevation. Elevations mostly
' vary from 30.19 to 30.92 feet msl throughout the site with several small isolated depressions.
' The following sections describe the methods that were used to monitor these elements within the
wetland creation/restoration sites.

10

4.0 PROJECT HISTORY
Spring 2001 - Littoral shelf on Pond B 1 planted
February 2002 - 7-acre creation area planted
April - June 2002 - Littoral shelf on ponds C1, A1, and A3 planted
March - November 2002 - Hydrologic Monitoring (Year 1)
October 2002 - Vegetation monitoring (Year 1)
September 2003 - Vegetation / Hydrologic Monitoring (Year 2)
September 2004 - Vegetation Monitoring (Year 3)
October 2004 - Submit Proposed remediation plan
February 2005 - USACE approves remediation plan
February 2006 - Second planting of 7-acre creation area
July 2006 - Installation of new hydrology monitoring wells
September 2006 - Vegetation Monitoring (Year 1)
July 19 - November 7, 2006 - Hydrologic Monitoring (Year 1)
11
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' 5.0 HYDROLOGY
5.1 Success Criteria
In accordance with federal guidelines for wetland mitigation, the success criteria for hydrology
' states that the area must be inundated or saturated (within 12" of the surface) by surface or
groundwater for a consecutive 12.5% of the growing season. Areas inundated for less than 5% of
' the growing season are always classified as non-wetlands. Areas inundated between 5% - 12.5%
of the growing season can be classified as wetlands depending upon factors such as the presence
' of wetland vegetation and hydric soils. The Revised Compensatory Wetlands Mitigation Plan
Plantation for Nucor Steel Plate Recycling Mill, Hertford County (November 1998) set a target goal
' of saturated soils for at least 22 days of the growing season.
The growing season in Hertford County begins March 28 and ends November 7. These dates
correspond to a 50% probability that temperatures will drop to 28°F or lower after March 28 and
before November 71. The growing season is 224 days; therefore, optimum hydrology requires
' 12.5% of this season, or at least 28 consecutive days. A consecutive 10% would be equivalent to
22.4 days (rounded to 22 days) and a consecutive 5% would be equivalent to 11.2 days (rounded
to 11 days). Local climate must also represent average conditions for the area.

5.2 Hydrologic Description
Five new groundwater-monitoring gauges (Figure 3) and one reference wetland gauge were
installed July 19, 2006, per ERDC TN-WRAP-00-02 entitled, Installing Monitoring
Wells/Piezometers, dated July 2000, to evaluate hydrology in the wetland creation area, local
1 Soil Conservation Service, Soil Survey of Hertford County, North Carolina, p. 61.
12
1

7
climate data, and reference wetland hydrology. The automatic monitoring gauges record daily
readings of groundwater depth. The Nucor Steel wetland site involved the construction of a
stormwater pond (C 1) adjacent to the wetland. Overflow from the pond enters into the wetland
creation area using a 300-foot diffuser. This connection should provide adequate hydrologic
input along with rainfall and groundwater to sustain the necessary hydrology for the wetland area.
The hydrologic monitoring should show the reaction of the groundwater and surface water levels
to specific rainfall events. Per the approved remedial action plan Nucor will conduct
maintenance of the wells in March of each monitoring year.
' 5.3 Results of Hydrologic Monitoring
5.3.1 Site Data

The maximum number of consecutive days that the groundwater was within twelve
inches of the surface was determined for each gauge. This number was converted into a
percentage of the 224-day growing season. The results are presented in Table 1.
Appendix A contains a plot of the groundwater depth for each monitoring gauge. The
maximum number of consecutive days is noted on each graph. The individual
precipitation events, shown on the monitoring well graphs as bars, represent data
collected from the rain gauge installed on site. The site was inundated and or saturated to
the surface during our site visits in July 2006 and September 2006.
Nucor purchased and installed six new automated wells to record the hydrology in the
creation area and in the reference wetland and will conduct routine maintenance on an
annual basis. The maintenance of the wells will be performed in March of each
monitoring season. The installation locations of the new wells were recorded to sub-
meter accuracy using a Trimble GeoXT GPS unit and are shown on the enclosed figure.
13

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Table 1 Hydrologic Monitoring 7-Acre Creation Area 2006
Permit Success Criteria
Monitoring

Gauge <5%
5-8%
8-12.5%
> 12.5% Actual Number of
(<11 days) (11-18 days) (19-28 days) (> 28 days) Consecutive Days Success Dates
GW1 Percent
GW2 • 32% 71 days) Aug. 29 - Nov. 07
GW2 • $2% 70 days) Aug. 30 - Nov. 07
GW4 Aug. 30 - Nov. 07
GW4 ti July 19 - Nov. 07
RW1 11 37 da s Oct. 02 -Nov. 07
32% 70 days) Aug. 30 -Nov. 07
5.3.2 Climatic Data
Figure 4 represents an examination of the local climate in comparison with historical data
in order to determine whether 2006 was "average" in terms of climate conditions. The
figure compares the on-site rainfall from 2006 with that of historical rainfall (data
collected between 1971 and 2000). The graph shows 2006 rainfall totals from January
2006 through November 2006, which includes the growing season for this site.
5.4 Conclusions
The monitoring gauges in the created wetland show saturation and inundation for greater that
12.5 percent of the growing season and represent a successful initial hydrologic period. The
monthly rainfall totals to date are in the average range.
14

fl
6.0 FALL 2006 VEGETATION
The seven acre created wetland occurs on the southern site boundary between the railroad corridor
and adjacent to Bazemore Road (Figure 2). The site encompasses approximately 7 acres of created
wetland. The creation areas was planted with sapling species, including swamp chestnut oak, green
ash, willow oak, water tupelo, water oak, laurel oak and bald cypress. Base on the approved
remediation plan 3,300 trees were planted in the creation area in the Winter of 2006. Three
transects with a total of seven plots were located within the creation.area.
Vegetation monitoring was conducted in accordance with the Comprehensive Wetland
Determination Methodologies as described in the US Army Corps of Engineers Wetland
Delineation Manual 1987. Three line transects were established along a baseline transect generally
oriented perpendicular to Bazemore Road. Sample plots were permanently established at random
within 300-foot intervals in 7-acre creation area. All transects and plots were marked with stakes
painted a fluorescent color to facilitate identification and future monitoring. Vegetative species
composition and dominance were measured within each sample plot. Trees were monitored within
30-foot radius circular plots. Herbaceous vegetation was monitored within 5-foot radius circular
plots. All herbaceous species were identified and the percent area cover recorded for each.
6.1 -Success Criteria

Success Criteria states that there must be a minimum mean density of 320 characteristic trees
species/acre surviving for at least three years in the wetland creation area of the site.
Characteristic tree species are those species planted along with natural recruitment of other
naturally occurring hydrophytic species. Sweetgum and red maple will not be considered in the
tally of the 320 trees per acre. No quantitative sampling success requirements were developed for
the herbaceous and shrub assemblages as part of the vegetation success criteria per the November
2002 mitigation plan.
15

6.2 Description of Species
The following tree species were planted during the remediation effort the Wetland Creation Area:
Fraxinus pennsylvanica, Green Ash
Quercus laurifolia, Laurel Oak
Nyssa aquatica, swamp tupelo
Taxodium distichum, Bald Cypress
6.3 Vegetation Data
Table 2. 7-acre Creation Area (Planted Trees)
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? 57 5 8 9 79 79 1215
2 30 50 11
- 10 101 101 1553
3 19 10 4 -7 40 40 615
4 10 2 1 4 17 17 261
5 15 8 2 0 25 25 384
23 16 1 6 46 46 707
7
7
22
20
4
24
70
70
1076
Average Tree Density 830
Site notes: other species observe include Acer rubrum, Panicum dichotomiflorum, Eleocharis
microcarpa, Cyperus globules, Scirpus cyperinus, and Cyperus iria. Standing water was present on the
majority of the site at the time of monitoring.
16

6.4 Created Wetiand Vegetation Conclusions
Seven acres were planted with 5,150 hardwood seedlings (approximately 735 trees per acre) in
' March 2002 and seven vegetation monitoring plots were established in the wetland creation area.
In February 2006, an additional 3,300 trees were planted in the creation area in accordance with
' the approved remediation plan. The Fall 2006 vegetation monitoring revealed an average density
of 830 trees per acre well above the 320 tree/acre minimum requirements.

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' 7.0 SUMMARY 2006
Hydrologic monitoring indicated that the site is consistently meeting the hydrology success
' criteria. The period of inundation/saturation ranged from 16-50% percent of the growing season
(from, wells installed, July 19, 2006 to November 7, 2006). The gauges indicated that inundation
' was a common state for much of the growing season. The reference wetland site indicated
saturation/inundation for 32 percent of the growing season and is consistent with the well
' observations from the creation area. Total average tree density across all seven plots was 830
trees per acre.
' Nucor Steel will continue monitoring the site to evaluate hydrologic and vegetation success and
' submit those reports to the appropriate agencies on an annual basis.

18
7

8.0 LITERATURE CITED
Corps of Engineers Wetlands Delineation Manual, 1987. by Environmental Laboratory.
Department of Army. Waterways experiment Station. Vicksburg, Mississippi. 99 pp. plus
appendices.
Natural Resources Conservation Service, Hertford County Soil Survey, 1984.
Radford, Alhes, and Bell, Manual of the Vascular Flora of the Carolinas, 1968. University of North
Carolina Press, Chapel Hill.
Revised Compensatory Wetlands Mitigation Plan Plantation for Nucor Steel Plate Recycling Mill,
Hertford County, November 8, 1999.
19
d

PHOTOGRAPHS
20

Photograph 1. Overview of 7-acre creation Area, September 2006. Facing Northwest Plot 1,
Transect 1.
a+z•
Photograph 2. Overview of 7-acre creation Area, September 2006. Plot 5, Facing North Transect 3
21

JY Y

b f 5
i1 ? tl Fl / h .-
a
,
:.. . M f
1
- l i Y r
k? l S A
?
v ,n i - Nor: ?P

Photograph 3. Creation Area, Transect No. 1, Plot 1, September 2006. Facing NE.
• iivw6laP11't. %-.rCM1on Area, 1 ransect No. 1, Plot 2, September 2006. Facing NE.
22
. '? ? l?I II??I?t
PRaGRAM
September 13, 2005
Mr. Terry Hairston
Nucor Steel
1505 River Road
Cofield, NC 27922
Project: Nucor Steel County: Hertford
Dear Mr. Hairston:
SEP 2 12005
BY ....................
We are in receipt of your request dated August 16, 2005 for the Ecosystem Enhancement
Program, In-Lieu Fee Program, to assume responsibility of providing mitigation for 2.32 acres of
Riparian Wetland impacts in the Chowan River basin, cataloging unit 03010203. We recognize
that this request differs from routine In Lieu Fee requests in that you are requesting that EEP
assume responsibility for the remaining compensatory mitigation requirements associated with
USACE Permit No. 199811324, dated March 1, 2000. Specifically, you have requested that EEP
assume mitigation responsibility for the 7.2 riparian wetland creation mitigation site initiated by
NUCOR and currently in monitoring. EEP understands that this 7.2 acre riparian wetland
creation mitigation requirement is the only remaining compensatory mitigation requirement that
has not yet been fulfilled under USACE Permit No. 199811324.
We have reviewed the Special Conditions contained in the above permit as well as the Special
Conditions contained in the Permit Modification dated February 14, 2005 in light of the
procedures that EEP follows when implementing mitigation sites for the In Lieu Fee program
governed by the NCDENR-USACE Memorandum of Understanding (MOU) dated November 4,
1998.
EEP is willing to accept your request for payment into the In Lieu Fee Program provided the
following conditions are met and agreed to by NUCOR, the Army Corps of Engineers and the
NC Division of Water Quality:
1. Nucor, the Army Corps of Engineers, and NC Division of Water Quality certify that all
other mitigation responsibilities (except.for the 7.2 acre riparian wetland creation
mitigation site) associated with USACE Permit No. 199811324 have been successfully
completed.
RestoY` ... E ... Prot?ctr; Our Stag ATA
Mr. Hairston
9/13/05
Page 2
2. Nucor successfully transfers a permanent conservation easement to EEP on the 7.2 acre
riparian wetland creation mitigation site so that EEP may continue to implement and
complete the 7.2 acre creation mitigation site or provide replacement mitigation from the
in lieu fee program.
3. The mitigation requirement being transferred to EEP is 7.2 acres of riparian wetland
creation or 3.6 credits of riparian wetland compensatory mitigation.
4. ESP's acceptance of the mitigation responsibility will be governed solely by the
procedures and guidelines established in the NCDENR-USACE Memorandum of
Understanding (MOU) dated November 4,1998.
5. Payment has been made by NUCOR to EEP to cover the costs of completing the
mitigation site.
Since the In Lieu Fee program is a joint partnership with the Army Corps of Engineers and
DENR, the COE will have to approve the use of the In Lieu Fee program in order to transfer the
7.2 acre creation mitigation responsibility to the Ecosystem Enhancement program.
Mr. William D. Gilmore, Director
North Carolina Ecosystem Enhancement Program
1652 Mail Service Center
Raleigh, North Carolina 27699-1652
Mr. Ronald J. Mikulak, Chief
Wetlands Regulatory Section
Water Management Div.
U.S. Environmental Protection Agency
61 Forsyth Street; SW
Atlanta, GA 30303
Mr. Pete Benjamin
U.S. Fish and Wildlife Service
Fish and Wildlife Enhancement
Post Office Box 33726
Raleigh, North Carolina 27636-3726
Mr. Ron Sechler
National Marine Fisheries Service
101 Pivers Island
Beaufort, North Carolina 28516
Ms. Becky Fox
USEPA/Wetlands Regulatory Section
1349 Firefly Road
Whittier, North Carolina 28789
Ms. Cyndi Karoly
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1650 Mail Service Center
Raleigh, North Carolina 27699
Ms. Maria Tripp
North Carolina Wildlife Resources Commission
943 Washington Square Mall
Washington, North Carolina 27889
3
Mr. Terry Moore
District Manager
North Carolina Division of Coastal Management
943 Washington Square Mall
Washington, North Carolina 27889
Mr. Kyle Barnes
North Carolina Division of Water Quality
943 Washington Square Mall
Washington, North Carolina 27889
Mr. R. Clement Riddle
224 South Grove Street, Suite F
Hendersonville, North Carolina 28792
4

TABLE OF CONTENTS
.3
LIST OF FIGURES ................................................................ ..............................................................
4
LIST OF PHOTOGRAPHS ................................................... ..............................................................
EXECUTIVE SUMMARY ................................................... ................................................................ 5

1.0 INTRODUCTION ........................................................... ................................................................6
8
0 PURPOSE ............................................................
2 ......................................................... ...............
.
3.0 METHODS .......................................................... ............................................................................9
4.0 PROJECT HISTORY ...................................................................................................................10
5.0 HYDROLOGY .............................................................................................................................11
5.1 Success Criteria ............................................................................................................... 11
5.3 Hydrologic Description ................................................................................................... 11
5.3 Results of Hydrologic Monitoring ..................................................................................12
5.4 Conclusions .....................................................................................................................13
6.0 FALL 2003 VEGETATION ..........................................................................................................14
6.1 Success Criteria ...............................................................................................................14
6.2 Description of Species .....................................................................................................15
6.4 Created Wetland Vegetation Conclusions .......................................................................17
7.0 SUMMARY 2003 ..........................................................................................................................19
8.0 LITERATURE CITED ..................................................................................................................20
PHOTOGRAPHS ................................................................................................................................21

LIST OF FIGURES
Figure 1 Site Location Map ........................................................................42
Figure 2 Site Plan ....................................................................................43
Figure 3 Wetland Creation Area ...................................................................44
Figure 4a Rainfall 30 - 70 Percentile Graph (Edenton 30 Year WETS data) .................45
Figure 4b Rainfall 30 - 70 Percentile Graph (Lewiston 30 Year WETS data) ...............46

r

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LIST OF PHOTOGRAPHS
Photograph 1. Overview of Creation Area, Fall 2003 ......................................................................... 22
Photograph 2. Overview of Creation Area, Fall 2003 ......................................................................... 22
Photograph 3. Creation Area, Transect No. 1, Plot 1, 2003 ............................................................... 23
Photograph 4. Creation Area, Transect No. 1, Plot 2, 2003 ............................................................... 23
Photograph 5. Creation Area, Transect No. 1, Plot 3, 2003 ............................................................... 24
Photograph 6. Creation Area, Transect No. 2, Plot 4, 2003 ............................................................... 24
Photograph 7. Creation Area, Transect No. 2 Plot 5, 2003 ................................................................ 25
Photograph 8. Creation Area, Transect No. 3, Plot 6, 2003 ............................................................... 25
Photograph 9. Creation Area, Transect No. 3, Plot 7, 2003 ............................................................... 26
Photograph 10. Pond Cl, Plot 1, 2003 ............................................................................................... 26
Photograph 11. Pond Cl, Plot 2, 2003 .............................................................................................. 27
Photograph 12. Pond Cl, Plot 3, 2003 .............................................................................................. 27
Photograph 13. Pond Cl, Plot 4, 2003 No picture missing plot stake .............................................. 28
Photograph 14. Pond Cl, Plot 5, 2003 .............................................................................................. 28
Photograph 15. Pond Cl, Plot 6, 2003 .............................................................................................. 29
Photograph 16. Pond Cl, Plot 7, 2003 .............................................................................................. 29
Photograph 17. Pond B1, Plot 1, 2003 .............................................................................................. 30
Photograph 18. Pond B1, Plot 2, 2003 .............................................................................................. 30
Photograph 19. Pond Bl, Plot 3, 2003 .............................................................................................. 31
Photograph 20. Pond B1, Plot 4, 2003 .............................................................................................. 31
Photograph 21. Pond B 1, Plot 5, 2003 .................................................................... • 32
Photograph 22. Pond B1, Plot 6, 2003 ...................................................................... 32
Photograph 23. Pond Bl, Plot 7, 2003 .............................................................................................. 33
Photograph 24. Pond B1, Plot 8, 2003 .............................................................................................. 33
Photograph 25. Pond Bl, Plot 9, 2003. No picture missing plot stake .............................................. 34
Photograph 26. Pond B1, Plot 10, 2003 ............................................................................................ 34
Photograph 27. Pond Bl, Plot 11, 2003 ............................................................................................ 35
Photograph 28. Pond B1, Plot 12, 2003 ............................................................................................ 35
Photograph 29. Pond Al, Plot 1, 2003 .............................................................................................. 36
Photograph 30. Pond Al, Plot 2, 2003. No picture missing plot stake .............................................. 36
Photograph 31. Pond Al, Plot 3, 2003 .............................................................................................. 37
Photograph 32. Pond Al Plot 4, 2003 ............................................................................................... 37
Photograph 33. Pond Al, Plot 5, 2003 ..................................................................... ..................... 38
Photograph 34. Pond A3, Plot 1, 2003 .............................................................................................. 38
Photograph 35. Pond A3, Plot 2, 2003 .............................................................................................. 39
Photograph 36. Pond A3, Plot 3, 2003 .............................................................................................. 39
Photograph 37. Pond A3, Plot 4, 2003 .............................................................................................. 40
Photograph 38. Pond A3, Plot 5, 2003 .............................................................................................. 40
Photograph 39. Pond A3, Plot 6, 2003 .............................................................................................. 41
Photograph 40. Pond A3, Plot 7, 2003 .............................................................................................. 41
1

EXECUTIVE SUMMARY
Nucor Steel (Nucor) was issued a Department of the Army Permit (No. 199811324), a N.C. Division
of Water Quality 401 Certification (990231), and a Division of Coastal Management Permit (79-99) to
construct a railroad crossing and stormwater management ponds in unnamed intermittent tributaries of
the Chowan River and wetlands adjacent to Brooks Creek in Hertford County, North Carolina. As a
special condition to these permits, Nucor is required to implement mitigation measures outlined in the
' Revised Compensatory Wetlands Mitigation Plan Plantation for Nucor Steel Plate Recycling Mill,
Hertford County, November 8, 1999. The Mitigation Plan includes creation of a seven acre
bottomland hardwood wetland and creation of 2.68 acres of littoral shelves along the periphery of four
stormwater ponds, as well as the preservation of 150 acres of swamp forest along the Chowan River
and 14.68 acres of wetlands on-site. 'T'hese mitigation efforts are required to offset unavoidable
impacts to 2.32 acres of jurisdictional freshwater wetlands. The as-built monitoring was conducted in
May 2002, after construction and planting of the mitigation areas. The first annual fall monitoring was
conducted in October 2002. This document is the second annual fall monitoring report and
summarizes the monitoring conducted in September of 2003. Nucor will continue to monitor these
areas for the next three years and report the results annually to the U.S. Army Corps of Engineers
(USACE), N.C. Division of Water Quality (DWQ), and the N.C. Division of Coastal Management
' (CAMA).

I

1.0 INTRODUCTION
Nucor Steel (Nucor) was issued a Department of the Army Permit (No. 199811324), a N.C. Division
of Water Quality 401 Certification (990231), and a Division of Coastal Management Permit (79-99) to
construct a railroad crossing and stormwater management ponds in unnamed intermittent tributaries of
the Chowan River and wetlands adjacent to Brooks Creek in Hertford County, North Carolina (Figure
1). As a special condition to these permits, Nucor is required to implement mitigation measures
outlined in the Revised Compensatory Wetlands Mitigation Plan Plantation for Nucor Steel Plate
Recycling Mill, Hertford County, November 8, 1999.
The Mitigation Plan schedules activities to offset unavoidable impacts to 2.32 acres of jurisdictional
freshwater wetlands/Waters of the U.S. Jurisdictional wetlands are defined by 33 CFR Part 328.3(b)
and are protected by The Clean Water Act (33 CFR 1344) which is administered and enforced by the
U,S. Army Corps of Engineers (USACE). Mitigation efforts for the project include the following:
• 7-acre wetland creation area
• Pond Cl includes 0.604-acres of littoral shelf.
• Pond B 1 includes a 0.917-acres littoral shelf.
• Pond Al includes 0.839-acres littoral shelf.
• Pond A3 includes a 0.504-acres littoral shelf.
• 14.87-acres of Preserved Wetlands on-site
• 150 acres of preserved wetlands off-site
Planting of hydrophytic tree species was conducted at the seven acre wetland creation area (Figure 3)
and hydrophytic herbaceous species were planted on the littoral shelves at ponds Al, Bl, Cl and A3
(Figure 2). Hardwood saplings include the following species bald cypress (Taxodium distichum),
6

green ash (Fraxinus pennslyvanica), laurel oak (Quercus laurifolia), swamp chestnut oak (Quercus
michauxii), water tupelo (Nyssa biflora), willow oak (Quercus phellos), and water oak (Quercus
' ni a . Wax myrtle (Myrica cerifera) was planted along the transition area between the wetland area
' and the upland area. Herbaceous species planted on the littoral shelves included pickerel weed
(Pontedaria cordata), arrow arum (Peltandra virpnica), soft rush (Juncus effusus), lizard's tail
1 (Saururus cernuus), shallow sedge (Carex lurida) and uptight sedge (Carex stricta).
' Planting of hardwood saplings at the creation area was conducted in winter of 2002. Planting of
herbaceous species was conducted in Pond BI in the spring of 2001 and ponds C l, A3, and half of
' pond Al were planted in spring 2002. The remainder of Pond Al was planted in June of 2002. A total
of 5,150 seedling tree species as described above were planted on at least 6 x 10-foot center spacings
' (or 726 trees per acre) and approximately 51,885 herbaceous species were planted on 18-inch spacings
per the Revised Compensatory Wetlands Mitigation Plan for Nucor Steel Plate Recycling Mill (1999).
' Monitoring of wetlands and littoral shelves associated with the impoundments are to be carried out for
five years with a regulatory review after the fifth year to determine success. This report summarizes
' the second year results for the Fall of 2003. Mitigation monitoring was conducted in September 2003.
Details of the wetland preservation on-site and off-site were provided in the As-Built report dated

11

July 16, 2002.
7

' 2.0 PURPOSE
In order to demonstrate successful mitigation, the Nucor Steel wetland creation area must be
monitored for both hydrology and vegetation for a minimum of five years or until success criteria
' are fulfilled. Success criteria are based on federal guidelines for wetland mitigation. The following
report details the results of hydrologic and vegetative monitoring during the fall of 2003 at the
Nucor Steel Hertford County site as well as local climate conditions throughout the growing
' season.
The purpose of the long term monitoring program is to quantify the developing structure of the created
' bottomland hardwood and littoral shelf wetlands. Data collected will be used to determine the
regeneration and survivability of planted wetland vegetation, as well as the success of wetland
mitigation efforts. Also a qualitative analysis will be formulated through observations of vegetative
growth and wildlife usage throughout the mitigation areas. The goal of the proposed mitigation is to
offset impacts to on site wetlands by replacing lost functions and values with equal or higher functions
and values. The primary target functions to be replaced are stormwater storage and filtration
capacities, stormwater transfer, and habitat resources.

1

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1
8

' 3.0 METHODS
' As described in the Revised Compensatory Wetlands Mitigation Plan Plantation for Nucor Steel Plate
Recycling Mill, Hertford County (November 1998) prepared for Nucor, monitoring of wetland
' vegetation and hydrology was conducted on the mitigation areas. Photographs are taken annually to
document conditions occurring within the wetlands mitigation sites for future comparison.
The site was constructed over a year period beginning in the spring of 2001 and finishing in the winter
' of 2002. Prior to excavation beginning, spot elevations within existing wetland "W/X" were taken to
set the target elevation for the creation area. The target elevation was approximately 29 feet msl. The
1 site was graded to 28 feet and backfilled with approximately 1 foot of topsoil. The as-built elevations
indicate that the wetland creation area is mostly flat and averages an elevation near 28.5.
The following sections describe the methods that were used to monitor these elements within the
' wetland creation/restoration sites.

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i
4.0 PROJECT HISTORY
Spring 2001 - Littoral shelf on Pond B 1 planted
February 2002 - 7-acre creation area planted
April - June 2002 - Littoral shelf on ponds Cl, Al, and A3 planted
March - November 2002 - Hydrologic Monitoring (Year 1)
October 2002 - Vegetation monitoring (Year 1)
September 2003 - Vegetation / Hydrologic Monitoring (Year 2)
10

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1

5.1 Success Criteria
5.0 HYDROLOGY
In accordance with federal guidelines for wetland mitigation, the success criteria for hydrology
states that the area must be inundated or saturated (within 12" of the surface) by surface or
groundwater for a consecutive 12.5% of the growing season. Areas inundated for less than 5% of
the growing season are always classified as non-wetlands. Areas inundated between 5% - 12.5%
of the growing season can be classified as wetlands depending upon factors such as the presence
of wetland vegetation and hydric soils. The Revised Compensatory Wetlands Mitigation Plan
Plantation for Nucor Steel Plate Recycling Mill, Hertford County (November 1998) set a target goal of
saturated soils for at least 22 days of the growing season.
The growing season in Hertford County begins March 28 and ends November 7. These dates
correspond to a 50% probability that temperatures will drop to 28°F or lower after March 28 and
before November 71. The growing season is 224 days; therefore, optimum hydrology requires
12.5% of this season, or at least 28 consecutive days. A consecutive 10% would be equivalent to
22.4 days (rounded to 22 days) and a consecutive 5% would be equivalent to 11.2 days (rounded
to 11 days). Local climate must also represent average conditions for the area.
5.2 Hydrologic Description
Five groundwater-monitoring gauges (Figure 3), one rain gauge and one reference wetland gauge
were installed in the spring of 2002 to evaluate hydrology in the wetland creation area, local
climate data, and reference wetland hydrology. The automatic monitoring gauges record daily
readings of groundwater depth. The Nucor Steel wetland site involved the construction of a
stormwater pond (Cl) adjacent to the wetland. Overflow from the pond enters into the wetland
creation area using a 300-foot diffuser. This connection should provide adequate hydrologic input
i Soil Conservation Service, Soil Survey of Hertford County, North Carolina, p. 61.
11

along with rainfall and groundwater to sustain the necessary hydrology for the wetland area. The
' hydrologic monitoring should show the reaction of the groundwater and surface water levels to
specific rainfall events.
1
5.3 Results of Hydrologic Monitoring
' 5.3.1 Site Data
' The maximum number of consecutive days that the groundwater was within twelve inches
of the surface was determined for each gauge. This number was converted into a
' percentage of the 224-day growing season. The results are presented in Table 1.
Appendix A contains a plot of the groundwater depth for each monitoring gauge and the
surface water depth recorded by the surface gauges. The maximum number of consecutive
days is noted on each graph. The individual precipitation events, shown on the monitoring
r well graphs as bars, represent data collected from the rain gauge installed on site. The
attached pictures (1-9) show the site inundated/and saturated during our site visit in
September 2003.

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Table 1 Hydrologic Monitoring 7-Acre Creation Area 2003
Permit Success Criteria
Monitoring <50/0 5-8% 8-12.5% > 12.5% p?ctual Number of
Consecutive Days
Success Dates
Gauge (< 11 days) (11-18 days) -28 days)
(19 Ys) 28 days)
( Percent
GW1 • 100 % 224 days) March 28 - Nov. 07
GW2 • 100 % 224 days) March 28 - Nov. 07
March 28- July 11
GW3 • * 67 % (149 days) and September 26 -
November 7
GW4 0 100 % 224 days) March 28 - Nov. 07
GW5 * No Data
March 28-May 12
RW1 0 250/6 (56 days) and September 12 -
Nov 7
GW5 could not be located one to extensive vegewuuu giuww.
GW3 did not record hydrology data July 12, 2003 until September 25, 2003, due to a dead battery.
5.3.2 Climatic Data
Figure 4 represents an examination of the local climate in comparison with historical data in order
to determine whether 2003 was "average" in terms of climate conditions. The figure compares the
on-site rainfall from 2003 with that of historical rainfall (data collected between 1971 and 2000).
The graph shows 2003 rainfall totals from January 2003 through December 2003, which includes
the growing season for this site.
5.4 Conclusions
2003 represents the second full growing season that hydrologic data has been examined. The
monitoring gauges in the created wetland show saturation and inundation for greater that 12.5
percent of the growing season and represent a successful initial hydrologic period. The monthly
rainfall totals are in the average to above average range.
13
11

1
6.0 FALL 2003 VEGETATION
1
The seven acre created wetland occurs on the southern site boundary between the railroad corridor and
' adjacent to Bazemore Road (Figure 2). The site encompasses approximately 7 acres of created
wetland. Portions of this area have been planted with sapling species, including swamp chestnut oak,
' green ash, willow oak, water tupelo, water oak, laurel oak and bald cypress. Three transects with a
total of seven plots were located within the creation area.
1
Vegetation monitoring was conducted in accordance with the Comprehensive Wetland Determination
' Methodologies as described in the US Army Corps of Engineers Wetland Delineation Manual 1987.
Three line transects were established along a baseline transect generally oriented perpendicular to
' Bazemore Road. Sample plots were permanently established at random within 300-foot intervals in 7-
acre creation area and at 200 to 300 foot intervals along the littoral shelves. All transects and plots
were marked with stakes painted a fluorescent color to facilitate identification and future monitoring.
Vegetative species composition and dominance were measured within each sample plot. Trees were
' monitored within 30-foot radius circular plots. Herbaceous vegetation was monitored within 5-foot
radius circular plots. All herbaceous species were identified and the percent areal cover recorded for
1 each
6.1 Success Criteria
Success Criteria states that there must be a minimum mean density of 320 characteristic trees
' species/acre surviving for at least three years in the wetland creation area of the site.
Characteristic tree species are those species planted along with natural recruitment of other
naturally occurring hydrophytic species. Sweetgum and red maple will. not be considered in the
tally of the 320 trees per acre. No quantitative sampling success requirements were developed for
the herbaceous and shrub assemblages as part of the vegetation success criteria per the November
2002 mitigation plan.
-)A" J'C 1999 ?^
1 14

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1
6.2 Description of Species
The following tree species were planted in the Wetland Creation Area:
Quercus michauxii,
Quercus nigra,
Quercus phellos,
Frwdnus pennsylvanica,
Quercus laurifolia,
Nyssa aquatica,
Taxodium distichum,
Swamp Chestnut Oak
Water Oak
Willow Oak
Green Ash
Laurel Oak
swamp tupelo
Bald Cypress
1 The following herbaceous species were planted on the littoral shelves:

' Juncus effusus,
Pontederia cordata, Soft Rush
Pickerel Weed
Peltandra virginica, Arrows arum

' Carex lurida,
i shallow sedge
e
ht sed
ti
u
cta,
Carex str g
g
p

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6.3 VEGETATION DATA

1 A{Ji?i i . -AV¦?i v¦vw?.v ...-. -- ---

m
E w

c

¢ A
O
° m y
N v

4. CL
H 0
°r O
M
3
c
(D
~ c

a c M
p m
co c -_ 41
m S U 0
-
0

1 22 3 0 0 0 5 0 30 44 462
2 2 19 0 0 0 9 0 30 50 462
3 3 4 0 0 0 3 0 10 38 154
4 2 1 0 0 0 1 1 5 29 77
5 3 1 0 0 0 1 0 5 17 77
6 2 4 0 0 0 1 0 7 23 108
7 4 6 0 0 0 4 1 15 41 231
I Average Tree Density ZZ4
Site notes: other species observe include Acer rubrum, Panicum dichotomiflorum, Eleocharis
microcarpa, Cyperus globules, and Cyperus iria. Standing water was present on the majority of the site at
the time of monitoring.
15
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CILF V V. Vnw .a¦ v.¦?.¦. vv
Notes

Pickerel
Arrows Lizard's
shallow
uptight
Total
Plot # Soft Rush weed arum tail
% sedge sedge Areal
% cover % cover % cover % cover % cover Cover
cover
C1 5 0 0 5
C2 0
C3 0
Plot Stake Not Found
C4
C5 3
1
15 3
19
Eleocharis spp. 3%
C6
C7 2 16 Eleocharis spp. 4%
Sci us cyperinus 10%
Al 10 13 Eleocharis spp. 3%
Plot Stake Not Found
A3 50 3 81 Ludwigia leptocarpa 2%
Cyperus strigosus 10%
Agalinis purpurea 5%
Echinochloa crusgaN 1%
Panicum spp 3%
Bidens aristosa 2%
Ludwigia linearis 2%
Polygonum
Hydropiperoides 3%
A4 2 2 41 Polygonum
Hydropiperoides 5%
Cyperus strigosus 3%
Panicum spp. 4%
Echinochloa crusgalli 5%
Eleocharis spp. 20%
A5 20 3 84 Ludwigia linearis 1%
Cyperus strigosus 25%
Polygonum spp. 3%
Eleocharis spp. 15%
Panicum spp. 15%
Echinochloa crusgallis 1%
Ludwigia leptocarpa 1%
131 10 3 25 Typha latifolia 2%
Najas s pp. 10%
B2
B3 30 10 40
B4 7 22 Najas spp. 15%
B5 7 37 Najas spp. 30%
B6 2 5 Typha latffolia3%
B7 10 25 Najas spp. 15%
16

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1
68 1 26 Najas spp. 10%
Eleocharis spp. 15%
Plot Stake Not Found
B9
B10 1 21 Najas spp. 20%
Plot Stake Not Found
1311
B12 15 2 28 Najas spp. 10%
Eleocharis s pp. 1%
3A1 5 3 8 Vegetation Submerged
3A2 5 3 10 Panicum spp. 2%
Vegetation Submerged
3A3 5 5 Vegetation Submerged
3A4 1 3 4
3A5 3 3 unknown #1 10%
3A6 1 Scirpus cyperinus 1%
3A7 F - E 1 Sci?pus cyperinus 1%
6.4 Created Wetland Vegetation Conclusions
' Seven acres were planted with 5,150 hardwood seedlings in March 2002 and seven vegetation
monitoring plots were established in the wetland creation area. The Fall 2002 vegetation
monitoring revealed an average density of 415 trees per acre, well above the 320 tree/acre
minimum requirements. The Fall 2003 vegetation monitoring revealed an average density of 224
trees per acre. The majority of the tree mortality observed between the 2002 and 2003
monitoring seasons can be attributed to high water levels within the wetland creation area due to
above average rainfall conditions. This conclusion is supported by the high survivability rates of
bald cypress, water tupelo, and green ash and low survivability of less water tolerant oak species.
Nucor does not propose any additional plantings in the wetland area for the winter of 2004.
Based on the Fall 2004 vegetation monitoring results, we may propose to supplement tree
' plantings to include more water tolerant species in the winter of 2005. The Fall 2004 report will
provide information regarding pioneer species or a plan for additional tree plantings.
The littoral shelves encompass approximate 2.86 acres along the periphery of the four stormwater
ponds. The four ponds (Bl, Al, A3, and Cl) were planted and sampled using transects that
parallel the ponds edge for a total of thirty one sample plots. The littoral shelves were planted in
17

1
the Spring of 2002 and are typically 10 to 12 feet wide. As seen in the attached photographs the
herbaceous vegetation has been established on the littoral shelves. Baseline monitoring at the
littoral shelves indicates a successful attempt to introduce aquatic vegetation to the shoreline of
the stormwater ponds. We expect additional naturally occurring herbaceous species to become
more abundant and diverse in the future.
11
1
F
0
1
1

u

18
1
1
' 7.0 SUMMARY 2003
' Hydrologic monitoring indicated that the site is consistently meeting the hydrology success
criteria. The shortest period of inundation/saturation was 67 percent of the growing season. The
' gauges indicated that inundation varies from 67 percent to 100 percent for the growing season.
The high percentage of inundation within the mitigation area is likely attributed to above average
' rainfall. The reference wetland site indicated saturation/inundation for 25 percent of the growing
season which is considerably higher than the 9 percent observed for the year 2002 in that area.
1
Total average tree density across all seven plots was 224 trees per acre. The tree mortality
observed during 2003 should be attributed to the prolonged period of inundation/saturation. The
most water tolerant species (bald cypress, tupelo, and green ash) have maintained a high
' survivability rate. Nucor will monitor vegetation next year and include voluntary tree species in
the survey. If the trees per acre, including appropriate volunteer species, remain below 320 trees
t per acre, then Nucor will conduct a supplemental planting of tree species.
I Nucor Steel will continue monitoring the site to evaluate hydrologic and vegetation success for
the next three years and submit those reports to the appropriate agencies on an annual basis.

1
1
1
19
1

' 8.4 LITERATURE CITED
Corps of Engineers Wetlands Delineation Manual, 1987. by Environmental Laboratory. Department of
Army. Waterways experiment Station. Vicksburg, Mississippi. 99 pp. plus appendices.
' Natural Resources Conservation Service, Hertford County Soil Survey, 1984.
Radford, Alhes, and Bell, Manual of the Vascular Flora of the Carolinas, 1968. University of North
1 Carolina. Press, Cbapel Hill.
Revised Compensatory Wetlands Mitigation Plan Plantation for Nucor Steel Plate Recycling Mill,
Hertford County, November 8, 1999.
7

I
1
20

1
1
1

1

0
1

11

1
PHOTOGRAPHS
21
A
NO PICTURE; Missing Plot Stake

617-. 411
4. i- _ - : ? iot 5. Septen?t Fac;i 1g North
28
Photograph 13. Pond Cl Plot 4. September 2003. Facing East
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Photograph 15. Pond C 1 Plot 6 September 2003. Facing North East.
29
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Photograph 16. Pond Cl Plot 7 September 2003. Facing East.
30

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Photograph 17. Pond B1 Plot 1 September 2003. Facing east.
? a•
Photograph 18. Pond BI Plot 2 September 2003. Facing north.

31

Photograph 19. Pond B 1 Plot 3 September 2003. Facmg south.
Photograph 20. Pond B1 Plot 4 September 2003. Facmg south.

32
Photograph 21. Pond B1 Plot 5 September 2003. racing south.
Photograph 22. Pond B 1 Plot 6 September 2003. Facing southeast.
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Photograph 24. Pond B 1 Plot 8 September 2003. Facing west.
33
Photograph 23. Pond BI Plot 7 September 2003. Facing north.
NO PICTURE; Missing Plot Stake
Photograph 25. Pond B1 Plot 9 September 2003. Facing west.
Photograph 26. Pond B1 Plot 10 September 2003. Facing north
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34
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35
Photograph 27. Pond B 1 Plot 11 September 2003. Facing north.
Photograph 28. Pond B 1 Plot 12 September 2003. Facing north.

I NO PHOTOGRAPH; Picture did not develop
Photograph 29. Pond Al Plot 1 September 2003. Facing north.

NO PHOTOGRAPH; Missing Plot Stake
Photograph 30. Pond Al Plot 2 September 2003. Facing north.

36

Photograph 31. Pond Al Plot 3 September 2003. Facing north
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Photograph 32. Pond Al Plot 4 September 2003. Facing north
37
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Photograph 34. Pond A3 Plot 1 September 2003. Facing southwest.
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38
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Pond Al Plot 5 September 2003. Facing north.

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Photograph 35. Pond A3 ?lot 2 September 2003. Facing southwest.
tis.?' . F Fyt., -.. ,:e 5n 1 F ?:j I r: ..aJfl; c 's f•1.3 ., .. a. I
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Photograph 36. Pond A3 Plot 3 September 2003. Facing northwest.
39

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Pho Lo _-_ Pond A3 Plot 6 September 2003. Facing east.

41
\ _7

Nucor Steel CLEARWATER LOCATION MAP
Environmental Consultants, Inc.
Hertford County, 300 N. Main Street, Ste 202
Hendersonville, NC 28792 Figure 1
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NO DATA
Well 5 could not be located due to
? extensive vegetation growth.

?A7F Michael F. Easley, Governor
O
R
O? pG William G. Ross Jr., Secretary
`
y North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P. E. Director
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
January 7, 2004
Mr. Clement Riddle
Clearwater Environmental Consultants, Inc.
300 N. Main Street Suite 202
Hendersonville, NC 28792
Re: Nucor Plate Mill Annual Mitigation Report For 2003
Dear Mr. Riddle:
DWQ recently received and has reviewed your December 2003, "Nucor Plate Mill: Annual
Mitigation Report for 2003." As was expressed to you in our phone conversation on January 7,
2004, several observations were made or concerns raised upon review of the document. While you
have acknowledged some of these concerns yourself and have suggested causes, we feel that it is
important that we note the issues as well.
1) The vegetation success criteria of 320 trees/acre must be met for five years (as stated in the
"Revised Compensatory Wetlands Mitigation Plan: November 8, 1999") not for three years as
stated in the "Annual Mitigation Report for 2003: December 2003".
2) We are concerned with the mortality of the trees between 2002 and 2003. This loss may have
been due to the wet year in 2003. If you choose to wait to re-plant after the 2004 monitoring
season, the five year time frame for the success criteria will reset after the planting has occurred.
3) The water level for the site (primarily 100 % inundation for 2003) may be problematic for some
of the selected tree species. The water level for 2002 did have fluctuations between inundation,
saturation within 12 inches, and water levels below 12 inches; however, 2002 was an unusually
dry year. It is possible that the created site may remain inundated for the entire year during an
average rainfall year. The hydrologic monitoring for 2004, may provide some insight as to the
best, final tree species composition for the site.
4) The November 8, 1999 mitigation plan states that, "Successful accomplishment of the planting
goals will be determined by the establishment of vegetative shelves that have 75% aerial
coverage within the three ponds." Only two vegetation plots (A3 and A5) have met these
criteria. While pond A and B have been improving in their aerial coverage, pond C and 3A have
decreased.

N. C. Division of Water Quality, 401 Wetlands Certification Unit,
1650 Mail Service Center, Raleigh, NC 27699-1650 (Mailing Address)
2321 Crabtree Blvd., Raleigh, NC 27604-2260 (Location)
[phone] (phone), 919-733-6893 (fax), (http://h2o.enr.state.nc.us/ncwetlands
You do not need to respond to this correspondence; however, if you have any questions or need any
further assistance please do not hesitate to contact Amanda Mueller at [phone].
Cc: Central files
File Copy

N. C. Division of Water Quality, 401 Wetlands Certification Unit,
1650 Mail Service Center, Raleigh, NC 27699-1650 (Mailing Address)
2321 Crabtree Blvd., Raleigh, NC 27604-2260 (Location)
1919) 733-1786 (phone), 919-733-6893 (fax), (http://h2o.enr.state.nc.us/ncwetlands
Sincerely Yours,
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality

James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
ivlr. Griffin Daughtridge
General Manager
Nucor Steel - Hertford
216 North Street
Ahoskie, NC 27910
Dear Mr. Daughtiidge:
1 ? •
AwAftftmooom
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
August 31, 1999
Re: Certification Pursuant to Section 401 of the Federal Clean Water Act.
Proposed Nucor Steel Plant in Hertford County,
WQC Project n 990231 COE T# 199811324
Attached hereto is a copy of Certification No. 3241 issued to Nucor Steel dated August 31,
1999.
If we can be of further assistance, do not hesitate to contact us.
Attachments
990231. wqc
Si erel
.Ste ns
cc: Wilmington District Corps of Engineers
Corps of Engineers Washington Field Office
Washington DWQ Regional Office
Mr. Doug Huggett, Division of Coastal Management
Central Files
Edythe McKinney, DENR
Clement Riddle: Newkirk Environmental. Inc.
John Sutherland; DWR
Clark Wright; Ward and Smith, P.A.
File Copy
Division of Water Quality • Environmental Sciences Branch
Enviro. Sciences Branch, 4401 Reedy Creek Rd., Raleigh, NC 27607 Telephone [phone] FAX # [phone]
An Equal Opportunity Affirmative Action Employer • 50% recycled/10% post consumer paper'

NORTH CAROLINA 401 WATER QUALITY CERTIFICATION
THIS CERTIFICATION is issued in conformity with the requirements of Section 401
Public Laws 92-500 and 95-217 of the United States and subject to the North Carolina Division
of Water Quality (DWQ) Regulations in 15 NCAC 2H, Section .0500 to Nucor Steel resulting in
2.32 acres of permanent wetland impacts and 0.19 acres of temporary wetland impact pursuant to
the original application filed on March 19, 1999 and a revised application filed on the 22°d day of
July 1999 to construct a steel recycling facility on the Chowan River.
The application provides adequate assurance that the discharge of fill material into the
waters of the Chowan River and its unnamed tributaries in conjunction with the proposed
development will not result in a violation of applicable Water Quality Standards and discharge
guidelines. Therefore, the State of North Carolina certifies that this activity will not violate the
applicable portions of Sections 301, 302, 303, 306, 307 of PL 92-500 and PL 95-217 if
conducted in accordance with the application and conditions hereinafter set forth.
This approval is only valid for the purpose and design that you submitted in your
application, as described in the Public Notice and subsequent modifications. If you change your
project, you must notify us and send us a new application for a new Certification. If the property
is sold, the new owner must be given a copy of the Certification and approval letter and is
thereby responsible for complying with all conditions. Should additional wetland fill be
requested in the future, compensatory mitigation may be required as described in 15A NCAC 2H
.0506 (h) (6) and (7). For this approval to be valid, you must follow the conditions listed below.
In addition, you should get any other federal, state or local permits before you go ahead with
your project including (but not limited to) Sediment and Erosion Control, Non-discharge and
Water Supply Watershed regulations.
Condition(s) of Certification:
Appropriate sediment and erosion control practices which equal or exceed those outlined
in the most recent version of two manuals either the "North Carolina Sediment and
Erosion Control Planning and Design Manual" or the "North Carolina Surface Mining
Manual" (available from the Division of Land Resources in the DENR Regional or
Central Offices). The control practices shall be utilized to prevent exceedances of the
appropriate turbidity water quality standard (50 NTUs in all fresh water streams and
rivers not designated as trout waters; 25 NTUs in all lakes and reservoirs, and all
saltwater classes; and 10 NTUs in trout water).
2. All sediment and erosion control measures placed in wetlands or waters shall be
removed and the natural grade restored after the Division of Land Resources has released
the project.
3. Measures shall be taken to prevent live or fresh concrete from coming into contact with
waters of the state until the concrete has hardened.
4. If waste or borrow sites for fill material be located in wetlands or other waters, an
additional 401 Certification as well as compensatory mitigation will be required since it
is a direct impact from this project.
5. Compensatory mitigation shall be done in accordance with the approved Corps of
Engineers requirements at least as stringent as those described in July 21, 1999 submittal

A )?
from Clement Riddle; Newkirk Environmental, Inc. DWQ shall receive three copies of
the as-built and annual reports for the mitigation.
6. Any ditching in or adjacent to wetlands which impact the hydrology of the wetland is not
allowed since it would be a violation of wetland standards (I5ANCAC 2B .0231).
7. This Certification shall expire three (3) years from the date of issuance of the 404
Permit.
Violations of any condition herein set forth shall result in revocation of this Certification
and may result in criminal and/or civil penalties. This Certification shall become null and void
unless the above conditions are made conditions of the Federal 404 Permit. This Certification
shall expire upon expiration of the 404 Permit.
If this Certification is unacceptable, you have the right to an adjudicatory hearing upon
written request within sixty (60) days following receipt of this Certification. This request must
be in the form of a written petition conforming to Chapter 150B of the North Carolina General
Statutes and filed with the Office of Administrative Hearings, P.O. Box 27447, Raleigh, N.C.
27611-7447. If modifications are made to an original Certification, you have the right to an
adjudicatory hearing on the modifications upon written request within sixty (60) days following
receipt of the Certification. Unless such demands are made, this Certification shall be final and
binding.
This the 31st of August 1999
DIVISION OF WATER QUALITY
98tev?ens'
WQC # 3241

F
f<
March 23, 2000 1 °
? I ,. ,l t?f q a
Mr. Dave Lekson? 7 20? b 99' j
U.S. Army Corps of Engineers
Washington Regulatory Field Office
107 Union Drive, Suite 202
Washington, NC 27889 T,'! ?ECT?ON
RE: Action ID No. 199811324
Nucor Steel
Wetland Mitigation Plan - Littoral Shelves
Dear Mr. Lekson,
Enclosed you will find a drawing titled Nucor Steel - Hertford County, Stormwater
Management Plan, dated March 2, 2000. The final drawing plans for stormwater ponds Al, B1,
and C 1 calculated a littoral shelf size of 2.18. The approved mitigation plan (Revised Mitigation
Plan, November 8,1999) states that 2.43 acres of littoral shelves will be created around
stormwater ponds Al, B1, and Cl. To make up the additional required littoral shelf acreage,
Nucor will incorporate stormwater pond A3 into the approved mitigation plan. The littoral shelf
on pond A3 is approximately 0.51 acres. The new total acreage of littoral shelves around the four
stormwater ponds is approximately 2.68, which is greater than the original approved plan of 2.43
acres of littoral shelves. The littoral shelf on pond A3 will be constructed, planted, and monitored
the same as the other stormwater ponds already specified in the Revised Mitigation Plan, Dated
November 8, 1999.
Please do not hesitate to call me at [phone] if you have any questions regarding
the submitted information.
Sincerely,
R. Clement Riddle
Project Biologist
cc: John Dorney, NCDWQ Permit No.990231
Deborah Sawyer
David Moye, CAMA Permit No. 79-99
Chad Prior
NEWKIRK
ENVIRONMENTAL, INC

Enclosures:
Savannah, GA Office
340 Eisenhower Drive
Building 200, Suite 201
Savannah, GA 31406
[phone]
Facsimile: [phone]
E-Mail: [e-mail]
Charleston, SC Office
192 East Bay Street
Suite 201
Charleston, SC 29401
[phone]
Facsimile: [phone]
E-Mail: [e-mail]
Hendersonville, NC Office
300 N. Main Street, Suite 205
Post Office Box 2876
Hendersonville, NC 28793
[phone]
Facsimile: [phone]
E-Mail: [e-mail]
1
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gOjOaj\
0
Revised Compensatory Wetlands Mitigation Plan "
for
The Nucor Steel Plate Recycling Mill - Hertford County
July 21, 1999
AHE TRIANGLE GROUP
NEWKIRK
ENVIRONMENTAL, INC

1

11
1
Revised Compensatory Wetlands Mitigation Plan
for
The Nucor Steel Plate Recycling Mill - Hertford County
July 21, 1999

Prepared For:
NUCOR STEEL - HERTFORD COUNTY
1
I t

Prepared By:
The Triangle Group
Post Office Box 33604
Raleigh, North Carolina 27636
[phone]
Attention: Russ Lea, Ph.D.
Newkirk Environmental, Inc.
192 East Bay Street, Suite 201
Charleston, South Carolina 29401
[phone]
Attention: Stephen A. Nichols
t
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TABLE OF CONTENTS
1.0 INTRODUCTION ...................................................... 1
2.0 AVOIDANCE AND MINIMIZATION .................................... . 2
3.0 IMPACTED WETLANDS .............................................. . 3
4.0 COMPENSATORY MITIGATION ...................................... . 4
4.1 Mitigation Goals and Target Functions ................................ . 5
4.2 On-Site Creation ................................................. . 5
4.2.1 Implementation and Methodology .............................. . 8
4.2.1.1 Excavation and Site Preparation ........................ . 8
4.2.1.2 Hydrologic Input .................................... . 9
4.2.1.3 Vegetative Planting .................................. 10
4.2.1.4 As-Built Report ..................................... 11
4.2.2 Monitoring ................................................ 11
4.2.2.1 Vegetative Monitoring ................................ 12
4.2.2.2 Hydrologic Monitoring ............................... 13
4.2.3 Probability of Success ....................................... 14
4.2.4 Success Criteria ............................................ 14
4.2.5 Contingency ....... ......................................... 14
4.2.6 Timing and Schedule ........................................ 15
4.3 Preservation of Off-Site Acreage ..................................... 15'
5.0 ADDITIONAL ON-SITE MITIGATION
5.1 On-Site Preservation .............................................. 17
5.2 Enhancement and Bioengineering of Stormwater Ponds ................... 18
5.2.1 Establishment of Vegetation within Shelves ...................... 19
5.2.2 Vegetation Maintenance ..................................... 20
FIGURES
Figure 1 Site Plan
Figure 2 & 2a Location Map and Orthophotograph for Preservation Area
Figure 3 & 3a Wetland Creation Site
Figure 4 Wetland Creation Site Cross Section
Figure 5 Diffuser Pipe Detail
Figure 6 Littoral Shelf Cross Section
APPPENDICES
A Impacted Wetland Characteristics
B Evaluation of Mitigation Sites
C Compensatory Hardwood Mitigation Guidelines
D Photograph of Preservation Site and Reference Plots
E Soil Survey - Hertford County, NC
F Stormwater Permit Application Calculations
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Nucor Steel - Hertford County
Revised Compensatory Mitigation Plan
July 21, 1999
1.0 INTRODUCTION
This revised mitigation plan describes the compensatory measures for unavoidable impacts to 2.32-
acres' of freshwater wetlands and Waters of the United States associated with development of the
Nucor Steel - Plate Recycling Mill, Hertford County. The mill facility is located on approximately
900 acres of land adjacent to the western shore of the Chowan River, approximately 8 miles east of
Winton, North Carolina. The applicant, Nucor Steel, has applied to the US Army Corps of
Engineers for the necessary permits to excavate and fill the identified jurisdictional waters. The
following revised mitigation plan is provided in support of the permit application and is in response
to agency comments, including those provided by the U.S. Army Corps of Engineers in a February
24, 1999 letter. Major revisions to the original compensatory mitigation plan have been made in
response to agency comments and based on additional information obtained by Nucor's
environmental consultants (Newkirk Environmental, Inc. and The Triangle Group). Nucor will also
purchase and preserve approximately 150-acres of off site high quality riparian wetlands along the
Chowan River. In addition to the compensatory mitigation, which achieves no-net-loss, the
stormwater management ponds will be enhanced through construction of 2.43 acres of vegetated
littoral shelves. Finally, as previously documented, higher value wetlands located within the mill site
will be preserved and protected with an upland buffer zone.
Nucor has committed to 0.41 acres of additional avoidance and minimization resulting in a 15% further
reduction in wetland impacts.
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This plan successfully meets the mitigation needs of the project. The design of this plan provides
compensatory mitigation substantially in excess of the "no-net loss" policy. Nucor and its
environmental consultants are confident of its feasibility and success.
2.0 AVOIDANCE AND MINIMIZATION
Nucor Steel has made every reasonable and practicable effort to avoid and minimize impacts to
jurisdictional wetlands and waters while still attaining project goals and construction requirements.
A comprehensive alternatives analysis, which details the site selection process, previously was
completed by DeLaney and Sellers, P.A. Additional support was submitted May 28, 1999, as a
supplement entitled "Nucor Steel'Hertford County - Plate Mill' Wetland Avoidance/Minimization".
In response to comments, each proposed impact has been reviewed and re-evaluated to ensure that
appropriate avoidance and minimization measures have been taken.
The additional avoidance and minimization is being accomplished by complete elimination of
stormwater pond B3 and re-routing the haul road to the port. The wetlands which were to be
impacted by pond B3 and the haul road have been identified by Nucor's consultants as having higher
values and functions of branch bottoms than the remaining drainage ways to be impacted. Avoiding
and preserving these areas will limit remaining impacts to the upper reaches of the drainage channels
where wetland values and functions are generally lower. Stormwater volumes lost by the elimination
of stormwater pond B3 will be replaced by resizing ponds B 1 and Al. The location of the haul road
will be shifted to the west and designed to cross the wetland at an existing crossing. New culverts
will be installed at the existing crossing and the road will be stabilized to handle expected vehicle
weights and stormwater flows.
Comprehensive wetland delineations (Figure 1, revised site plan) identified a total of 19.49 acres of
wetlands and Waters of the United States. Of this total, approximately 10% (2.32 acres) are now
proposed to be impacted by construction of the mill and necessary support structures or features.
The remaining 17.17 acres of wetlands will be preserved. The majority of the on-site wetlands,
consisting of 14.67 acres, will not only be preserved. Nucor has continued to make every effort to
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avoid and minimize wetland impacts, including the recent elimination of impacts associated with
stormwater pond B3 and the haul road to the port. Elimination of these impacts, a total of 0.41 acres,
reduces the total impact to 2.32 acres (1.71 acres to the site proper and 0.61 acres to the adjoining
utility corridor), an additional 15% decrease (Figure 1).
3.0 IMPACTED WETLANDS
Impacts within the Nucor Tract (excluding the utility corridor) are confined to the upper limits of
three linear drainages, which have been identified as jurisdictional "Waters of the United States".
Each of these drainages ultimately transition into narrow forested branch bottom wetlands associated
with, and draining to, the Chowan River. After review of the difference between the upper and lower
reaches of these drainages, Nucor has made several revisions to site plans to avoid impacts to the
lower reaches of these drainages where values and functions are generally greater. A majority of the
proposed impacts to the upper reaches of these systems are directly related to the construction of
stormwater detention ponds.
Newkirk Environmental, Inc. and The Triangle Group have analyzed impacts to jurisdictional
wetlands/waters associated with construction of stormwater ponds. These reports are attached in
Appendix A. The portions of the drainages proposed to be impacted are virtually devoid of
vegetation and are characterized as temporarily flooded wet weather gullies or drainage ways.
Following rainfall events, runoff from adjacent land is collected in the gullies, temporarily inundates
the sites, and is carried to the lower elevations and eventually to the Chowan River. During dry
periods, the gullies may maintain minimal levels of saturation until collected water has been
transferred or evaporated. It is not uncommon for the sites to be completely dry for extended
periods. As a result of natural erosion that occurs within the bottom of the gullies, very little organic
material is present or able to accumulate. Both environmental consultants concluded that the narrow
intermittent drainage ways to be impacted serve limited wetland functions, and serve primarily to
transport surface water. Both Newkirk Environmental, Inc. and The Triangle Group have concluded
that the stormwater ponds with vegetated littoral shelves should provide comparable or better
nutrient and pollutant removal functions than the natural drainage channels they replace. In
addition, the stormwater ponds will serve the functions of erosion and sediment control by allowing
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surface waters to collect and to settle out sediments prior to the release of stormwater. The use of
vegetated littoral shelves around the stormwater ponds will provide additional sediment and pollutant
filtering and removal, and may provide additional habitat for waterfowl and wildlife. Finally, the
stormwater ponds will be designed to gradually provide surface water hydrology (post storm event)
for the branch bottom wetlands located down gradient.
Temporary impacts to wetlands are associated with installation of electric power and natural gas
within the designated utility corridor. Upon completion of construction activities wetland
topography will be restored to original contour elevations and seeded with hydrophytic herbaceous
vegetation. Wooden mats and other BMP=s will be used to aid in utility installation within the
utility corridor wetlands.
4.0 COMPENSATORY MITIGATION
During the planning and permitting process, Nucor has expended great effort to identify suitable and
appropriate mitigation sites. This process has included reviewing potential creation, restoration,
enhancement and preservation opportunities, both on-site and off-site. Nucor and its consultants
have received considerable input from the USACE, other federal agencies, public comments, and
state agencies. In response to expressed preferences for off-site restoration, Nucor and its
consultants conducted extensive searches for off-site restoration opportunities in Hertford, Gates,
Bertie, and Chowan Counties and have determined that suitable off-site mitigation opportunities are
unavailable or not practicable (Appendix B). Based on this research, Nucor has revised its
mitigation plan to provide compensatory mitigation for unavoidable impacts to the identified
wetlands as follows:
1) On-site creation of seven acres of freshwater bottomland
hardwood wetlands; and
2) Off-site preservation of approximately 150-acres of forested
riparian wetlands approximately 10 miles downstream on
Chowan River (Figure 2)
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4.1 Mitigation Goals and Target Functions
The goal of the proposed mitigation is to offset impacts to on site wetlands by replacing lost
functions and values with equal or higher wetland functions and values. The primary target
functions to be replaced are the loss of stormwater storage and filtration capacities,
stormwater transfer, and habitat resources. The creation of the proposed wetland area will
more than compensate for the stormwater storage and filtration functions that will be
impacted. The preservation of high value forested wetlands will ensure stabilization of
valuable habitat in an undisturbed state.
4.2 On-site Creation
The applicant proposes to construct seven acres of forested wetlands adjacent to an existing
on-site wetland that is proposed to be protected (Figures 3 and 3a). Construction of this
wetland will follow the Corps of Engineers - Wilmington District Compensatory Hardwood
Mitigation Guidelines (Appendix Q. Upon completion, the created wetland and a 100 foot
upland buffer will be preserved. Specifics of the planned creation project are outlined below.

US Army Corps of Engineers mitigation recommendations request that impacted wetlands be
mitigated at a 3:1 ratio. Using the total impact of 2.32 acres, the required mitigation for the
project to meet Corps requirements is 6.96 acres. State mitigation requirements are based
upon distances from major surface water tributaries. Noting that most of the proposed
impacts fall within the lower bracket of the state requirements, the 3:1 Corps ratio will
exceed the State requirements. Once stabilized, the created wetland should compensate for
lost functions associated with the natural drainages and wetlands proposed to be impacted.
r Ultimately, the created forested wetland will provide similar hydrologic functions to those of
the impacted wetlands (water transfer) and will likely provide higher vegetative, habitat
resources, and stormwater desynchronization values than the upper reaches of several of the
impacted areas.
The proposed creation site is located along the southern property boundary adjacent to
i
"
"
"
"
is a small topographically depressed dra
nage
(Figure 3). Wetland
W/X
W/X
wetland
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that originates approximately 200 feet from Bazemore Road. The small portion of wetland
"W/X" that is present within the Nucor Tract is a portion of a larger tributary that drains in a
southwesterly direction to Brooks Creek. Bazemore Road bisects the wetland; an eighteen
inch culvert maintains the hydrologic flow. The natural wetland is hydrologically supported
by both ground water and surface runoff from adjacent highland. A shallow swale that runs
from the upper (northern) end of the wetland through the forested uplands in a northeasterly
direction collects runoff and carries water to lower elevations.
On June 24, 1999, Newkirk Environmental, Inc. completed plot surveys of the natural
wetland to document existing conditions and establish reference data for comparison with the
creation area. This was completed by establishing random 30 foot diameter plots at three
locations within the wetland system: 1) within the center of the on-site portion of wetland
"W/X", 2) adjacent to the road at the intersection of Brooks Creek and Bazemore Rd. and 3)
adjacent to the road at the intersection of Brooks Creek and Wiccacon Rd. At each location,
vegetative species within the plot were identified and documented in a species list. The
following species were identified as occurring most commonly or as dominants:
Table 1.
TREES SAPLINGS/SHRUBS HERBACEOUS
Red Maple (Acer Rubrum) Sweet gum Royal Fern (Osmunda regalis)
Blackgum (Nyssa sylvatica) Red Maple Sphagnum moss (Sphagnum spp.)
Laurel Oak (Quercus Laurifolia) Red Bay (Persea borbonia)
' Cinnamon Fern (Osmunda
cinnamonea)
Cypress (Taxodium distichum) Blackgum Netted Chain Fem (Woodwardia
aerolata)
Loblolly Pine (Pinus taeda) Water Oak (Quercus nigra)
Sweet gum (Liquidambar
styracif lua)
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Representative photographs of the reference site are included in Appendix D. As the
wetlands to be impacted have been noted as-being generally void of vegetation, the
species list compiled from the reference plots will serve to establish a planting list.
Additional data and observations collected during plot surveys of the natural wetland
"W/X" include soil characteristics and inundation/saturation indicators. Soil samples
match the description of Bibb soil, which is listed as hydric in Hertford County.
Excavated soil pits found the ground water table approximately 2-3 inches below the
surface. Regional indicators of soil saturation, including oxidized rhizospheres, were
common. Buttressed and multiple trunks are also present. Indications that the natural
wetland is subject to periodic levels of inundation include matted leaf litter and water
marks at approximately 3 inches above the surface.
Nucor proposes to convert approximately seven acres (6.96-acres) of upland adjacent to
wetland "W/X" to a similar wetland system (Figures 3 and 3a). The area proposed to be
used for the creation site has been verified as uplands in the site wetland delineation
previously approved by the USACE. This adjacent upland is approximately 1.5 to 2.0
feet higher in elevation than wetland "W/X" and is typical of the upland areas found on
the Nucor Tract. Vegetatively the proposed site is dominated by red maple, tulip poplar
(Liriodendron tulipifera), laurel oak and loblolly pine (Pinus taeda). Soils on the site
match the description of Leaf series (Appendix E).

The particular area is proposed because, unlike other areas of the site, the site maintains a
?- relatively constant elevation, which is close to the elevation of the adjacent wetland.
Other wetlands, both on site and on adjacent lands, are typically located in much lower,
steeply topographic draws. The difference in elevation at these other sites would make
excavation and successful creation activities difficult to achieve.
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4.2.1 Implementation and Methodology
The applicant proposes a five-step approach to complete creation of the
designated wetland site.
1. Data collection from reference points.
2. Excavation and site preparation
3. Design and installation of water budget
4. Vegetative planting
5. Hydrologic and vegetative monitoring to establish success criteria.
A portion of the first of these tasks has been completed with the plot surveys of
wetland "W/X" prepared by Newkirk Environmental, Inc on June 24, 1999.
4.2.1.1 Excavation and Site Preparation
Upon approval, the applicant will promptly survey and mark in the field
the location of seven acres of upland immediately adjacent to wetland
"W/X" to be used as the creation area and associated buffers. The general
location of the creation site has been identified (Figures 3 and 3a). The
final site boundaries will be field located based upon soils, elevation and
vegetation impacts. Once located, the creation site will be prepared by
grading using Best Management Practices to prevent unwanted erosion
during and after grading activities. This will include the stabilization of
the transition area between the created wetland and the adjacent upland
1
areas using a not less than 3:1 vegetated slope.
Prior to excavation, spot elevations within wetland "W/X" will be taken to
determine the appropriate finish elevation of the creation area. It is
anticipated that the creation area will be nearly level with only enough
change in elevation to permit the natural sheet flow of water.
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ill b
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d b
f h
hi
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i
Excavate
mater
a
w
e remove
y means o
eavy mac
nery an
trucks and stock piled or moved to an appropriate upland site. Existing
soils will be removed to an elevation approximately 6 inches below the
desired finished elevation (Figure 4). Following excavation, the site will
be backfilled with 6 inches of suitable wetland top soil or peat (800 cubic
yards/acre). Following backfilling, the site will be leveled and elevations
are spot checked and documented. As part of the excavation, a smooth
transition from the creation area to the natural wetland will be established.
In areas where the identified wetland boundary is slightly higher than the
desired finish elevation, a minimal amount of grading at the wetland
boundary will be completed to prevent the creation of a "hump" between
the two areas.
4.2.1.2 Hydrologic Input
Existing wetland "W/V is supported by ground water and surface water
runoff. By setting the finished elevation of the creation area to the same
level as the natural wetland, natural ground water elevations, which
influence the existing wetland, should occur in the creation area. The Leaf
soils identified within the creation area are characterized as poorly drained
with slow permeability. The high water table for both the Leaf and Bibb
series are similar and are noted as being 0.5-1.5 feet below the surface for
five months. Additional sources of water to the site will come from
stormwater runoff from: (I) the newly constructed public road diverted by
ond (C1) which will be
ed sto
mwater
ide
l
ii) f
d
rom a propos
r
p
swa
es, (
roa
s
constructed immediately to the north of the creation site, and (iii) from
natural stormwater runoff from adjacent undisturbed areas.
Stormwater pond C 1 is designed to collect water from approximately
86.78 acres of land, including 39.72 acres of impervious surface, with a
capacity of 738,882 to 1,291,418 cubic feet. The outlet of this pond will
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be constructed to discharge into the creation area. Using calculations from
the "Stormwater Management Permit Application" (Appendix F),
discharges into the creation area will total 0.43 cfs during and following a
1 inch storm and will increase with larger rain events. The discharge of
treated water will be directed into the created wetland by means of a
diffuser pipe or structure that will evenly spread the water over the
northern end of the creation area (Figure 5). Once in the created wetland,
the discharged water will follow the ground contours through the creation
area and continue through the existing pipe at Bazemore Road.

4.2.1.3 Vegetative Planting
Using the species list compiled during plot surveys of the existing
wetland, a planting list of at least six species will be determined. Specific
species to be planted will be determined based upon availability and
condition of plant material, but will include at least six of the following:

Laurel Oak (Quercus laurifolia)
Tupelo (Nyssa biflora)
Cypress (Taxodium distichum)
Red bay (Persea borbonia)
Water Oak (Quercus nigra)
Green Ash (Fraxinus pennsylvanica)
Swamp Chestnut Oak (Quercus michauxii)
Willow Oak (Quercus phellos)
Bareroot seedling stock will be obtained from a qualified nursery in a
similar region. Individual seedlings will be manually dibbled on 6 X 10
foot spacing (726 trees per acre). Species mixing/distribution will be
planned at the nursery prior to planting. No single species will account for
more than 20% of the total. Planting will occur during the dormant season
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(December - March) to reduce shock and promote survival rates. With
each planted seedling, a fertilizer pack will be included during planting.
Shrub and herbaceous species are not proposed to be planted to reduce
immediate competition to the planted hardwoods. Adjacent seed sources
and the addition of peat or top soil should naturally encourage and support
the establishment of indigenous shrubs and herbs.
At the time of planting, each planted seedling within an established
monitoring plot (see section 4.2.2.1) will be marked and the total within
each plot documented for use in determination of survival rates and
attainment of success criteria.
4.2.1.4 As-Built Report
Within 30 days of the completion of planting, the applicant will submit to
the appropriate agencies an As Built Report to document completion of the
work. This report will include exhibits of the site location, final site
elevations and grades, well locations, sample plot locations and planting
design. If any problems or deviations from the original plans are
necessary, these will be fully documented and explained.
4.2.2 Monitoring
Monitoring of the creation site will be completed on a annually scheduled basis
to document attainment of success criteria. Monitoring will occur at the end of
the growing season (August - September) each year. Monitoring will include
both vegetative and hydrologic measures that will be compared with reference
data and designated success criteria. Collected data and photographic
documentation of plot succession and conditions will be compiled in an Annual
Report to be submitted to the appropriate agencies following each scheduled
monitoring. Photographic documentation will be provided by taking a
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photograph of each plot center and two additional photographs of each plot
facing north and south.
4.2.2.1 Vegetative Monitoring
The applicant will monitor the creation site to document survival of
planted trees and regeneration of volunteer species six times over a five
year period. Baseline monitoring and As-Built Summaries will be
submitted immediately following planting. Annual monitoring will occur
annually thereafter for a period of five years. Vegetative monitoring will
be conducted in accordance with the Comprehensive Wetland
Determination Methodologies as described in the US Army Corps of
Engineers Wetland Delineation Manual (1987).
Vegetative monitoring will be accomplished by establishing parallel line
transects within the creation area. Randomly set permanent plots
(minimum of seven) will be established at the time of planting on
approximately 300 foot intervals along the transects. The center of each
plot will be permanently marked using ten foot high stakes appropriately
labeled and marked for future identification. Within each plot, stem
survival of planted and volunteer tree species will be documented in a 30
foot diameter area. Volunteer shrubs and herbaceous species will be
documented in ten (10) and five (5) foot diameter areas, respectively.
Baseline monitoring will be completed within each plot at the time of
planting so that all planted seedlings may be identified and marked for
future surveys.
Species composition and dominance will be measured within each plot.
All stems will be identified to at least the genus level and the number of
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stems recorded for each. For the purpose of measuring against the success
criteria, survival of planted seedlings will be expressed in terms of the
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calculated number of live stems per acre. Volunteer species will be
expressed in terms of number of stems per acre and coverage.
4.2.2.2 Hydrologic Monitoring
Hydrologic monitoring of the creation area will be completed by recording
and documenting groundwater and surface water elevations. Recorded
levels within the creation area will be compared with levels in the adjacent
natural wetland "W/X" to establish that similar hydrologic conditions exist
between the sites and/or that wetland hydrology criteria is met.
Three automated wells will be installed on the site following construction
of the creation area. Two wells will be located in the creation area and a
single well will be placed in the existing adjacent wetland. Wells will be
installed immediately following completion of grading and planting
according to the manufacturer's specifications and instructions. Two
readings per day will be recorded for one month prior to the beginning of
the growing season and continue for a minimum of two months into each
growing season of the five year monitoring program. At the end of the
three month period, collected data will be analyzed and compared with
success criteria. If wetland hydrology has not been documented in the
creation area, additional well readings will occur through the end of the
growing season.
Recorded hydrology data will be supported by photographic
documentation of saturation and/or inundation. This documentation will
be made by taking a photograph of each plot center and two additional
,r photographs of each plot facing north and south.
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1 4.2.3 Probability of Success
The proposed plan has been written and reviewed by both Newkirk
Environmental, Inc. and The Triangle Group. Both consultants have surveyed
the proposed site and believe the proposed creation site will be successful and
will adequately compensate for the wetland functions that will be impacted by
construction of the project.
4.2.4 Success Criteria
Success criteria for the vegetative and hydrologic components of the creation
area will be determined using the reference sites and the following criteria. For
vegetation, the goal of the mitigation is to create a wetland ecosystem with
comparable species composition and diversity to the existing wetland "W/X".
Considering this, the site will be considered successful and the monitoring
complete if, at the end of the five year monitoring program, the survival rate of
planted and volunteer tree species is at least 320 planted and volunteer trees per
acre. (Acceptable volunteer species will be defined as indigenous species,
excluding those in the genus Pinus).

Hydrologic success will be determined by documenting that water levels within
the creation area are similar to the existing wetland "W/X", or that wetland
hydrology criteria, as defined by the US Army Corps of Engineers 1987 Manual,
is present. As such, success criteria will be determined by the establishment of
wetland hydrology for 12.5% of the growing season, or the establishment of a
hydro period at least as great as that of the reference well within the existing
wetland "W/X".
4.2.5 Contingency
criteria have not been met for
it
i
h
d
f
ng program, success
e mon
or
o
t
If, at the en
either the vegetative or hydrologic components, the applicant will consult with
encies
deral a
t
t
d f
t
h
i
d
i
g
a
e an
e
er appropr
a
e s
neers an
ot
the US Army Corps of Eng
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to determine specific causes and appropriate remedial actions. Review of
specific causes resulting in success criteria deficiencies may include: hydrologic
influences, plant mortality, vandalism, animal depredation, or invasion of
I nuisance plants.
If significant problems are identified prior to the end of the monitoring program,
USACE regulatory agency personnel will be consulted regarding the advisability
of remedial action at that time. Remedial action may include replanting,
additional grading and continued monitoring. It is the intent of the applicant to
obtain the success criteria, however the applicant cannot be responsible for acts
of god or natural disasters, which may undermine or preclude success. In the
event of such acts or disasters, Nucor will immediately coordinate with the
appropriate state and federal agencies.

4.2.6 Timing and Schedule
Implementation of the mitigation plan for the creation site will occur as soon
after issuance of the necessary permits and at a schedule based upon the growing
season, which will promote the greatest success rates. Excavation and grading
activities will occur at the end of the first growing season following issuance of
the necessary permits. This will minimize establishment of competitive
vegetation prior to planting the desired seedlings. Planting of seedlings will then
occur during the dormant season immediately following excavation activities.
Monitoring will then follow the schedule in section 4.2.2.

4.3 Preservation of Off-Site Acreage
As a further compensatory mitigation measure, Nucor has elected to preserve 150 acres of
high quality bottomland hardwood riparian forest adjacent to the Chowan River (Figure 2
& 2A). The proposed preservation site is similar in composition to the riparian wetlands
in and near the Nucor site. In an undisturbed and protected state, the preservation of this
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I riparian buffer area will maintain the values and functions of the protected site and
I continue to enhance the adjacent Chowan River system.
The 150-acre site is currently owned by Mr. Jimmy Early and Ms. Ann Stevens. Nucor
obtained a signed agreement on July 14, 1999 to purchase this land.
s of the 150-acre
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1999
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,
riparian wetland to document existing conditions (Appendix D). This was completed by
t th
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30 f
t di
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hi
d
d
bli
ree
oca
ons
oo
ame
er p
o
s a
ng ran
om
esta
s
cruising the shore line an
along the river's edge and a fourth plot in the northern corner of the site accessed from
ifi
d
d
l
id
ent
e
ot were
an
high ground: At each location, all vegetative species within the p
documented in a species list. The following species were identified as occurring most
commonly or as dominants:

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TREES SAPLINGS/SHRUBS HERBACEOUS

Cypress (Taxodium
distichum) Tupelo Netted Chain Fern
(Woodwardia aerolata)
Red Maple (Ater Rubrum) Sweet gum Royal Fern (Osmunda regalis)
Black gum (Nyssa sylvatica) Red Maple Sphagnum moss (Sphagnum
spp•)
Tupelo (Nyssa sylvatica var.
Mora) Red Bay (Persea borbonia) Short-bristle Beakrush
(Rhynchospora corniculata)
Water Oak (Quercus nigra) American holly (Ilex opaca) Giant cane (Arundinaria
gigantea)
Sweet gum (Liquidambar Wax myrtle (Myrica cerifera) Arrow arum (Peltandra
styraciflua) vir inica
Green Ash (Fraxinus Water Oak Lizard's tail (Saururus cernuus)
pennsylvanica)
L Coast pepper-bush (Clethra
alnifolia) False-nettle (Boehmeria
cylindrical
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Additional data and observations collected during plot surveys of the site included soil
characteristics and inundation/saturation indicators. Soil samples match the description of
Dorovan soil, black peaty muck (0-24 inches +), which is listed as hydric in Hertford
County. Soils are saturated to the surface. Regional indicators of soil saturation,
including oxidized rhizospheres, and sulfidic odor are common. Additionally, buttressed
and multiple trunks are also present. Indications that the natural wetland is subject to
periodic levels of flooding include matted leaf litter and water marks at approximately 12
inches above the surface.
As documented in the enclosed photographs, at least four Osprey nests are present within
the site.
Under this plan, Nucor will place this property under a Conservation Easement or
protective covenants, which will be subject to approval of the US Army Corps of
Engineers and will be implemented promptly after issuance of the 404/401/CAMA/
Section 10 permits.
5.0 ADDITIONAL ON-SITE MITIGATION
In addition to the compensatory mitigation described above, the applicant intends to provide
additional enhancement to on-site wetlands and stormwater ponds through buffers and
bioengineering.
5.1 On-Site Preservation
As additional voluntary mitigation, 14.67 acres of on-site wetlands will be left
undisturbed. The wetlands to remain have been identified by Newkirk Environmental,
Inc. and The Triangle Group as being those wetlands with the highest functions and
values. Nucor will protect these remaining wetlands with associated 100 foot buffers
where feasible.
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5.2 Enhancement and Bioengineering of Stormwater Ponds
Nucor proposes enhancement and bioengineering of on-site stormwater ponds to
maximize stormwater buffering and purification and stabilize water flows to downstream
wetland areas.
Nucor's wet detention ponds are designed to provide water quality benefits to downstream
wetlands and waters. They are over-designed in terms of stormwater retention and are
configured to provide significant removal of suspended solids, nutrients, and pollutants.
They will maintain a permanent pool of water designed for a target sediment removal rate
at or above 90% for ponds Al, B1, and Cl. The ponds will hold runoff that results from a
10-year 24-hour period rainfall event and release this water over a period of several days.
As a further public interest review mitigation measure (i.e., not as part of formal 404(b)(1)
mitigation), Nucor has elected to design a littoral shelf around the perimeter of these
ponds, set at a 6:1 slope, starting at the permanent pool elevation and continuing two feet
below water level (Figure 6). These designs should result in a stormwater pond system
where most suspended solids, nutrients and pollutants attached to sediment are allowed to
settle out of the water, and should release water at a rate such that downstream erosion is
lessened or eliminated.
The presence of perimeter shelves will allow for the establishment of vegetative areas that
provide enhanced pollutant removal, wildlife and waterfowl habitat and protect the
shoreline from potential erosion. As part of this elective public interest mitigation
measure, Nucor will vegetate the shelves of ponds A1, B1 and C1. Establishment of a
stable vegetative community will have a direct relation to replacing lost filtration values
and functions within impacted drainage ways. The shelf areas proposed to be planted are:
Pond Al 1.13 acres
Pond B 1 0.79 acres
Pond C 1 0.51 acres
TOTAL 2.43 acres
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There are many benefits of wet detention ponds over other stormwater measures. For
example, dry detention basins are less efficient in removing suspended solids and other
pollutants (US EPA, 1983;Metropolitan Washington COG, 1983) and hold little aesthetic
value (Maryland DNR, 1986). Wet detention ponds are also appropriate in areas where
infiltration is impractical due to low infiltration rates of the underlying soils. In addition
to water quality benefits, wet detention ponds can reduce the peak runoff rate from the
developed site and better control downstream erosion (Stormwater Best Management
Practices, NC DENR, Division of Water Quality, Water Quality Section, reprinted July
1998). The ponds are a requirement under the stormwater management plan and may
require periodic maintenance to meet stormwater plan requirements. Therefore, the
proposed shelves will not be tied to any restrictive covenants. Finally, wet detention
ponds can serve as a water source to reduce the potential for desiccation of downstream
wetland areas.
5.2.1 Establishment of Vegetation within Shelves
Following the construction of each of the three wet detention ponds, the
applicant proposes to vegetate each of the shelves with indigenous
aquatic/wetland herbaceous species. Under the stormwater management plan,
much of the area within these shelves should be inundated for extended periods,
if not permanently. Based upon these conditions, the following species are
proposed to be planted:
Pickerelweed (Pontederia cordata)
Soft rush (Juncus effusus)
Arrow Arum (Peltandra virginica)
Lizard's tail (Saururus cernuus)
Individual plants of these species will be manually planted in the shelf areas on
18" spacing. Fertilizer packs may be used to enhance plant growth. Species will
19
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be planted according to acknowledged water tolerances and anticipated water
levels on each shelf.
5.2.2 Vegetation Maintenance
The goal of vegetative shelves is to provide a vegetative community that will
enhance wildlife habitat and improve pollutant reduction through uptake of
nutrients by the vegetation. Successful accomplishment of the planting goals
will be determined by the establishment of vegetative shelves that have 75%
aerial coverage within the three ponds. Establishment of a vegetative community
within the shelf areas will be documented through a voluntary monitoring
program. Monitoring is proposed to occur six months following planting and at
the end of the next full growing season.
Twice during the first year after planting, random plots will be established at 300
foot intervals along the perimeter of each pond and shelf area. Within each plot,
species composition and density will be documented within a 3 foot radius of the
plot center. Each species present will be identified at least to the genus.
Estimates regarding the percent coverage of each species and of the total plot
coverage will also be made. Collected data, including photographs of the plot
centers and to the north and south, will be compiled and included in the annual
Compensatory Monitoring Reports to be submitted to the appropriate agencies.
Nucor Steel will strive to maintain the vegetative shelves for as long as the
stormwater ponds are in active use. If, at any time during the active use of the
ponds it is necessary to perform maintenance activities or expansion in the
ponds, any vegetated shelves that are temporarily impacted will be re-vegetated
according to the original planting plans, subject to state agency stormwater
approvals.
20

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Figure 2
Location Map
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Appendix A
Impacted Wetland Characterizations

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A Description of Impacted Drainage-ways
and
Functional Wetland Features of Stormwater Ponds
on the
Nucor - Hertford County Plate Steel Mill Site
By Russ Lea, Ph.D.
Drainage-way Description
Wetland impacts within the Nucor industrial site are confined to the upper limits of
three riparian drainage-ways that have been identified as jurisdictional wetlands. These
drainage-ways are found in the uppermost landscape position and feed directly into well
defined branch bottom wetlands at lower elevations. These drainage-ways function as
intermittent tributaries and serve more as upland connections to the branch bottom wetlands
and downstream aquatic habitats. They are not high performing wetlands that provide
values, such as, flood desynchronization, organic matter accumulation, sedimentation
accumulation, groundwater recharge and denitrification, because they lack the general
features of alluvial forested wetlands possessing backwater drainage channels, floodplains,
anaerobic soils and discrete water bodies.
Productive riparian-wetland complexes evolve in response to dynamic interactions
between the channel and the floodplain. Since these drainage-ways are longitudinal wetlands
at the upper end of the watershed, they possess little or no floodplain. Although riparian
wetlands are generally regarded as among the most productive ecosystems, Brown (1981)
indicates that high productivity characterizes only those riparian systems that have prolonged
lateral hydrological interaction with a floodplain. The sloping topography of the drainage-
ways on the Nucor site cannot support prolonged wetland hydrology on a lateral floodplain
and therefore function primarily as discharge channels that convey water only when rainfall
exceeds the capacity of the soil infiltration. Odum (1979) recognized the most productive
riparian wetlands are those that do not undergo abrasive flooding within sloping topography
but are those subject to annual flooding from lateral water movement on nearly horizontal
floodplains. Welcomme (1976) also demonstrated a strong positive correlation between
floodplain area and productivity of riparian areas.
Not only do the hydrological conditions markedly influence structural and functional
attributes of riparian wetlands, but the wetlands themselves regulate the hydrology (Conner
and Day, 1982). Since the delineated wetlands of the Nucor drainage-ways are mostly the
channel proper, then it is obvious that flooding occurs across upland habitats rather than on
wetlands. Since the topography is too incised to support floodplains adjacent to the drainage-
ways, there are no natural levees formed to impede the movement of surface waters back to

1
the river (e.g. nominal flood storage). Groundwater aquifers are not recharged during
flooding events because of the lack of adjacent wetlands, and water conveys quickly into
branch bottom wetlands via the surface water drainage-ways. The lack of lateral movement
of water onto adjacent wetlands means that there are no still water areas to structure the
habitat or the trophic conditions found in most other riparian wetland systems. Floodborne
sediments and nutrients released in floodwaters cannot inundate the soils at a frequency to
support primary wetland functions as a nutrient "sink." One of the most significant intrinsic
values of riparian wetlands is their tight nutrient cycles because nutrients are adsorbed on the
floodborne sediment particles and deposited on adjacent floodplains (Brinson, 1977;
Wharton et al., 1982; van der Valk et al., 1979; Furtado and Verghese, 1981). The Nucor
drainage-ways are also well-oxygenated, and their topography is such that anaerobic
' conditions do not develop upon inundation - significantly limiting denitrification processes
and nutrient transformation (Etherington 1983).
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Since the delineated wetlands on the Nucor site are generally confined to drainage-
ways and have limited wetland vegetation flooded by adjacent waterways, one has to wonder
if some of the key wetland habitat functions are supported. The richness of wetland habitat is
often a virtue of the hydrologic regime and diverse plant communities that provide shelter,
cover, food sources, and breeding areas. The drainage-ways are not flooded for any
significant length of time and do not have diversified plant communities that commonly
support the larval stages of fish, aquatic insects, and amphibians characteristic of fully
diversified wetland habitats.
In summary, the three "core factors" -hydrologic energy, hydroperiod, and nutrient
supply-which are fundamental for distinguishing the value of a wetland,(Lugo et al. 1988),
are not at the optimum levels to support high value wetlands at the Nucor site. In considering
a site-specific impact, it is easy to overlook the extent to which these wetlands are dependent
on forces outside their boundaries. With the ever rapid development of the adjacent uplands,
these core factors will become even more variable. For example, drainage-way wetlands will
depend on catchment basins to provide the hydraulic energy of water flow and to transport
nutrients in suspended sediments to the down stream branch bottoms. In this altered
landscape, the catchment basins are usually least dependent on outside forces and are thus
most amenable to wetland stability (Winters, 1981). In the altered landscape, catchment
basins can duplicate the existing energy signature of the drainage-ways and can serve to
modulate the influences of the local physical environment (Brinson and Lee, 1989).
Wetland Functions of Stormwater Ponds
One key element of surface water quality protection is the management of stormwater
runoff. Stormwater pretreatment (e.g. stormwater ponds, swales, and buffers) is essential to
minimize pollutant and sediment loading to natural surface waterways and wetlands.
Pretreatment can reduce nutrient and sediment loadings. Pretreatment also absorbs the
"shock" from the first flush effect of runoff when pollutant concentrations are highest from

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impermeable surfaces. One of the major wetland issues presently being discussed is the
relationship between wetlands and stormwater structures in developing landscapes. Land
developers and surface water managers would like to maximize the flood attenuation
functions that natural wetlands provide but also realize that stormwater structures can make
excellent wetland surrogates and can protect valuable down-stream wetlands if designed
correctly.
Recently there has been a growing recognition of the ecological and aesthetic values
that stormwater retention facilities provide. Research over the past two decades (Office of
Technology Assessment, 1984; Zedler and Kentula, 1986; Kusler and Riexinger, 1985) has
documented that such facilities if designed with wetland features can perform:
1. Water quality functions, such as sedimentation and the uptake and/or
transformation of nutrients, heavy metals and anthropogenic substances;
2. Hydrologic functions, such as flood storage and desyncronization, modification
of groundwater discharge, and streambank stabilization through attenuated flows;
and
3. Food chain support functions, or the contribution of wetlands to the
environmental requirements of organisms, such as food and habitat for fish,
waterfowl, amphibians, endangered species, and other species.
The understanding of the significance of these multiple functions has led to a growing
recognition that wetland features designed into stormwater retention basins serve as viable
ecological systems within the developing landscape. In spite of this new understanding,
degradation of adjacent wetlands often continues without the benefit of these pretreatment
surrogates. Surface water bodies downstream from stormwater retention basins depend on
nutrient regulation, sediment supply and control, and other water quality improvement
functions to maintain ecosystem and riparian balance. Downstream systems clearly benefit
from stormwater management activities upstream, particularly when those activities are
conducted as part of basin-wide management efforts. For example, accelerating stormwater
flows in developing basins can cause erosion problems in streams, particularly when flows
are uncontrolled. Scouring of stream substrates results in fish egg mortality, degradation of
instream habitat quality, and removal of floodplains and vegetation. As storm flow energy
recedes, the scoured sediments are deposited, reducing channel capacity, silting spawning
beds, and suffocating benthic organisms.
The Nucor stormwater ponds were designed along the basic principles for
maximizing wetland functions (Canning, 1988; Kulzer, 1989). They include the following:
1. Proper hydrological parameters have been optimized to ensure success of the
pond and to optimize vegetation growth and pollutant attenuation. The standing
water pool (during the seasons in which water quality benefits are desired) can be
adjusted with flashboard risers to range between 0.5 ft and 3.0 ft. (Schueler,
1987).
2. To minimize turbulence and short-circuiting into natural wetlands, stormwater
discharge to the adjacent drainage ways is distributed by splash-ways using

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1
impermeable surfaces. One of the major wetland issues presently being discussed is the
relationship between wetlands and stormwater structures in developing landscapes. Land
developers and surface water managers would like to maximize the flood attenuation
functions that natural wetlands provide but also realize that stormwater structures can make
excellent wetland surrogates and can protect valuable down-stream wetlands if designed
correctly.
Recently there has been a growing recognition of the ecological and aesthetic values
that stormwater retention facilities provide. Research over the past two decades (Office of
Technology Assessment, 1984; Zedler and Kentula, 1986; Kusler and Riexinger, 1985) has
documented that such facilities if designed with wetland features can perform:
I . Water quality functions, such as sedimentation and the uptake and/or
transformation of nutrients, heavy metals and anthropogenic substances;
2. Hydrologic functions, such as flood storage and desyncronization, modification
of groundwater discharge, and streambank stabilization through attenuated flows;
and
3. Food chain support functions, or the contribution of wetlands to the
environmental requirements of organisms, such as food and habitat for fish,
waterfowl, amphibians, endangered species, and other species.
The understanding of the significance of these multiple functions has led to a growing
recognition that wetland features designed into stormwater retention basins serve as viable
ecological systems within the developing landscape. In spite of this new understanding,
degradation of adjacent wetlands often continues without the benefit of these pretreatment
surrogates. Surface water bodies downstream from stormwater retention basins depend on
nutrient regulation, sediment supply and control, and other water quality improvement
functions to maintain ecosystem and riparian balance. Downstream systems clearly benefit
from stormwater management activities upstream, particularly when those activities are
conducted as part of basin-wide management efforts. For example, accelerating stormwater
flows in developing basins can cause erosion problems in streams, particularly when flows
are uncontrolled. Scouring of stream substrates results in fish egg mortality, degradation of
instream habitat quality, and removal of floodplains and vegetation. As storm flow energy
recedes, the scoured sediments are deposited, reducing channel capacity, silting spawning
beds, and suffocating benthic organisms.
The Nucor stormwater ponds were designed along the basic principles for
maximizing wetland functions (Canning, 1988; Kulzer, 1989). They include the following:
I . Proper hydrological parameters have been optimized to ensure success of the
pond and to optimize vegetation growth and pollutant attenuation. The standing
water pool (during the seasons in which water quality benefits are desired) can be
adjusted with flashboard risers to range between 0.5 ft and 3.0 ft. (Schueler,
1987).
2. To minimize turbulence and short-circuiting into natural wetlands, stormwater
discharge to the adjacent drainage ways is distributed by splash-ways using

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stabilized rock and promoting sheetflow rather than single point discharge that
results in stream scouring and reduced water quality.
3. Promoting residence time of runoff over several days enables precipitation of
the finer particulates, contact time with substrate, adsorption of nutrients, and
promotion of biomass interaction with floodwaters. Retention times are targeted
to over a week for intermittent storms in order to control particulate pollutants and
for adsorption of soluble pollutants (USEPA 1986).
4. Dense-growing wetland species will be planted along pond edges to increase
sedimentation, and to improve water quality treatment. Species will be planted
that will provide rapid stabilization and colonization of the soils on the designed
shelves in the ponds. Planting mixed stands of vegetation will provide the best
overall sedimentation and nutrient efficiency. Plants will not be extracted from
existing wetland donor sites because of the significant negative impact on those
sites. Plants will be obtained from a local native plant nursery. Relatively
constant water levels in the ponds will be maintained over long periods of time to
promote vegetative growth. Shallow water areas will be used to promote the
growth of emergent and submerged vegetation, which also results in higher
growth of algae and bacteria important for food-chain support. The success of the
planting program will be assessed annually to ensure colonization by desirable
species and to assess invasion of noxious species.
5. Wildlife use in stormwater ponds can occur disproportionately to other more
available habitats because the major life requirements for many species are found
in these areas (Brown, 1985). Many species show a preference for these habitats
even though their survival may not be dependent on them. The easy availability
of food, decreased predators, and rich vegetation can magnify the use of wildlife
of stormwater ponds.
In summary, wetlands are those areas that are inundated or saturated by surface or
ground water at a frequency and duration sufficient to maintain saturated conditions. These
conditions can exist in the preexisting Nucor site wetlands or the constructed stormwater
systems. The soil, benthic, vegetative, and species requirements in stormwater ponds are
often similar to those found in natural wetlands, especially if such features are designed into
the project. Such stormwater ponds have been shown to influence the character and health of
downstream wetland ecosystems, as reflected by species composition and richness, primary
productivity, organic deposition and flux, and nutrient cycling (USEPA, 1988). In general,
water movement through stormwater pond wetlands has a positive impact on the ecosystem.
Rather than wasting water, upland stormwater retention appears to save water and thus
promote increased regional wetland productivity indirectly.
References
1. Brinson, M.M. 1977. Decomposition and nutrient exchange of litter in an alluvial swamp
forest. Ecology. 58:601-609.

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2. Brinson, M.M. and L.C. Lee. 1989. In-kind mitigation for wetland loss: Statement of
ecological issues and evaluation of examples. IN: Freshwater wetlands and wildlife. No.
61. pp 1069-1085.
3. Brown, S. 1981. A comparison of the structure, primary productivity, and transpiration of
cypress ecosystems in Florida. Ecological Monographs. 51:403-427.
4. Brown, E.R. 1985. Effects of wetlands on quality of runoff entering lakes in the Twin
Cities Metropolitan Area, Minn. USGS Survey Report 85-4170.
5. Canning, D.J. 1988. Urban runoff water quality: Effects and management options.
Shorelands Technical Adisory Paper Number 4, Second Edition WA Dept. Ecology,
Olympia, WA.
6. Conner, W.H., and J.W. Day, Jr. 1982. The ecology of forested wetland in the
southeastern United States. Wetlands Ecology and Management. India. pp. 69-87.
7. Etherington, J.R. 1983. Wetland Ecology. Edward Arnold Publishers Ltd. London.
8. Furtado, J.I., and S. Verghese. 1981. Nutrient turnover in a freshwater inundated forest
swamp. Angewandte Limnologie. 21:265-315.
9. Kulzer, L. 1989. Considerations for the use of wet ponds for water quality enhancement.
Municipality of Metropolitan Seattle, Office of Water Quality, Seattle, WA.
10. Kusler, J.A. And P. Riexinger. 1985. Proceedings, National Wetlands Assessment
Symposium. June 17-20, 1985. Portland Maine. State Association of Wetland Managers,
Inc.
11. Lugo, A.E. 1988. Fringe Wetlands. Forested Wetlands. Elsevier, Amsterdam.
12. Odum, E.P. 1979. Ecological importance of the riparian zone. Strategies for protection
and management of floodplain wetlands and other riparian ecosystems. US For. Serv.
Gen. Tech. Rep. WO-12, WA DC. pp 2-4.
13. Office of Technology Assessment. 1984. Wetlands: Their use and regulation. US Printing
Office. WA DC. OTA-0-206.
14. Schueler, T.R. 1987. Controlling urban runoff: A practical manual for planning and
designing urban BMPs. Metropolitan Washington Council of Governments, WA DC.
15. US Environmental Protection Agency, 1986. Methodology for analysis of detention
basins for control of urban runoff quality. Nonpoint Source Branch. EPA-440/5-87-001.
16. US Environmental Protection Agency, 1988. Design manual for constructed wetlands
and aquatic plant systems for wastewater treatment. EPA/625/1-88/022.
17. Van Der Valk, A.G, C.B. Davis, J.L. Baker, and C.E. Beer, 1979. Natural Fresh water
wetlands as nitrogen and phosphorus traps for land runoff. Wetland Functions and
Values: The state of our understanding. IN: P.E. Greeson, J.R. Clark, and J.E. Clark, eds.
Pp.457-467.
18. Welcomme, R.L. 1976. Some General and theoretical consideration on fish yields.
Journal of Fish Biology. 8:351-364.
19. Wharton, C.H., W.M. Kitchens, E.C. Pendleton, and T.W. Sipe. 1982. The ecology of
bottomland hardwood swamps of the Southeast: A community profile. FWS/OBS-81/37.
20. Winters, T.C., 1981. Uncertainties in estimating the water balance of lakes. Water
Resources Bulletin. 17:82-115.
21. Zedler, J.B. and M.E. Kentula. 1986. Wetlands Research Plan. USEPA. EPA/600/3-
86/009. NTIS Number PB-86-158-656/AS.
J

Nucor Steel - Hertford
Characterization of
Intermittent Stream Channel Impacts and Stormwater Ponds

The following is a general characterization of "waters of the United States" that are proposed to be
impacted as part of the development of the Nucor Steel - Hertford Mill. The characterization is
based upon field inspections of the site by biologists with Newkirk Environmental, Inc.
Impacts within the Nucor Tract (excluding the utility corridor) are confined to the upper limits of
three linear drainages, which have been identified as jurisdictional "Waters of the United States".
Each of these drainages ultimately transition into narrow forested wetlands associated with, and
draining to, the Chowan River. In review of the difference between the upper and lower reaches of
these drainages, Nucor has made several revisions to site plans so as to avoid impacts to the lower
' reaches of these drainages where values and functions are greater. A majority of the proposed
impacts to the upper reaches of these systems are directly related to the construction of stormwater
detention ponds, associated with the mill.
The portions of the drainages proposed to be impacted are virtually without vegetation and are
characterized as temporarily flooded wet weather gullies. Following rainfall events, runoff from
' adjacent land is collected in the gullies, temporarily inundates the sites, and is carried to the lower
elevations and eventually to the Chowan River. During dry periods, the gullies may maintain
minimal levels of saturation until collected water has been transferred or evaporated. It is not
' uncommon for the sites to be completely dry for extended periods. As a result of natural erosion that
occurs within the bottom of the gullies, very little organic material is present or able to accumulate.
Considering site conditions and characteristics of the identified areas, the prim functions of these
?'
gullies are short-term flood storage and the transport of stormwater. The natural gradient of the
' channels does not permit significant groundwater recharge or allow for extended periods of ponding,
which would permit settling of sediment or particulate.
' The stormwater ponds to be constructed as part of the mill facility are designed to perform the same,
and in most cases enhanced, hydrologic functions performed by the existing gullies that are to be
' impacted. The three proposed ponds (Al, BI and C l) are designed to have vegetated littoral shelves
that will provide water quality benefits to downstream wetlands and waters. As designed, each of
these ponds will provide enhanced abilities to remove suspended solids, nutrients and pollutants.
Additionally, each pond is designed to temporarily hold the runoff from a 10-year 24-hour rainfall
event and release the water over a period of several days. Using this process, the downstream
wetlands and water will receive water but at a more controlled rate with less likelihood of erosion
and/or sediment collection. Also, the water released will have accumulated in the ponds for some
period of time, thereby allowing sediments, nutrients, and pollutants to settle out thereby improving
the water quality.

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Appendix B
Evaluation of Mitigation Sites

?j
NEWKIRK
Ewmo wNTAL, INC
Summary of Mitigation Search
Newkirk Environmental, Inc.
July 19, 1999
As part of the mitigation plans for Nucor Steel - Hertford County, Newkirk Environmental, Inc.
along with The Triangle Group completed comprehensive searches of a four county (Hertford, Gates,
Bertie and Chowan) area to identify potential restoration sites suitable and available for use in the
Compensatory Mitigation Plan for Nucor Steel - Hertford. Following are summaries of both
consultants regarding the results of these searches.
Newkirk Environmental, Inc.'s searches were completed in three phases:
' 1) Aerial reconnaissance by small plane;
2) Search of Hertford County "prior converted" sites; and
3) Review of Edenton Bay Restoration Project.
On March 12, 1999, Newkirk Environmental, Inc. and Nucor representatives flew the
Chowan River basin, both north and south of the project site, to identify potential mitigation
sites. Focus was placed on identifying potential restoration sites affected by ditching, road
construction, or filling. The results of this search found that the wetlands associated with the
Chowan River and adjacent lands are well defined and easily recognizable from the air. No
obvious sites with characteristics of impacts or potential restoration were identified.
Additionally, Newkirk Environmental, Inc. and The Triangle Group met with representatives,
county sponsors and landowners of the Edenton Bay Restoration project located in Chowan
County. The Edenton Bay Restoration Project is an ongoing effort to restore and enhance
functions and values of impacted wetland systems and protect high value systems in the area
of Edenton, North Carolina. Nucor explored the possibilities of becoming a partner with the
project as well as exploring opportunities of adding additional acreage and restoration sites
to the designated project area. Complexities associated with funding and structure of the
existing project make partnering difficult. A search for additional wetland restoration sites
to be added to the Edenton Bay project did not identify any areas that were available or
I feasible.
Savannah, GA Office
340 Eisenhower Drive
Building 200, Suite 201
Savannah, GA 31406
[phone]
Facsimile: [phone]
E-Mail: [e-mail]
Charleston, SC Office
192 East Bay Street
Suite 201
Charleston, SC 29401
[phone]
Facsimile: [phone]
E-Mail: NewkirkEnv®aol.com
Hendersonville, NC Office
300 N. Main Street, Suite 205
Post Office Box 2876
Hendersonville, NC 28793
[phone]
Facsimile: [phone]
E-Mail: [e-mail]
During the week of June 21-25, Newkirk Environmental, Inc. searched for and reviewed
potential restoration sites within Hertford County. This search was completed using soil
surveys and information, aerial photography and county mapping resources. Conversations
and meetings with the county Natural Resource Conservation Service (Mr. Greg Hughes)
were conducted to learn of "prior converted" sites on record. Additionally, Newkirk
Environmental, Inc. staff reviewed ortho-photographs of the county. Sites identified by
either, or both, the county or the NRCS were visited in the field to make preliminary
assessments of restoration potential. Only a few sites were identified as having potential and
upon a field review, it is the opinion of Newkirk Environmental, Inc. that none of the sites
is suitable or appear to be a strong candidate for successful restoration. The Triangle Group
has completed extensive searches and reviews of the sites identified by Newkirk
Environmental, Inc. as well as 29 additional sites in Bertie, Gates and Chowan Counties. A
full description and discussion of each researched site is included in The Triangle Group
chart that follows:
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RESTORATION SITE SEARCH DETAIL CHART BY COUNTY
The Triangle Group, LLC
During the period of June 28 - July 16, The Triangle Group conducted a mitigation site search in areas of
Bertie, Chowan, Hertford and Gates Counties that are within approximately 12 miles of the Nucor plant
site in Hertford County. The search targeted agricultural sites in that area for the following reasons:
• Agricultural sites are often the most cost-effective sites to restore and have high rates of
success.
• The benefits to water quality from restoring such sites are well documented and defendable
from a regulatory standpoint.
Sites were located in each county using soils and aerial photography data, along with conversations and
meetings with state and local agencies and government data on the properties. After gathering data on the
sites, field reviews were completed to visually inspect each site. In some cases, the property owner was
contacted to request permission onto the property. Preliminary assessments made based on these visits
follow. For each site, the county, owner, acreage, soil types present and a determination of suitability is
give.
s BERTIE COUNTY
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Site # County Owner Tract # Acres Soils
1 Bertie Mr. Wood Beasley T49 20 Bibb
2 Bertie Mr. Howard Brown T623 4 Tomotle
3 Bertie Mrs. Ramona Miller T320 8 Tomotle
4 Bertie Mr. Earnest Evans T1096 15.2 Rains
5 Bertie Inez Robertson/Milton
Robertson T 4 18.8 Rains
6 Bertie Robertson Bros., Inc. T411 18.46 Pante o
Bertie Catherine Henry T110 6 Rains
7 Bertie D. L. Askew T20 12 Rains

Site Descriptions: Bertie
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Site # Site Description
1 This site contains several drains that were once used as irrigation ponds and have since been
drained. These drains are not considered restorable due to their existing jurisdictional wetland
status. There are also problems with an existing center pivot irrigation system that uses these
areas as a travel lane.
2 Site 2 and 3 are very close together and were considered for their PC status and hydric soils.
After a field study, these sites were determined to have too much slope and divided the existing
farm fields severely for continued fanning activities.
3 Site 3 also is quite isolated from existing drainages and adjacent wetland areas.
4 This site is considered too isolated from nearby drainages and is reverting back to natural
vegetation.
5 Site 5 contains Rains soils on the majority of the tract and contains the headwaters of a nearby
drain. Soils exhibit hydric characteristics such as low chroma and mottles. This site was not
selected since hydrological modifications would affect adjacent landowners and the site was not
contiguous with adjacent wetland areas.
6 This site contains a large ditched creek with adjacent Pantego and Rains soils. Soils are hydric
and the area is contiguous with a wetland drain. Several landowners hold this site. Therefore,
restoring it back to wetlands would require lengthy, and probably unsuccessful negotiation if just
one owner objected to the project.
7 This site has hydric soils and is adjacent to a large wetland drainage. However, this site has too
much slope and not enough acreage for mitigation requirements.
GATES COUNTY
Site # County Owner Tract # Acres Soils Description
1 Gates Fort Island
location -------- 5-10 Pactolus with
Ballahack inclusions - not suitable
2 Gates Dou htie -------- 15-20 Icaria - not suitable
3 Gates Sherwood Eason -------- 5-10 Icaria inclusions - not for sale
4 Gates Todd Lewis T41,
T1319 200+ Various
h drics - not suitable
5 Gates Gurney Harrell T260 20.9 Ballahack - not for sale
6 Gates Charles Harrell T266 22.8 Ballahack - not for sale
7 Gates Todd Lewis T48 200+ Bladen - presently
unavailable
8 Gates Tim Plyler -------- 50+ Bladen - presently
unavailable
9 Gates Ellen Riddick T121 30+ Bladen - presently
unavailable
10 Gates Catherine Hofler T63 25+ Bladen inclusions - not selected
1 I Gates Umphlett family T400
I 43+ Bladen inclusions
I - presently
unavailable
11
Site # Site Description Continued
12 Gates Ivey Locke T107 9+ Icaria - not for sale
13 Gates Sherwood Eason T25 21+ Roanoke, Torhunta - not for sale
14 Gates Mary Ellen Eure T277 26+ Roanoke - not for sale
15 Gates Mary Hall T591 50+ various - presently
unavailable
16 Gates Gerald Greene T240 24.05 Bladen - presently
unavailable
17 Gates Galen Swinson T324 30+ Roanoke - not selected
18 Gates Joseph Duke Harrell T261 14.08 Roanoke - presently
unavailable
19 Gates Herbert Skinner ---------- 15+ Bladen - presently
unavailable

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Site Descriptions: Gates
Site # Site Description
1 This site has too few h dric soil inclusions and does not meet mitigation acre requirements.
2 Site 2 is not close enough to a drain and would affect the hydrology of adjacent landowners if
restored.
3 This site is not associated with any stream and is not for sale.
4 This site south of Gatesville is adjacent to a large bottomland wetland and is ditched. It was
learned that the owner is already restoring this tract due to an enforcement action by the USCOE
and it is not available for other work.
5 This PC site is ideal for wetland restoration and meets the mitigation acre requirements. A field
study showed that the site has hydric soils and is adjacent to a drainage and bottomland swamp.
Hydrological modifications would restore the wetland hydrology. Attempts to purchase were
made; the property is not for sale for any price.
6 This PC site is ideal for wetland restoration and meets the mitigation acre requirements. A field
study showed that the site has hydric soils and is adjacent to a drainage and bottomland swamp.
Hydrological modifications would restore the wetland hydrology. Attempts to purchase were
made; the property is not for sale for anrice.
7 This site has hydric Bladen soil and is located near a drainage. Hydrologic trespass concerns
may make the site unsuitable.
8 This site has hydric Bladen soil. The site is located near a drainage and Merchants Mill Pond. A
possibility exists here, although the site is presently unavailable.
9 This site has hydric Bladen soil. The site is located near a drainage north of Merchants Mill
Pond. Numerous owners resent difficulty in acquisition.
10 This site has Bladen soil near Merchants Mill Pond state park, but there are too few hydric soil
inclusions.
11 Much of the land is composed of Bladen soils. 1 drained pine plantation is present. The
property is presently unavailable.

12 Good site but learned after negotiations that the tract is not for sale.
13 Good site but learned after negotiations that the tract is not for sale.
14 Good site but learned after negotiations that the tract is not for sale.
15 An old drained and site. Presently unavailable.
16 Available hydrology is questionable.
17 Unlisted phone number, contacted property operator and inquired about possibilities. Presently
unavailable.
18 Possibility of hydrologic trespass in field to the south.
19 Available hydrology is questionable.
CHOWAN COUNTY
Site # County Owner Tract # Acres Soils
1 Chowan C.A. Perry & Son,
Inc. T239 19.3 Roanoke
2 Chowan George Jordan
(operator) T328 19.3 Roanoke
3 Chowan RudolphPerry T354 89.4 Roanoke
Site Descriptions: Chowan
1
Site # Site Description
1 This site has Roanoke soils that are hydric but are precipitation driven. Rolling topography is a
concern here.
2 This site has Roanoke soils and could possibly work, although on-site creation is a better
alternative.
3 This site has Roanoke soils that are hydric but are precipitation driven and are not ideal for
wetland restoration.
HERTFORD COUNTY

a

Site # County Owner Tract # Acres Soils Descri tion
1 Hertford J.D. Flowers T1157 30+ Leaf - presently unavailable
2 Hertford E. W. Jones T292 17+ Leaf - presently unavailable
3 Hertford 11 owners/Bazemore T306 16+ Leaf - presently unavailable

Site Descriptions: Hertford
Site # Site Description
1 Although precipitation driven, this site, which is on the upper portion of a 75 ac field could be
utilized without hydrologic trespass on the lower part of the field. Available hydrology is
questionable.
2 This site does not appear to demonstrate restorable jurisdictional hydrology.
3 Too man owners 11 counted in NRCS listing).
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Appendix C
US Army Corps of Engineers - Wilmington District
Compensatory Hardwood Mitigation Guidelines (12/8/93)
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CORPS OF ENGINEERS - WILMINGTON DISTff&'oK' BK""cll
COMPENSATORY HARDWOOD MTIGATION GUIDE INES (12/8/93)
1. IMPACT AREA / REFERENCE AREA EVALUATION
A. PHYSICAL CHARACTERISTICS
B. FUNCTIONS AND VALUES
C. IDENTIFY MITIGATION NEEDS IN ACCORDANCE WITH COEMITTGATION POLICY
U. SPECIFIC GOALS/STRUCTURE DESIGN/SUCCESS CRPPERIA
A. PHYSICAL CHARACTERISTICS OF SITE
1. SOILS: SUITABLE TO SUPPORT TARGET PLANT SPECIES
a. PHYSICAL
b. CHEMICAL
2. HYDROLOGY: SATURATED WITHIN 12 INCHES OF THE SURFACE, PONDER,
OR FLOODED AT LEAST 12.5% OF THE GROWING SEASON UNDER
REASONABLY AVERAGE CLIMATIC CONDITIONS
3. GEOMORPHOLOGY: SUITABLE TO MEET HYDROLOGY REQUIREMENT
a. CONTOURS
b. ELEVATION
c. DRAINAGE / CONNECTION WITH SURFACE WATERS
B. BIOLOGICALIVEGETATIONAL CHARACTERISTICS OF SITE DESIGN
1. SPECIES SELECTION: HARDWOOD SPECIES NATIVE TO AREA
f
2. NUMBERS OF INDIVIDUAL TREES: A MINIMUM OF 320 TREES/ACRE
SURVIMG FOR 3 YEARS
3. UP TO 10% OF SITE SPECIES COMPOSITION MAY BE COMPRISED OF
SOFTWOOD SPECIES
4. TREE COMPOSMON: MINIMUM OF 6 HARDWOOD SPECIES WITH NO
MORE THAN 20% OF ANY ONE SPECIES
III. SELECTION OF SITE
A. SUITABIIdTY OF LOCATION: ECOLOGICALLY ACCEPTABLE
B. SUFFICIENT SIZE TO SATISFY MITIGATION NEED
C. PHYSICAL CHARACTERISTICS
1. HYDROLOGY
2. SOILS
f 3. SLOPE
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S. VEGETATION SAMPLE PLOT REQUIREMENTS
a. 0-3 ACRE MITIGATION SITE: MINIMUM OF TWO 0.0S ACRE SAMPLE
PLOTS/ACRE OF MITIGATION SITE
b. 3-10 ACRE MITIGATION SITE: MDW4UM OF ONE OAS ACRE SAMPLE
PLAT/ACRE OF MITIGATION SITE
c. GREATER THAN 10 ACRE MITIGATION SITE: M GWM OF ONE 0.05
ACRE SAMPLE PLOT/1 ACRES OF MITIGATION SITE
d. PLOT DATA MUST BE REPRESENTATIVE OF ENTIRE SITE OR
COMMUNITIES OF ENTIRE SITE
c. SAMPLE PLOT REQUIREMENTS TO BE ULTIMATELY DE D ON
A CASE-BY-CASE BASIS
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C. MONITORING WELL REQUIREMENTS
1. NUMBER, LOCATION( AND INSTALLATION TECHNIQUE TO BE DETERMINED
BY SITE CONDITIONS
2. ALTERNATIVE HYDROLOGY MONITORING
o. OBSERVATION/PHOTO DOCUMENTATION OF SATURATION AND/OR
INUNDATION
b. STREAM GAUGE DATA RELATED TO SITE ELEVATIONS (FLOODING)
V. TRACKING SYSTF.M/MONMRING
A. FINAL DESIGN SPECIFICATIONS: SUBN TTED PRIOR TO INITIATION OF
CONSTRUCTION
B. AS BUILT REPORT: SUBMTITED WITIIIN 30 DAYS OF MITIGATION SITE
COMPLETION AND SERVES AS OFFICIAL NOTICE OF COMPLETION OF
MITIGATION CONSTRUCTION
1. FINAL ELEVATIONS
2. PHOTOGRAPHS
3. SAMPLE PLOT LOCATIONS
4. WELL AND GAUGE LOCATIONS (IF APPLICABLE)
S. PROBLEMS/RESOLUTION
6. OTHER LNFORMATION AS DEEMED APPROPRIATE
7. PLANTING DESIGN
C. ANNUAL MONITORING
1. CONDUCTED AUGUST SEPT04BER OF EACH YEAR UNTIL VEGETATIVE
SUCCESS CRITERIA MET
2. REPORT SUBMITTED WlIWIN 30 DAYS OF SITE MONITORING
a. PHOTOGRAPHS
b. SAMPLE PLOT DATA
c. WELL DATA (Er APPLICABLE)
d. PROBLEMS/RESOLUTION

VI. REMEDIAL ACTION: DEVIATIONS FROM ACCE19MD MITIGATION PLAN MUST BE
COORDINATED WffMAPPROVED BY THE CORPS OF ENGINEERS
A. UNSUCCESSl• L VEGETATION SURVIVAL
1 I. REPLANTING
2. SPECIES MODIFICATIONS
B. HYDROLOGY PROBLEMS
1. TOO WET
2. TOO DRY
C. VANDALISM
' D. ANIMAL DEPREDATION
E. NUISANCE PLANT SPECIES
VII. PERFORMANCE BOND TO ENSURE COMPLIANCE WITH PERMIT MITIGATION
REQUIREMENTS
VIII. FINAL DISPOSITION OF PROPERTYIPERMANENCE OF INTENTIONS
A. CONSERVATION EASEMENT
B. DEED RESTRICTIONS
C. DONATION TO CONSERVATION AGENCIES/ORGANIZATIONS

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IV. SPECIFIC CONSIDERATIONS
A. PHYSICAL SITE. PREPARATION REQUIREMENTS
I 1. HYDROLOGY
2. FERTILIZER NEEDS
3. pIULIME
4. DRAINAGE
5. ELEVATION
6. EROSION CONTROL MEASURES
B. VEGETATION REQUI RIB S
1. SPECIES SELECTION: HARDWOOD SPECIES NATIVE TO AREA
2. NUMBERS OF INDIVIDUAL TREES: A MINIMUM OF 320 TREES/ACRE
SURVIVING FOR 3 YEARS
3. TYPE OF STOCK
a. BARE ROOT:
1) 1 YEAR OLDt 12 TO 16 INCHES HIGH
2) 1/4 INCH OR GREATER DIAMETER ROOT COLLAR
3) 4 OR MORE LATERAL ROOTS
4) HEALTHY
b. ROOT BALL: ACCEPTABLE
c. SEED: CONDITIONALLY ACCEPTABLE
4. AVAILABILITY
a. SEASON
' b. NUMBERS
c. STOCK ORIGINILOGISTICS
5. SOURCES OF STOCK: PREFERRED SOURCE(S) WITHIN 200 MUM NORTH OR
SOUTH OF SITE
6. PLANTING REQUIREMEN'T'S
a. DENSITY OF PLANTINGS: MINIMUM OF 320 TREES/ACRE
b. SPECIES COMPOSITION: MINIM M OF 6 HARDWOOD SPECIES WITH
NO MORE THAN 20% OF ANY ONE SPECIES
c. PLANTING TR*M DECEMBER THROUGH MARCH
d. PLANTING PROCEDURES: SITE SPECIFIC, PROPER SILVICULTURAL
TECHNIQUES TO BE EMPLOYED
7. OTHER CONSIDERATIONS: SITE DISTRIBUTION OF SPECIE, S SHOULD BE
BASED ON SPECIES GROWTH RATE AND HYDROGEOMORPHOIOGY OF
TITS SITE

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Appendix D
Photographs of Preservation Site
and
Reference Plots

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On -Site Creation Area - Reference Plot (6/24/99)

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Proposed 150 acre Ott=Site Preservation Site (7/12/99)
r r R! r w. R? Rar w w? ? w r r. w r r=
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U. S. DEPARTMENT OF AGRICULTURE
Soil Conservation Service
HYDRIC SOILS
Hertford County, North Carolina
Hydric codes (HC):
Vegetation codes (VC):
Technical Guide
Section II-A-2
June 1991
1 = Hydric soils, only because of saturation for a
significant period during the growing season;
2 = Hydric soils that are frequently flooded for long or
very long periods during the growing season; and
3 = Hydric soils that are ponded for long or very long
periods during the growing season.
i = Hydric soils that support woody vegetation under
natural conditions; and
2 - Hydric soils that do not support woody vegetation under
natural conditions.
IMPORTANT NOTES: (1) Hydric soils in this county cannot be farmed under natural conditions
without removing woody vegetation or hydrology manipulation. (2) Some map units and included soils
listed as hydric soils in this county may not meet the definition of hydric soils and wetlands because
the hydrology has been altered through drainage or other manipulations.
A. Map units that are all hydric soils or have hydric soils as a major component.
Map Unit
Symbol HC VC Map Unit Name
BB 1,2, 1 Bibb soils
3
DO 1,2, 1 Dorovan soils
3
LF 1 1 Leaf loam
Ra 1 1 Rains fine sandy loam
Ro 1 1 Roanoke loam
To 1 1 Tomotley fine sandy loam
We 1,2, 1 Wehadkee silt loam
3
Wn 1,2, 1 Wilbanks silty clay loam
3
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Hertford County
B. Map units with inclusions of hydric soils or have wet spots.
Map Unit Hydric Normal location
Symbol Map Unit Name Inclusion HC VC Inclusion
Ata Altavista fine sandy Tomotley 1 1 depressions
loam, 0 to 2 percent
slopes
Ln Lenoir loam Leaf 1 1 depressions
Rains
Ly Lynchburg fine sandy Rains
loam
1 1 depressions
1 1 depressions

Appendix F
Stormwater Permit Application Calculations
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Nucor Steel Hertford County
Stormwater Design Calculations
Basin B2B
Using Pond C1
Basin Characteristics
Total Basin Area (Ta)= 3,780,137,, sf= 86.78 ac
Impervious Area da)= 1.730.203 sf= 35.72 ac
Permanent Pool Calculations (Pond C1)
Select Permanent Pool Depths ; u:5 ft
Permanent Pt>ol Top Elevation= 3025, It
Bottom Elevation= ..25:25•ft
Top of Dike Elevation=
Required Surface
Area ;SA)= 20.964 sf= 2.78 ac
(TSSi100)"Ta
(3.201100)"86.78= 120.964 st= 2.78 ac
Per. Pool Volume= 738;662 cf
Percent impervious ?I)= 45.77%
(lalral
90% TSS Removal k0wo Vegetative f=ilter- d .3=20.
From SAIDA Table Attached - 5' deep a 45.77% Imp.
Actual Surface Area
PrvAded= 1,7P0,400 sf
1" Storm Volume (Pond C1)
Volume to be drawn down from 2 to 5 days.
Runoff Coefficient (Rv)= 0.46 inlir. 1" Storm Stage= 31.15 ft
(0.05+0.009"1)
(0.05+0.009"45.77)= 0.46 inAn
1" Storm Volume (Vol)= 3.34 aaft 145,516 of
(1 "-Rv-Ta)
(0.083.0 46'86.78)= 3.34 actt 145,515 of
Select orifice size to discharge runoff from 1" rain event and calculate drawdown Gme.
(Drewdown time must be between 2 to 5 days to meet stcrmwater BMP.)
Orifice Coeffdent (Cd)= 0.6
Orifice Size (d)= 4 in
Orifice Area= 0.09 sf
or. 32.2 Wsec2 Drawdown Time= 3.9 d OK
head (h)= 1.07 ft (Must be more than 2 days and less :hen 5 days)
'Discharge (Q)= 0.43 efs
'Discharge from orifice sized above for runoff from the 1" rain event.

99 0X1)
Revised Compensatory Wetlands Mitigation Plan
for
The Nucor Steel Plate Recycling Mill
Hertford County, NC
November 8,1999
Prepared For:
NUCOR STEEL - HERTFORD COUNTY, NC
Prepared By:
The Triangle Group
Post Office Box 33604
Raleigh, North Carolina 27636
[phone]
Attention: Russ Lea, Ph.D.
Newkirk Environmental, Inc.
192 East Bay Street, Suite 201
Charleston, SC 29401
[phone]
Attention: Stephen A. Nichols

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Revised Compensatory Wetlands Mitigation Plan
for
The Nucor Steel Plate Recycling Mill
Hertford County, NC
November 8, 1999
Prepared For:
NUCOR STEEL - HERTFORD COUNTY, NC
Prepared By:
The Triangle Group
Post Office Box 33604
Raleigh, North Carolina 27636
[phone]
Attention: Russ Lea, Ph.D.
Newkirk Environmental, Inc.
192 East Bay Street, Suite 201
Charleston, SC 29401
[phone]
Attention: Stephen A. Nichols

TABLE OF CONTENTS

' 1.0 INTRODUCTION ...............................................................................................................1

...........................................................................
2.0 AVOIDANCE AND MINIMIZATION. .2
' 3.0 IMPACTED WETLANDS ............................................................................................... ..3
' 4.0 COMPENSATORY MITIGATION ................................................................................
4.1 Mitigation Goals and Target Functions ................................................................ ..4
..5
4.2 On-Site Creation ................................................................................................... ..6
' 4.2.1 Implementation and Methodology .............................................................
4.2.1.1 Excavation and Site Preparation .................................................... ..9
..9
4.2.1.2 Hydrologic Input ............................................................................ 11
4.2.1.3 Water Budget Analysis ..................................................................
4.2.1.4 Vegetative Planting ....................................................................... 12
13
4.2.1.5 As-Built Report ............................................................................. 14
' 4.2.2 Monitoring .................................................................................................
4.2.2.1 Vegetative Monitoring ................................................................... 15
15
4.2.2.2 Hydrologic Monitoring .................................................................. 16
4.2.3 Probability of Success ................................................................................
4.2.4 Success Criteria .......................... 17
4.2.5 Contingency ............................................................................................... 18
' 4.2.6 Timing and Schedule .................................................................................
4.3 Preservation of Off-Site Acreage ......................................................................... 18
19
4.3.1 Fisheries Functions of Preservation Area ................................................ 20
' 4.3.2 Preservation Area Quality ........................................................................
4.3.3 Effects of Clearcutting on Breeding Bird Communities 21
Enhancement and Bioengineering of Stormwater Ponds ......................... 22
' 5.0 ADDITIONAL ON-SITE MITIGATION ....................................................................... 24
5.1 On-Site Preservation ................................................................................................ 24
' 5.2 Enhancement and Bioengineering of Stormwater Ponds ........................................ 24
5.2.1 Establishment of Vegetation within Shelves . .. 26
5.2.2 Vegetation Maintenance ............................................................................ 26

10

Nucor Steel - Hertford County
Revised Compensatory Mitigation Plan
November 12, 1999
' 1.0 INTRODUCTION
This revised mitigation plan describes compensatory measures for unavoidable impacts to 2.32-
acres' of freshwater wetlands and Waters of the United States associated with development of the
Nucor Steel - Plate Recycling Mill, Hertford County. The mill facility is located on approximately
' 900 acres of land adjacent to the southern shore of the Chowan River, approximately 8 miles east of
Winton, North Carolina. The applicant, Nucor Steel, has applied to the US Army Corps of
Engineers for the necessary permits to excavate and fill the identified jurisdictional waters. The
' following revised mitigation plan is provided in support of Nucor's 404/Section 10 permit
application and in response to agency comments, including those provided by the U.S. Army Corps
of Engineers in a February 24, 1999 letter, August 16, 1999 meeting, and a November 10, 1999
letter. Major revisions to the original compensatory mitigation plan (January 1999) have been made
' in response to agency comments and based on additional information obtained by Nucor's
environmental consultants (Newkirk Environmental, Inc. and The Triangle Group). Nucor will also
purchase and preserve approximately 150-acres of off site high quality riparian wetlands along the
' Chowan River. In addition to the compensatory mitigation, which exceeds no-net-loss, the
' stormwater management ponds will be enhanced through construction of 2.43 acres of vegetated
littoral shelves. Finally, as previously documented, higher value wetlands located within the mill site
' will be preserved and protected with an upland buffer zone (48.82 acres).

' INucor had previously committed to 0.41 acres of additional avoidance and minimization resulting in a
15% further reduction in wetland impacts.
io 1

This plan successfully meets the mitigation requirements of Section 404 and implementing
regulations. The design of this plan provides compensatory mitigation substantially in excess of the
"no-net loss" policy. Nucor and its environmental consultants have reviewed the plan and concluded
' that it is both feasible and very likely to succeed.
' 2.0 AVOIDANCE AND MINIMIZATION
Nucor Steel has made every reasonable and practicable effort to avoid and minimize impacts to
' jurisdictional wetlands and waters while still attaining project goals and construction requirements.
A comprehensive alternatives analysis, which details the site selection process, was previously
' completed by DeLaney and Sellers, P.A. Additional support was submitted May 28, 1999, as a
supplement entitled "Nucor Steel'Hertford County - Plate Mill' Wetland Avoidance/Minimization."
In response to comments, each proposed impact has been reviewed and re-evaluated to ensure that
appropriate avoidance and minimization measures have been taken.
The additional avoidance and minimization is being accomplished by complete elimination of
M stormwater pond B3 and re-routing the haul road to the port. The wetlands which were to be
impacted by pond B3 and the haul road have been identified by Nucor's consultants as having higher
' values and functions than the remaining drainage ways to be impacted. Avoiding and preserving
these areas will limit remaining impacts to the upper reaches of the drainage channels where wetland
values and functions are generally lower. Stormwater volumes lost by the elimination of stormwater
pond B3 will be replaced by resizing ponds B 1 and Al. The location of the haul road will be shifted
' to the west and designed to cross the wetland at an existing crossing. New culverts will be installed
at the existing crossing and the road will be stabilized to handle expected vehicle weights and
stormwater flows.
Comprehensive wetland delineations (Figure 1, revised site plan) identified a total of 19.49 acres of
' wetlands and Waters of the United States and on the site proper and adjoining utility corridor (this
acreage total does not include the "non-determined jurisdictional area"). Of this total, approximately
10% (2.32 acres) are now proposed to be impacted by construction of the mill and necessary support
structures or features. The remaining 14.87 acres of wetlands on-site will be preserved. Nucor has
2

continued to make every effort to avoid and minimize wetland impacts, including the recent
elimination of impacts associated with stormwater pond B3 and the haul road to the port.
Elimination of these impacts, a total of 0.41 acres, reduces the total impact to 2.32 acres (1.71 acres
to the site proper and 0.61 acres to the adjoining utility corridor), an additional 15% reduction
(Figure 1).
3.0 IMPACTED WETLANDS
' Impacts within the Nucor Tract (excluding the utility corridor) are confined to the upper limits of
three linear drainages, which have been identified as jurisdictional "Waters of the United States".
' Each of these drainages ultimately transition into narrow forested branch bottom wetlands associated
with, and draining to, the Chowan River. After review of the difference between the upper and
lower reaches of these drainages, Nucor made several revisions to site plans to avoid impacts to the
lower reaches of these drainages where values and functions are generally greater. A majority of the
' proposed impacts to the upper reaches of these systems are directly related to the construction of
stormwater detention ponds.
Newkirk Environmental, Inc. and The Triangle Group have analyzed impacts to jurisdictional
wetlands/waters associated with construction of stormwater ponds. These reports are attached in
Appendix 1. The portions of the drainages proposed to be impacted are virtually devoid of
vegetation and are characterized as temporarily flooded wet weather gullies or drainage ways.
' Following rainfall events, runoff from adjacent land is collected in the gullies, temporarily inundates
the sites, and is carried to the lower elevations and eventually to the Chowan River. During dry
periods, the gullies may maintain minimal levels of saturation until collected water has been
transferred or evaporated. It is not uncommon for the sites to be completely dry for extended
' periods. As a result of natural erosion that occurs within the bottom of the gullies, very little organic
material is present or able to accumulate. Both environmental consultants concluded that the narrow
intermittent drainage ways to be impacted serve limited wetland functions, and serve primarily to
transport surface water. Both Newkirk Environmental, Inc. and The Triangle Group concluded that
' the proposed stormwater ponds with vegetated littoral shelves should provide comparable or better
nutrient and pollutant removal functions than the natural drainage channels they replace. In
3

addition, the stormwater ponds will serve the functions of erosion and sediment control by allowing
surface waters to collect and to settle out sediments prior to release of stormwater. The use of
vegetated littoral shelves around the stormwater ponds will provide additional sediment and
' pollutant filtering and removal, and may provide additional habitat for waterfowl and wildlife.
Finally, the stormwater ponds will be designed to gradually provide surface water hydrology (post
' storm event) for down-gradient branch bottom wetlands.
' Temporary impacts to wetlands are associated with installation of a water line and natural gas line
within the designated utility corridor. Upon completion of construction activities, wetland
topography will be restored to original contour elevations and seeded with hydrophytic, herbaceous
vegetation. Wooden mats and other BMP's will be used to aid in utility installation within the utility
' corridor wetlands.
4.0 COMPENSATORY MITIGATION
During the planning and permitting process, Nucor expended great effort to identify suitable and
appropriate mitigation sites. This process has included reviewing potential creation, restoration,
enhancement and preservation opportunities, both on-site and off-site. Nucor and its consultants
have received considerable input from the USACE, other federal agencies, public comments, and
state agencies. In response to expressed preferences for off-site restoration, Nucor and its
' consultants conducted extensive searches for off-site restoration opportunities in Hertford, Gates,
Bertie, and Chowan Counties and determined that suitable off-site mitigation opportunities are
' unavailable or not practicable (Appendix 2). Based on this research, Nucor revised its mitigation
plan to provide compensatory mitigation for unavoidable impacts to identified wetlands as follows:
1) On-site creation of seven acres of freshwater bottomland
' wetlands; and
2) Off-site preservation of approximately 150 acres of forested
' riparian wetlands approximately 10 miles downstream on the
Chowan River (Figure 2)
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4.1 Mitigation Goals and Target Functions
The goal of the proposed mitigation is to offset impacts to on-site wetlands by replacing lost
' functions and values with equal or higher functions and values. The primary target functions
to be replaced are stormwater storage and filtration capacities, stormwater transfer, and
' habitat resources. The creation of the proposed wetland area will more than compensate for
the stormwater storage and filtration functions that will be impacted. The preservation of
high value forested wetlands will ensure stabilization of valuable habitat in an undisturbed
state.
Wetland functions involve the performance or execution of changes within the wetland
' ecosystem whether natural or created. In conformance with the laws of nature, these
functions include biological, chemical and physical transformations in the diversity of forms
' and substances that exist within the wetland. Representative biological functions include
providing habitat for reproduction, feeding, and resting. Representative physical functions
include flood attenuation, groundwater recharge and sediment entrapment. Representative
chemical functions include nutrient removal and toxics decontamination.
In addition to the three primary transformations described above, morphometry
' (measurement of external form) also impacts the functions of wetlands. Morphometry
includes location, drainage area, surrounding land use, area, slope of wetland, slope of
surrounding land, and perimeter to slope area. As most wetlands are located in topographic
depressions, these external factors have been used to provide indirect determination of
' wetlands functions, such as sediment trapping abilities.
' The Nucor wetland creation will play a principal role in modifying water quality discharged
from stormwater pond C 1. The created wetland will be in a headwater location of Brooks
Creek just north of Bazemore Road. Reliance on the principal function of this created
wetland in terms of water quality is justified given the proven success of using small-scale
wetlands for on-site stormwater treatment (both primary and secondary). Pioneering work
5

' by Kadlec (1979), as well as work by Mitsch et al. (1988), Hammer (1989, 1992), Mitsch
(1992), and Rodgers and Dunn (1992), have considered the assimilative capacity and success
of created wetlands in terms of improving water quality.
While the creation project will possess a morphometry to promote retention of stormwater,
' retention of sediments and enhancement of biogeochemical cycling of nutrients, it will also
be designed to enhance plant growth to improve the biotic metabolism of the wetland
ecosystem. Optimization of the wetland soils condition will be undertaken to ensure that
stem and leaf productivity of wetland plants will be accelerated to provide surface area for
' microbes. The same vegetation will enhance below ground transport of oxygen and will
produce an oxidized zone in the rhizosphere where additional microbial populations can
' exist. Such functions of water quality enhancement, like the Nucor wetland creation, have
recently been incorporated into wetland designs to control non-point sources of pollution
' (Mitsch 1992), treat agricultural runoff (Hammer 1992) and treat pesticides (Rodgers and
Dunn 1992). Not only have the functions of engineered wetlands been elevated in terms of
treatment of wastewater, but also nutrient removal by natural wetlands has been valued for
its role in water quality improvement. As a result, based on landscape ecology functions
' related to water quality, the U.S. Environmental Protection Agency (1990) has established
national guidance on expected water quality in wetlands. Nucor believes it is preferential to
improve water quality leaving the Nucor site than to restore natural wetlands off-site.
4.2 On-site Creation
The applicant proposes to construct seven acres of forested wetlands adjacent to an existing
' on-site wetland that is proposed to be protected (Figures 3 and 3a). Construction of this
wetland will follow the Corps of Engineers - Wilmington District Compensatory Hardwood
' Mitigation Guidelines (Appendix 3). Upon completion, the created wetland and a 100 foot
buffer will be preserved. The southern portion of the created wetland area is also protected
by the 200' perimeter buffer. Specifics of the planned creation project are outlined below.
10 6

US Army Corps of Engineers mitigation recommendations request that impacted wetlands
be mitigated at a 3:1 ratio. Using the total impact of 2.32 acres, the required mitigation for
the project to meet Corps requirements is 6.96 acres. State mitigation requirements are
' based upon distances from major surface water tributaries. Noting that most of the proposed
impacts fall within the lower bracket of the State requirements, the 3:1 Corps ratio will
' exceed the State requirements. Once stabilized, the created wetland should compensate for
lost functions associated with the natural drainages and wetlands proposed to be impacted.
Ultimately, the created forested wetland will provide similar hydrologic functions to those of
the impacted wetlands (water transfer) and will likely provide higher vegetative, habitat
' resources, and stormwater desynchronization values than the upper reaches of several of the
impacted areas.

The proposed creation site is located along the southern property boundary adjacent to
' wetland "W/X" (Figure 3). Wetland "W/X" is a small topographically depressed drainage
that originates approximately 200 feet from Bazemore Road. The small portion of wetland
"W/X" that is present within the Nucor Tract is a portion of a larger tributary that drains in a
southwesterly direction to Brooks Creek. The natural wetland is hydrologically supported
' by ground water and surface runoff from adjacent highland. A shallow swale that runs from
the upper (northern) end of the wetland through the forested uplands in a northeasterly
' direction collects runoff and carries water to lower elevations.
' On June 24, 1999, Newkirk Environmental, Inc. completed plot surveys of the natural
wetland to document existing conditions and establish reference data for comparison with
the creation area. This was completed by establishing random 30 foot diameter plots at three
locations within the wetland system: 1) within the center of the on-site portion of wetland
' "W/X", 2) adjacent to the road at the intersection of Brooks Creek and Bazemore Rd. and 3)
adjacent to the road at the intersection of Brooks Creek and Wiccacon Rd. At each location,
' vegetative species within the plot were identified and documented in a species list. The
following species were identified as occurring most commonly or as dominants:
7

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Red Maple (Acer Rubrum) Sweet gum Royal Fern (Osmunda regalis)
Blackgum (Nyssa sylvatica) Red Maple Sphagnum moss (Sphagnum spp.)
Laurel Oak (Quercus Laurifolia) Red Bay (Persea borbonia) Cinnamon Fern (Osmunda
cinnamonea)
Cypress (Taxodium distichum) Blackgum Netted Chain Fern (Woodwardia
aerolata)
Loblolly Pine (Pinus taeda) Water Oak (Quercus nigra)
Sweet gum (Liquidambar
styraciflua)
Representative photographs of the reference site are included in Appendix 4. As the
wetlands to be impacted have been noted as being generally void of vegetation, the species
list compiled from the reference plots will serve to establish a planting list.
Additional data and observations collected during plot surveys of the natural wetland "W/X"
include soil characteristics and inundation/saturation indicators. Soil samples match the
description of Bibb soil, which is listed as hydric in Hertford County. Excavated soil pits
found the ground water table approximately 2-3 inches below the surface. Regional
indicators of soil saturation, including oxidized rhizospheres, were common. Buttressed and
multiple trunks are also present. Indications that the natural wetland is subject to periodic
levels of inundation include matted leaf litter and water marks at approximately 3 inches
above the surface.
Nucor proposes to convert approximately seven acres of upland adjacent to wetland "W/X"
to a similar wetland system (Figures 3 and 3a). The area proposed to be used for the creation
site has been verified as uplands in the site wetland delineation previously approved by the
USACE. This adjacent upland is approximately 1.5 to 2.0 feet higher in elevation than
wetland "W/X" and is typical of the upland areas found on the Nucor Tract. Vegetatively
the proposed site is dominated by red maple, tulip poplar (Liriodendron tulipifera), laurel
8

0
' oak and loblolly pine (Pinus taeda). Soils on the site match the description of Leaf series
(Appendix 5).
' The particular area is proposed because, unlike other areas of the site, the site maintains a
relatively constant elevation, which is close to the elevation of the adjacent wetland. Other
wetlands, both on site and on adjacent lands, are typically located in much lower, steeply
topographic draws. The difference in elevation at these other sites would make excavation
and successful creation activities difficult or impossible to achieve.
' 4.2.1 Implementation and Methodology
The applicant proposes a five-step approach to complete creation of the
designated wetland site.
1. Data collection from reference points - (collected)
2. Design of water budget - (completed)
3. Excavation and site preparation
4. Vegetative planting
5. Hydrologic and vegetative monitoring to show success.
The first two tasks have been completed with the plot surveys of wetland "W/X"
prepared by Newkirk Environmental, Inc on June 24, 1999.
4.2.1.1 Excavation and Site Preparation
' Upon approval, the applicant will promptly survey and mark in the field the
location of seven acres of upland immediately adjacent to wetland "W/X" to
' be used as the creation area. The associated 100-foot wide upland buffer
(3.27-acres) protecting the mitigation creation area will also be marked in
the field. The approximate location of the creation site has been identified
(Figures 3 and 3 a). The final site boundaries will be field located based upon
' soils, elevation and vegetation impacts. Once located, the creation site will
9

1
be graded using Best Management Practices to prevent unwanted erosion
during and after grading activities. This will include the stabilization of the
transition area between the created wetland and the adjacent upland areas
1 using a not-less-than 3:1 vegetated slope. The transition area will be planted
with shrubs and trees on a 6 x 10-foot spacing and an acceptable ground
1 cover. Shrub and tree species for the transition area will include wax myrtle
(Myrica cerifera), redbay (Persea borbonia), and mast producing species
1 such as chestnut oak (Quercus michauxii). The initial ground cover will be
winter wheat and/or Japanese millet and will be mowed the first year prior to
1 seed maturity.
1 Prior to excavation, spot elevations within wetland "W/X" will be taken to
determine the appropriate finish elevation of the creation area. It is
1 anticipated that the creation area will be nearly level with only enough
change in elevation to permit natural sheet flow.
Excavated material will be removed by means of heavy machinery and trucks
1 and stock piled or moved to an appropriate upland site. Existing soils will be
removed to an elevation approximately 12 inches below the desired finished
1 elevation (Figure 4). Soil samples will be taken from this elevation (12
inches below final grade) and tested for chemical aspects such as pH and
1 nutrients. Soil test results will be used to determine the best method of
enhancing growth of planted vegetation.
1
Following excavation, the site will be backfilled with a minimum of 12
1 inches of suitable topsoil. Following backfilling, the site will be leveled and
elevations spot checked and documented. As part of the excavation, a
' smooth transition from the creation area to the natural wetland will be
established. In areas where the identified wetland boundary is slightly higher
1 than the desired finish elevation, a minimal amount of grading at the wetland
10
11

boundary will be completed to prevent the creation of a "ridge" between the
two areas. Prior to undertaking this work the permittee will coordinate with
the USACE.

4.2.1.2 Hydrologic Input
' Existing wetland "W/X" is supported by ground water and surface water
runoff. By setting the finished elevation of the creation area to the same
' level as the natural wetland, natural ground water elevations, which influence
the existing wetland, should occur in the creation area. The Leaf soils
' identified within the creation area are characterized as poorly drained with
slow permeability. The high water table for both the Leaf and Bibb series are
' similar and are noted as being 0.5-1.5 feet below the surface for five months.
Additional sources of water to the site will come from stormwater runoff
from: (I) the newly constructed public road diverted by roadside swales, (ii)
stormwater pond (C 1) which will be constructed immediately to the north of
the creation site, and (iii) natural stormwater runoff collected from the
adjacent undisturbed watershed areas.
1
Stormwater pond C1 (Figure 3) is designed to collect water from
' approximately 86.78 acres of land, including 39.72 acres of impervious
surface, with a capacity of 738,882 to 1,291,418 cubic feet. Permanent pool
' size of this pond is 170,400 square feet (3.91 acres). Pond C l is designed
with two forebays (Figure 3). These forebays collect sediment that may flow
' into the stormwater pond. The total storage area for the forebays is
approximately 258,284 cubic feet. Sediment deposits will be removed on a
' periodic as needed basis from the forebay areas as described in Appendix 6.
Stormwater pond C1 will be maintained on a regular basis as described in
' id
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the following described discharges into the wetland creation area. Periodic
10 11

I I
' maintenance of Pond C1 is not expected to have an adverse effect on the
wetland creation area.
' The outlet of this pond will be constructed to discharge into the creation area.
Using calculations from the "Stormwater Management Permit Application"
' (Appendix 6), discharges into the creation area will total 0.43 cfs during and
following a 1 inch storm and will increase with larger rain events. The
t discharge of treated water will be directed into the created wetland by means
of a diffuser pipe that will evenly spread the water and create sheet flow over
' the creation area (Figure 5). Construction drawings of the diffuser pipe will
be submitted to the USACE prior to installation of the diffuser pipe. Once in
' the created wetland, discharged water will follow the ground contours
through the creation area and continue towards Brooks Creek.
4.2.1.3 Water Budget Analysis:
y Method of Thornthwaite and Mather (1957):
' A water balance was determined for the approximate area of the Nucor
wetland creation site using the adjusted Thornthwaite method for Eastern
' North Carolina, a widely accepted hydrological model (Table 1).The
following data was used in the computations: Long-term (1974-1998)
' precipitation data, acquired from the nearest meteorological station (Station
312637 - Edenton, NC), average monthly day lengths determined for
' Edenton from U.S. Naval meteorological observation data available on the
internet, and other parameters needed for the model including soil texture,
' mean vegetative rooting depth, and water-holding capacity. The soil texture
parameter used was clay loam, the vegetative rooting depth was 1.0 meter,
and the water holding capacity in the root zone was estimated to be 200 mm
(Dunne and Leopold 1978). Table 1 illustrates the water balance model
12

I
'
using long-term precipitation data and the temperature-based Thonthwaite
potential evapotranspiration (PET) formula. This formula is as follows:
' PET =1.6*Ld*(10*TC/I)a
Where:
' I = the annual heat index
a=(1.6/100)*I+0.5
' PET = potential evapotranspiration in cm/month
T = avg. temperature for the month in degrees C
' Ld = daytime hours in units of 12
Potential evapotranspiration is greater for the months of April, May, June,
' and July during the growing season due to higher temperatures and increased
transpiration from growing vegetation (Figure 6). Based on the water
' balance model, (Figures 7 and 8), there will be ample water for 22 days
during the growing season.
4.2.1.4 Vegetative Planting
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planting list of at least six species will be determined. Specific species to be
planted will include at least six of the following:
' Laurel Oak (Quercus laurifolia)
Tupelo (Nyssa biflora)
Cypress (Taxodium distachum)
Red bay (Persea borbonia)
Water Oak (Quercus nigra)
' Green Ash (Fraxinus pennsylvanica)
Swamp Chestnut Oak (Quercus michauxii)
' Willow Oak (Quercus phellos)
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' Bareroot seedling stock will be obtained from a qualified nursery in a similar
region (less than 200 miles north or south from the mitigation site).
Individual seedlings will be manually dibbled on 6 x 10 foot spacing (726
trees per acre). Species mixing/distribution will be planned at the nursery
'
Prior to planting. No single species will account for more than 20% of the
total. Planting will occur during the dormant season (December - March) to
reduce shock and promote survival rates. With each planted seedling, a
fertilizer pack will be included during planting. Broadcast fertilizing is not
proposed, as this would increase competition.
Shrub and herbaceous species are not proposed to be planted to reduce
' immediate competition to the planted hardwoods. Adjacent seed sources and
the addition of peat or topsoil should naturally encourage and support the
' establishment of indigenous shrubs and herbs.
At the time of planting, each planted seedling within an established
monitoring plot (see section 4.2.2.1) will be marked and the total within each
' plot documented for use in determination of survival rates and attainment of
success criteria.
4.2.1.5 As-Built Report
' Within 30 days of the completion of planting, the applicant will submit to the
appropriate agencies anAs Built Report to document completion of the work.
' This report will include exhibits of the site location, final site elevations and
grades, well locations, sample plot locations and planting design. If any
problems or deviations from the original plans are necessary, these will be
fully documented and explained.
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' 4.2.2 Monitoring
Monitoring of the creation site will be completed on a annually scheduled basis to
document attainment of success criteria. Vegetation monitoring will occur at the
' end of the growing season (August - September) each year. Hydrologic monitoring
will occur at the beginning of the growing season (February - May) each year. The
' monitoring data will be compared with designated success criteria. A qualitative
assessment and description of the entire creation area will also be conducted.
' Collected data and photographic documentation of plot succession and conditions
will be compiled in an Annual Report to be submitted to the appropriate agencies by
December 31 of each monitoring year. Photographic documentation will be
provided by taking a photograph of each plot center and two additional photographs
of each plot facing north and south.
' 4.2.2.1 Vegetative Monitoring
The applicant will monitor the creation site to document survival of planted
trees and regeneration of volunteer species six times over a five year period.
Baseline monitoring and As-Built Summaries will be submitted immediately
' following planting. Annual monitoring will occur annually thereafter for a
period of five years. Vegetative monitoring will be conducted in accordance
with the Comprehensive Wetland Determination Methodologies as described
in the US Army Corps of Engineers Wetland Delineation Manual (1987).
Vegetative monitoring will be accomplished by establishing parallel line
' transects within the creation area. Randomly set permanent plots (minimum
of seven) will be established at the time of planting on approximately 300
' foot intervals along the transects. The center of each plot will be
permanently marked using ten-foot high stakes appropriately labeled and
marked for future identification. Within each plot, stem survival of planted
and volunteer tree species will be documented in a 30-foot radius area.
Volunteer shrubs and herbaceous species will be documented in ten (10) and
15

' five (5) foot radius areas, respectively. Baseline monitoring will be
completed within each plot at the time of planting so that all planted
seedlings may be identified and marked for future surveys.
Species composition and dominance will be measured within each plot. All
' stems will be identified to at least the genus level and the number of stems
recorded for each. For the purpose of measuring against the success criteria,
survival of planted seedlings will be expressed in terms of the calculated
number of live stems per acre. Volunteer species will be expressed in terms
' of number of stems per acre and coverage.
' 4.2.2.2 Hydrologic Monitoring
Hydrologic monitoring of the creation area will be completed by recording
and documenting groundwater and surface water elevations. Water levels
within the creation area will be recorded to determine that wetland hydrology
criteria is met. Five automated wells will be installed on the site following
construction of the creation area. Four wells will be located in the creation
' area and a single well will be placed in the existing adjacent wetland to begin
gathering background data. Wells will be installed immediately following
' completion of grading and planting following the guidance set forth in
Installing Monitoring Wells/Piezometers in Wetlands (VW Technical Note
NY-IA-3.1, August 199). Two readings per day will be recorded for one
month prior to the beginning of the growing season and continue for a
' minimum of two months into each growing season of the five year
monitoring program. At the end of the three-month period, collected data will
' be analyzed and compared with success criteria. If wetland hydrology has
not been documented in the creation area, additional well readings will occur
through the end of the growing season.
ie 16

'
Recorded hydrology data will be supported by visual observation of
hydrologic indicators. This includes visual observation of inundation,
saturation within 12 inches of the surface, watermarks, drift lines, sediment
' deposits and/or wetland drainage patterns. This visual inspection will be
made on a bi-weekly basis during the first two months of the growing season.
' Documentation will include taking a photograph of each plot center and two
additional photographs of each plot facing north and south.

For comparison, a sixth well will be installed within an existing bottomland
hardwood wetland system (Figure 10) and used as a reference for monitoring
groundwater fluctuations within the area. Groundwater and surface water
data will be documented for the reference area following the same methods
described above for documenting hydrology in the wetland creation area.

4.2.3 Probability of Success
The proposed plan has been written and reviewed by both Newkirk Environmental,
Inc. and The Triangle Group. Both consultants have surveyed the proposed site and
' believe the proposed creation site will be successful and will adequately compensate
for the wetland functions and values that will be impacted by construction of the
project.
4.2.4 Success Criteria
Success criteria for the vegetative and hydrologic components of the creation area
' will be determined using the reference sites and the following criteria. For
vegetation, the goal of the mitigation is to create a wetland ecosystem with
' comparable species composition and diversity to the existing wetland "W/X".
Considering this, the site will be considered successful and the monitoring complete
' if, at the end of the five-year monitoring program, the survival rate of planted tree
species is at least 320 planted and volunteer trees per acre. (Acceptable volunteer
' species will be defined as indigenous hydrophytic tree species, excluding those in
17

0
' the genus Pinus, Liquidambar, and Acer). Hydrologic success will be determined
by the establishment of wetland hydrology (saturated within 12 inches of the
surface, ponded or flooded) for at least twenty-two (22) days of the growing season.
' The growing season as published in the Soil Survey of Hertford County, 1984, is
determined to be from March 28 to November 7.
4.2.5 Contingency
' If, at the end of the monitoring program, success criteria have not been met for
either the vegetative or hydrologic components, the applicant will consult with the
' US Army Corps of Engineers and other appropriate state and federal agencies to
determine specific causes and appropriate remedial actions. Review of specific
' causes resulting in success criteria deficiencies may include: hydrologic influences,
plant mortality, vandalism, animal depredation, or invasion of nuisance plants.
If significant problems are identified prior to the end of the monitoring program, US
Army Corps of Engineers regulatory agency personnel will be consulted regarding
the advisability of remedial action at that time. Remedial action may include
' replanting, additional grading and continued monitoring. It is the intent of the
applicant to obtain the success criteria; however, the applicant cannot be responsible
' for acts of god or natural disasters, which may undermine or preclude success. In
the event of such acts or disasters, Nucor will immediately coordinate with the
' appropriate state and federal agencies for proper actions, if needed.
' 4.2.6 Timing and Schedule
implementation of the mitigation plan for the creation site will occur shortly after
' issuance of the necessary permits on a schedule based upon the growing season.
Such a schedule will promote the greatest success rates. Excavation and grading
activities will occur at the end of the first growing season following issuance of the
necessary permits. This will minimize establishment of competitive vegetation
prior to planting the desired seedlings. Planting of seedlings will occur during the
18

r
L7

1

10
dormant season immediately following excavation activities. Monitoring will then
follow the schedule in section 4.2.2.
4.3 Preservation of Off-Site Acreage
As a further compensatory mitigation measure, Nucor has agreed to preserve 150 acres of
high quality bottomland hardwood riparian forest adjacent to the Chowan River (Figure 2 &
2A). The proposed preservation site is similar in composition to the riparian wetlands in and
near the Nucor site. In an undisturbed and protected state, the preservation of this riparian
buffer area will maintain the high values and functions of the protected site and continue to
enhance the adjacent Chowan River system.
obtained a signed agreement on July 14, 1999 to purchase this land.
The 150-acre site is currently owned by Mr. Jimmy Early and Ms. Ann Stevens. Nucor
On July 12, 1999, Newkirk Environmental, Inc. completed surveys of the 150-acre riparian
wetland to document existing conditions (Appendix 4). This was completed by cruising the
shore line and establishing random 30 foot diameter plots at three locations along the river's
edge and a fourth plot in the northern corner of the site accessed from high ground: At each
location, all vegetative species within the plot were identified and documented in a species
list. The following species were identified as occurring most commonly or as dominants:
" ' T C O
li
a. T aPUN S SHRUB _
S' R
_
Cypress (Taxodium Tupelo Netted Chain Fern
distichum) (Woodwardia aerolata)
Red Maple (Acer Rubrum) Sweet gum Royal Fern (Osmunda regalis)
.Black gum (Nyssa sylvatica) Red Maple Sphagnum moss (Sphagnum
spp•)
Tupelo (Nyssa sylvatica var. Red Bay (Persea borbonia) Short-bristle Beakrush
biflora) (Rhynchospora corniculata)
Water Oak (Quercus nigra) American holly (Ilex opaca) Giant cane (Arundinaria
gigantea)
19

117

y

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0

10
Sweet gum (Liquidambar Wax myrtle (Myrica cerifera) Arrow arum (Peltandra
styraciflua) vir inica
Green Ash (Fraxinus Water Oak Lizard's tail (Saururus cernuus)
pennsylvanica)
Coast pepper-bush (Clethra False-nettle (Boehmeria
E alnifolia) c lindrica
Additional data and observations collected during plot surveys of the site included soil
characteristics and inundation/saturation indicators. Soil samples match the description of
Dorovan soil, black peaty muck (0-24 inches +), which is listed as hydric in Hertford County.
Soils are saturated to the surface. Regional indicators of soil saturation, including oxidized
rhizospheres, and sulfidic odor are common. Additionally, buttressed and multiple trunks are
also present. Indications that the natural wetland is subject to periodic levels of flooding
include matted leaf litter and water marks at approximately 12 inches above the surface. As
documented in the enclosed photographs, at least four Osprey (Pandion haliaetus) nests are
present within the preservation site.
Under this plan, Nucor will donate the property via a fee simple title transfer to the North
Carolina Wetland Restoration Program, promptly after issuance of the 404/401/CAMA/
Section 10 permits. The North Carolina Council of State in a meeting on November 3, 1999
approved accepting the 150-acre tract for preservation through the North Carolina Wetland
Restoration Program. This action permanently will prevent any future, negative impacts
(such as timber harvesting) to the preservation site.
4.3.1 Fisheries Functions of Preservation Area
The 150 acres preservation site of "off-site" bottomland hardwoods is part of the
aquatic ecosystem of the Chowan River because of the semi-permanent flooding
associated with the cypress-tupelo forest. In contrast, the location where Section 10
impacts will occur at the Nucor site is a steeply graded cutbank that has a narrow
eroding bottomland hardwood edge. The difference in the quality of the two habitats
for finfish is worthy of comparison.
20

1
4.3.2 Preservation Area Quality
The value of bottomland hardwood ecosystems to finfish is dependent on the time
' and length of flooding, the amount of permanent water during the low-water season,
and the characteristics of the fish populations. The makeup of the bottomland
' hardwood forest zones that stay saturated for longer periods of time are therefore
very important in determining the size and the makeup of floodplain fish
' populations. Fish populations are dependent upon the forested areas for their food
production, feeding, spawning areas, and rearing of young. In turn, the existence of
' the bottomland hardwood forests depends upon the hydroperiod produced by the
water flows in the permanent-water areas and the dissolved and particulate
' constituents carried by these flows. Thus the two must be considered to be part of
the same ecosystem. One difference is that in one case the end product is trees and
' the products associated with them, while in the other case the end product is fishes
and the products and recreation associated with them. One does not usually refer to
fish as part of bottomland hardwood forest ecosystems, but the two are inextricably
related. Fish and the semi-permanently flooded cypress-tupelo where they reside for
' part of the year are as much a part of the bottomland hardwood forest ecosystems as
are the trees commonly associated with them. Therefore, the viability of fish
' populations in permanent waterbodies located in bottomland hardwood ecosystems
cannot be isolated from the productivity and quality of adjacent floodplains.
There are little to no areas of hardwoods that are permanently inundated at the (pre-
development) Nucor dock location. Accordingly, recruitment and production of fish
populations should be considerably greater in the preservation site. Fisheries
production can be considered a continuum that expands with the width of the water's
edge through low elevation bottomland hardwood stands. Concomitantly, limitations
in access to floodplain habitat may limit fishery productivity. As floodwaters rise
and recede, an edge of shallow water migrates across the floodplain. It is this
shallow zone of the shifting water's edge that houses the highest fishery production
21

' at any given time. Therefore, the values assessed in our analysis must be considered
transient in the steep edge of the Nucor site versus the considerable values
attributable to the shallow-water areas associated with the preservation site (see
' Fisheries Workgroup Report. IN: Gosselink, et al. 1990. Ecological Processes and
Cumulative Impacts: illustrated by bottomland hardwood ecosystems).
4.3.3 Effects of Clearcutting on Breeding Bird Communities of Bald Cypress-
Tupelo Wetlands
In order to assess the value of the Nucor cypress-tupelo bottomland hardwood
preservation as viable wetland mitigation, it must be considered in the realm of what
key values would not be present if it were clearcut by use of a helicopter. By the
' early 1980's there was a certain and predictable decimation of some of the most
extensive cypress-tupelo habitats that were previously "inaccessible" using
' conventional harvesting technology. With the advent of small-ship helicopter
logging and river barging, cypress-tupelo stands are being clearcut in random patches
and sizes (depending on ownership patterns) fragmenting the habitat and taking its
toll on interior breeding bird species. In the southeastern U. S. alone, the bottomland
hardwood resource has an estimated stumpage sale value of $130 million annually
(Lea, 1988). One of the most commercially important assemblage is SAF type 102,
' Baldcypress-tupelo (Eyre, 1980). This forest type is classified by the National
Wetlands Technical Council as occurring in Bottomland Hardwood Zone II, which is
' characterized by nearly permanently inundated and saturated substrate (Larson et al.,
1981).
One of the key values of cypress-tupelo wetlands is the ability to support high
' densities of breeding birds. Dickson (1978) found that bottomland hardwoods
supported two to four times higher breeding birds than in adjacent upland forests.
' Blem and Blem (1975) noted that both birds and small mammals of floodplains had
higher density, biomass, and standard metabolism than similar populations in upland
areas. It is generally assumed that without intact tracts of cypress-tupelo that many
22

' species would disappear or become rare. According to Brinson et al. (1981), 80 of
the 276 species listed as threatened or endangered by the U.S. Fish and Wildlife
Service in 1980 were partially dependent on this habitat. However, it wasn't until a
' 1987 study conducted by Dr. Lea's graduate, Laura Mitchell, at NC State University,
that the relationship between clearcutting and breeding bird communities in cypress-
tupelo swamps was defined. As a secondary part of the same study, bird community
parameters were defined across an age distribution of intact cypress-tupelo stands.
Previous to this study there was no research that specifically addressed the effects of
timber management activities on bird communities of cypress-tupelo forest types.
These studies addressed the potential conflicts associated with the use of a specific
bottomland hardwood forest type for timber production and the provision of habitat
' for breeding bird communities. The first study on the Tensaw River compared the
breeding bird species abundance, diversity, and richness of three habitat types: first-
year helicopter logged clearcut, forest-clearcut edge, and the 70-year-old uncut
reference stand. The second study was located on the North Santee River and
measured breeding bird parameters in stands aged 5, 12, 24, 31, and 127 years to
determine the modulation rate of long-term habitat loss associated with clearcutting.
Results indicated 127-year-old stand supported the highest numbers of birds and the
' highest number of habitat specialists. Bird communities seemed to recover rapidly in
the initial successional stages after clearcutting, but complete recovery seemed to be
' slow and gradual. Recovery of the initial densities and diversities of breeding birds
occurs sometime after 30 years. Although there was a temporary introduction of
' disturbance-related bird species in the clearcut forests, this substitution must be
weighed against the value of retaining species adapted to extensive cypress-tupelo
' swamp forests with large diameter trees and high canopy. Retaining older trees
along the river's edge provides perching and nesting sites for raptors, especially
' ospreys. The white-breasted nuthatch, yellow-throated vireo, and yellow-throated
warbler are passerine species requiring older-growth forests. The key conclusion of
' this study was that retention of mature forest preserves is essential for maintaining
23

avifauna in this forest type. Mature forests provide the highest numbers of birds and
a high number of habitat specialists. The Nucor wetland preservation essentially
removes the possibility of a commercial clearcut on this 150-acre tract, and will
allow this timber to mature and support a wide diversity of plant and key avifaunal
' species dependent on large unbroken blocks of mature cypress-tupelo. This
preservation will permanently buffer this portion of the Chowan River bottom from
commercial clearcutting of cypress-tupelo based on economic conditions, logging
technology and/or private landowner incentives.
' 5.0 ADDITIONAL ON-SITE MITIGATION
In addition to the compensatory mitigation described above, the applicant intends to provide
additional voluntary enhancement to on-site wetlands and stormwater ponds through buffers and
bioengineering.
5.1 On-Site Preservation
As additional voluntary mitigation, 14.87 acres of on-site wetlands will be left undisturbed
and protected under restrictive covenants (Appendix 7). The wetlands to remain have been
identified by Newkirk Environmental, Inc. and The Triangle Group as being those wetlands
with the highest functions and values. Nucor will protect these remaining wetlands with
' associated 100-foot buffers as shown on revised site plans (Figure 1).
' 5.2 Enhancement and Bioengineering of Stormwater Ponds
Nucor proposes enhancement and bioengineering of on-site stormwater ponds to maximize
' stormwater buffering and purification and to stabilize water flows to downstream wetland
areas.
Nucor's wet detention ponds are designed to provide water quality benefits to downstream
' wetlands and waters. They are over-designed in terms of stormwater retention and are
configured to provide significant removal of suspended solids, nutrients, and pollutants. They
' will maintain a permanent pool of water designed for a target sediment removal rate at or
24

above 90/o forponds Al B 1 and C l. The ponds will hold runoff that results from a 10-year
°
10 24-hour period rainfall event and release this water over a period of several days. As a further
public interest review mitigation measure (i.e., not as part of formal 404(b)(1) mitigation),
' Nucor has elected to design a littoral shelf around the perimeter of these ponds, set at a 6:1
slope, starting at the permanent pool elevation and continuing two feet below water level
' (Figure 9). These designs should result in a stormwater pond system where most suspended
solids, nutrients and pollutants attached to sediment are allowed to settle out of the water, and
' should release water at a rate such that downstream erosion is lessened or eliminated.
' The presence of perimeter shelves will allow for the establishment of vegetative areas that
provide enhanced pollutant removal, wildlife and waterfowl habitat and protect the shoreline
' from potential erosion. As part of this elective public interest mitigation measure, Nucor will
vegetate the shelves of ponds Al, B1 and Cl. Establishment of a stable vegetative
community will have a direct relation to replacing lost filtration values and functions within
impacted drainage ways. The shelf areas proposed to be planted are:

Pond Al 1.13 acres
' Pond B 1 0.79 acres
Pond CI 0.51 acres
' TOTAL 2.43 acres
' There are many benefits of wet detention ponds over other stormwater measures. For
example, dry detention basins are less efficient in removing suspended solids and other
' pollutants (US EPA, 1983; Metropolitan Washington COG, 1983) and hold little aesthetic
value (Maryland DNR, 1986). Wet detention ponds are also appropriate in areas where
' infiltration is impractical due to low infiltration rates of the underlying soils. In addition to
water quality benefits, wet detention ponds can reduce the peak runoff rate from the
developed site and better control downstream erosion (Stormwater Best Management
Practices, NC DENR, Division of Water Quality, Water Quality Section, reprinted July 1998).
The ponds are a requirement under the stormwater management plan and may require
25

'
periodic maintenance to meet stormwater plan requirements. Therefore, the proposed shelves
will not be tied to any restrictive covenants. Finally, wet detention ponds can serve as a water
source to reduce the potential for desiccation of downstream wetland areas.

5.2.1 Establishment of Vegetation within Shelves
' Following the construction of each of the three wet detention ponds, the applicant
proposes to vegetate each of the shelves with indigenous aquatic/wetland
herbaceous species. Under the stormwater management plan, much of the area
within these shelves should be inundated for extended periods, if not permanently.
' Based upon these conditions, the following species are proposed to be planted:
' Pickerelweed (Pontederia cordata)
Soft rush (Juncus effusus)
Arrow Arum (Peltandra virginica)
Lizard's tail (Saururus cernuus)

Individual plants of these species will be manually planted in the shelf areas on 18
' spacing. Fertilizer packs may be used to enhance plant growth. Species will be
planted according to acknowledged water tolerances and anticipated water levels on
' each shelf.
' 5.2.2 Vegetation Maintenance
The goal of vegetative shelves is to provide a vegetative community that will
' enhance wildlife habitat and improve pollutant reduction through uptake of nutrients
by the vegetation. Successful accomplishment of the planting goals will be
' determined by the establishment of vegetative shelves that have 75% aerial
coverage within the three ponds. Establishment of a vegetative community within
' the shelf areas will be documented through a voluntary monitoring program.
Monitoring is proposed to occur six months following planting and at the end of the
next full growing season.
26

Twice during the first year after planting, random plots will be established at 300-
foot intervals along the perimeter of each pond and shelf area. Within each plot,
' species composition and density will be documented within a 3-foot radius of the
plot center. Each species present will be identified at least to the genus. Estimates
' regarding the percent coverage of each species and of the total plot coverage will
also be made. Collected data, including photographs of the plot centers and to the
north and south, will be compiled and included in the annual Compensatory
Monitoring Reports to be submitted to the appropriate agencies.
Nucor will strive to maintain the vegetative shelves for as long as the stormwater
' ponds are in active use. If, at any time during the active use of the ponds it is.
necessary to perform maintenance activities or expansion in the ponds, any
' vegetated shelves that are temporarily impacted will be re-vegetated according to
the original planting plans, subject to state agency stormwater approvals.

u
n
0

19 27

REFERENCES
Blem, C.R. and L.B. Blem. 1975. Density, biomass, and energetics of the bird and mammal
' populations of an Illinois deciduous forest. Trans. Ill. Acad. Sci. 68:156-164.
Brinson, M.M., A.E. Lugo, and S. Brown. 1981. Primary productivity, decomposition and consumer
' activity in freshwater wetlands. Annual Review Ecol. and Systematics. 12:123-161.
Dickson, J.G. 1978. Forest bird communities of the bottomland hardwoods. Pp. 66-73 IN: (R.M.
' DeGraaf, ed.) Proceedings of the workshop: Management of southern forests for nongame birds. US
Department of Agriculture, Forest Service, Atlanta, GA. GTR/5E-14.
' Eyre, F.H. (Ed.). 1980. Forest cover types of the United States and Canada. Society of American
foresters, Washington, DC.
' Kadlec, R.H. 1979. Wetlands for tertiary treatment. IN: P.E. Greeson, J.R. Clark and J.E. Clark,
eds. Wetland Functions and Values: The State of Our Understanding. American Water
Resources Association. Minn. MA. Pp. 490-504
Mitsch, W.J., M. Straskruba and S.E. Jorgensen, eds. 1988. Wetland Modeling. Elsevier Science
Publishing Co., Inc. NY, NY.
y Hammer, D.A. 1989. Constructed Wetlands for Wastewater Treatment. Lewis Publishers.
Chelsea. MI. 831 pp.
Larson, J.S., Bedinger, M., Bryan, C., Brown, S., Huffman, R., Miller, E., Rhodes, D, and B.
Touchet. 1981. Transition from wetlands to uplands in southeastern bottomland hardwood forests.
' Pp. 9-59 IN: National Wetlands Technical Council. Bottomland Hardwoods Wetlands 9 Workshop
Report. US Water Resources Council. Washington, DC.
' Lea, R. 1988. Management of eastern U.S. bottomland hardwood forests. In: Hook, D.D. (ed), The
Ecology and Management of Wetlands. Vol. 2: Management, Use and Value of Wetlands. Timber
Press, Portland, OR.
' Hammer, D.A. 1992. Designing constructed wetlands systems to treat agricultural nonpoint
source pollution. Ecological Engineering. 1(1/2):49-82.
' Mitsch, W.J. 1992. Landscape design and the role of created, restored and natural riparian
wetlands in controlling nonpoint source pollution. Ecological Engineering. 1(1/2):27-48.
Rodgers H.H. and A. Dunn. 1992. Developing design guidelines for constructed wetlands to
remove pesticides from agricultural runoff. Ecological Engineering. 1(1/2): 83-96.
' U.S. Environmental Protection Agency. 1990. Water quality Standards for Wetlands. National
Guidance. Office of Water Regulations and Standards. US EPA. 440/5-90-011.
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APPENDICES

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1 IMPACTED WETLAND
CHARACTERISTICS
2 EVALUATION OF
MITIGATION SITES
U. S. ARMY CORPS OF ENGINEERS
3 WILMINGTON DISTRICT
COMPENSATORY HARDWOOD
MITIGATION GUIDELINES (12/8/93)
PHOTOGRAPHS OF
PRESERVATION SITE AND
REFERENCE PLOTS
5 SOIL SURVEY
HERFORD COUNTY, N.C.
STORMWATER PERMIT
APPLICATION CALCULATIONS
RESTRICTIVE COVENANTS
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A Description of Impacted Drainage-ways
and
Functional Wetland Features of Stormwater Ponds
on the
Nucor - Hertford County Plate Steel Mill Site
By Russ Lea, Ph.D.
Drainage-way Description
Wetland impacts within the Nucor industrial site are confined to the upper limits of
three riparian drainage-ways that have been identified as jurisdictional wetlands. These
drainage-ways are found in the uppermost landscape position and feed directly into well
defined branch bottom wetlands at lower elevations. These drainage-ways function as
intermittent tributaries and serve more as upland connections to the branch bottom wetlands
and downstream aquatic habitats. They are not high performing wetlands that provide
values, such as, flood desynchronization, organic matter accumulation, sedimentation
accumulation, groundwater recharge and denitrification, because they lack the general
features of alluvial forested wetlands possessing backwater drainage channels, floodplains,
anaerobic soils and discrete water bodies.
Productive riparian-wetland complexes evolve in response to dynamic interactions
between the channel and the floodplain. Since these drainage-ways are longitudinal wetlands
at the upper end of the watershed, they possess little or no floodplain. Although riparian
wetlands are generally regarded as among the most productive ecosystems, Brown (1981)
indicates that high productivity characterizes only those riparian systems that have prolonged
lateral hydrological interaction with a floodplain. The sloping topography of the drainage-
ways on the Nucor site cannot support prolonged wetland hydrology on a lateral floodplain
and therefore function primarily as discharge channels that convey water only when rainfall
exceeds the capacity of the soil infiltration. Odum (1979) recognized the most productive
riparian wetlands are those that do not undergo abrasive flooding within sloping topography
but are those subject to annual flooding from lateral water movement on nearly horizontal
floodplains. Welcomme (1976) also demonstrated a strong positive correlation between
floodplain area and productivity of riparian areas.
Not only do the hydrological conditions markedly influence structural and functional
attributes of riparian wetlands, but the wetlands themselves regulate the hydrology (Conner
and Day, 1982). Since the delineated wetlands of the Nucor drainage-ways are mostly the
channel proper, then it is obvious that flooding occurs across upland habitats rather than on
wetlands. Since the topography is too incised to support floodplains adjacent to the drainage-
ways, there are no natural levees formed to impede the movement of surface waters back to

the river (e.g. nominal flood storage). Groundwater aquifers are not recharged during
flooding events because of the lack of adjacent wetlands, and water conveys quickly into
' branch bottom wetlands via the surface water drainage-ways. The lack of lateral movement
of water onto adjacent wetlands means that there are no still water areas to structure the
habitat or the trophic conditions found in most other riparian wetland systems. Floodborne
sediments and nutrients released in floodwaters cannot inundate the soils at a frequency to
support primary wetland functions as a nutrient "sink." One of the most significant intrinsic
values of riparian wetlands is their tight nutrient cycles because nutrients are adsorbed on the
' floodborne sediment particles and deposited on adjacent floodplains (Brinson, 1977;
Wharton et al., 1982; van der Valk et al., 1979; Furtado and Verghese, 1981). The Nucor
' drainage-ways are also well-oxygenated, and their topography is such that anaerobic
conditions do not develop upon inundation - significantly limiting denitrification processes
and nutrient transformation (Ethenngton 1983).
Since the delineated wetlands on the Nucor site are generally confined to drainage-
ways and have limited wetland vegetation flooded by adjacent waterways, one has to wonder
' if some of the key wetland habitat functions are supported. The richness of wetland habitat is
often a virtue of the hydrologic regime and diverse plant communities that provide shelter,
cover, food sources, and breeding areas. The drainage-ways are not flooded for any
significant length of time and do not have diversified plant communities that commonly
support the larval stages of fish, aquatic insects, and amphibians characteristic of fully
diversified wetland habitats.
' In summary, the three "core factors" -hydrologic energy, hydroperiod, and nutrient
supply-which are fundamental for distinguishing the value of a wetland (Lugo et al. 1988),
are not at the optimum levels to support high value wetlands at the Nucor site. In considering
' a site-specific impact, it is easy to overlook the extent to which these wetlands are dependent
on forces outside their boundaries. With the ever rapid development of the adjacent uplands,
these core factors will become even more variable. For example, drainage-way wetlands will
' depend on catchment basins to provide the hydraulic energy of water flow and to transport
nutrients in suspended sediments to the down stream branch bottoms. In this altered
landscape, the catchment basins are usually least dependent on outside forces and are thus
' most amenable to wetland stability (Winters, 1981). In the altered landscape, catchment
basins can duplicate the existing energy signature of the drainage-ways and can serve to
modulate the influences of the local physical environment (Brinson and Lee, 1989).
Wetland Functions of Stormwater Ponds
' One key element of surface water quality protection is the management of stormwater
runoff. Stormwater pretreatment (e.g. stormwater ponds, swales, and buffers) is essential to
minimize pollutant and sediment loading to natural surface waterways and wetlands.
' Pretreatment can reduce nutrient and sediment loadings. Pretreatment also absorbs the
"shock" from the first flush effect of runoff when pollutant concentrations are highest from

1
impermeable surfaces. One of the major wetland issues presently being discussed is the
relationship between wetlands and stormwater structures in developing landscapes. Land
developers and surface water managers would like to maximize the flood attenuation
functions that natural wetlands provide but also realize that stormwater structures can make
excellent wetland surrogates and can protect valuable down-stream wetlands if designed
correctly.
Recently there has been a growing recognition of the ecological and aesthetic values
' that stormwater retention facilities provide. Research over the past two decades (Office of
Technology Assessment, 1984; Zedler and Kentula, 1986; Kusler and Riexinger, 1985) has
documented that such facilities if designed with wetland features can perform:
1. Water quality functions, such as sedimentation and the uptake and/or
transformation of nutrients, heavy metals and anthropogenic substances;
' 2. Hydrologic functions, such as flood storage and desyncronization, modification
of groundwater discharge, and streambank stabilization through attenuated flows;
and
3. Food chain support functions, or the contribution of wetlands to the
environmental requirements of organisms, such as food and habitat for fish,
waterfowl, amphibians, endangered species, and other species.
' The understanding of the significance of these multiple functions has led to a growing
recognition that wetland features designed into stormwater retention basins serve as viable
ecological systems within the developing landscape. In spite of this new understanding,
degradation of adjacent wetlands often continues without the benefit of these pretreatment
surrogates. Surface water bodies downstream from stormwater retention basins depend on
' nutrient regulation, sediment supply and control, and other water quality improvement
functions to maintain ecosystem and riparian balance. Downstream systems clearly benefit
from stormwater management activities upstream, particularly when those activities are
' conducted as part of basin-wide management efforts. For example, accelerating stormwater
flows in developing basins can cause erosion problems in streams, particularly when flows
are uncontrolled. Scouring of stream substrates results in fish egg mortality, degradation of
instream habitat quality, and removal of floodplains and vegetation. As storm flow energy
recedes, the scoured sediments are deposited, reducing channel capacity, silting spawning
beds, and suffocating benthic organisms.
' The Nucor stormwater ponds were designed along the basic principles for
maximizing wetland functions (Canning, 1988; Kulzer, 1989). They include the following:
1. Proper hydrological parameters have been optimized to ensure success of the
pond and to optimize vegetation growth and pollutant attenuation. The standing
' water pool (during the seasons in which water quality benefits are desired) can be
adjusted with flashboard risers to range between 0.5 ft and 3.0 ft. (Schueler,
1987).
' 2. To minimize turbulence and short-circuiting into natural wetlands, stormwater
discharge to the adjacent drainage ways is distributed by splash-ways using

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stabilized rock and promoting sheetflow rather than single point discharge that
results in stream scouring and reduced water quality.
3. Promoting residence time of runoff over several days enables precipitation of
the finer particulates, contact time with substrate, adsorption of nutrients, and
promotion of biomass interaction with floodwaters. Retention times are targeted
to over a week for intermittent storms in order to control particulate pollutants and
for adsorption of soluble pollutants (USEPA 1986).
4. Dense-growing wetland species will be planted along pond edges to increase
sedimentation, and to improve water quality treatment. Species will be planted
that will provide rapid stabilization and colonization of the soils on the designed
shelves in the ponds. Planting mixed stands of vegetation will provide the best
overall sedimentation and nutrient efficiency. Plants will not be extracted from
existing wetland donor sites because of the significant negative impact on those
sites. Plants will be obtained from a local native plant nursery. Relatively
constant water levels in the ponds will be maintained over long periods of time to
promote vegetative growth. Shallow water areas will be used to promote the
growth of emergent and submerged vegetation, which also results in higher
growth of algae and bacteria important for food-chain support. The success of the
planting program will be assessed annually to ensure colonization by desirable
species and to assess invasion of noxious species.
5. Wildlife use in stormwater ponds can occur disproportionately to other more
available habitats because the major life requirements for many species are found
in these areas (Brown, 1985). Many species show a preference for these habitats
even though their survival may not be dependent on them. The easy availability
of food, decreased predators, and rich vegetation can magnify the use of wildlife
of stormwater ponds.
In summary, wetlands are those areas that are inundated or saturated by surface or
ground water at a frequency and duration sufficient to maintain saturated conditions. These
conditions can exist in the preexisting Nucor site wetlands or the constructed stormwater
systems. The soil, benthic, vegetative, and species requirements in stormwater ponds are
often similar to those found in natural wetlands, especially if such features are designed into
the project. Such stormwater ponds have been shown to influence the character and health of
downstream wetland ecosystems, as reflected by species composition and richness, primary
productivity, organic deposition and flux, and nutrient cycling (USEPA, 1988). In general,
water movement through stormwater pond wetlands has a positive impact on the ecosystem.
Rather than wasting water, upland stormwater retention appears to save water and thus
promote increased regional wetland productivity indirectly.
References
1. Brinson, M.M. 1977. Decomposition and nutrient exchange of litter in an alluvial swamp
forest. Ecology. 58:601-609.

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2. Brinson, M.M. and L.C. Lee. 1989. In-kind mitigation for wetland loss: Statement of
ecological issues and evaluation of examples. IN: Freshwater wetlands and wildlife. No.
61. pp 1069-1085.
3. Brown, S. 1981. A comparison of the structure, primary productivity, and transpiration of
cypress ecosystems in Florida. Ecological Monographs. 51:403-427.
4. Brown, E.R. 1985. Effects of wetlands on quality of runoff entering lakes in the Twin
Cities Metropolitan Area, Minn. USGS Survey Report 85-4170.
5. Canning, D.J. 1988. Urban runoff water quality: Effects and management options.
Shorelands Technical Adisory Paper Number 4, Second Edition WA Dept. Ecology,
Olympia, WA.
6. Conner, W.H., and J.W. Day, Jr. 1982. The ecology of forested wetland in the
southeastern United States. Wetlands Ecology and Management. India. pp. 69-87.
7. Etherington, J.R. 1983. Wetland Ecology. Edward Arnold Publishers Ltd. London.
8. Furtado, J.I., and S. Verghese. 1981. Nutrient turnover in a freshwater inundated forest
swamp. Angewandte Limnologie. 21:265-315.
9. Kulzer, L. 1989. Considerations for the use of wet ponds for water quality enhancement.
Municipality of Metropolitan Seattle, Office of Water Quality, Seattle, WA.
10. Kusler, J.A. And P. Riexinger. 1985. Proceedings, National Wetlands Assessment
Symposium. June 17-20, 1985. Portland Maine. State Association of Wetland Managers,
Inc.
11. Lugo, A.E. 1988. Fringe Wetlands. Forested Wetlands. Elsevier, Amsterdam.
12. Odum, E.P. 1979. Ecological importance of the riparian zone. Strategies for protection
and management of floodplain wetlands and other riparian ecosystems. US For. Serv.
Gen. Tech. Rep. WO-12, WA DC. pp 2-4.
13. Office of Technology Assessment. 1984. Wetlands: Their use and regulation. US Printing
Office. WA DC. OTA-0-206.
14. Schueler, T.R. 1987. Controlling urban runoff. A practical manual for planning and
designing urban BMPs. Metropolitan Washington Council of Governments, WA DC.
15. US Environmental Protection Agency, 1986. Methodology for analysis of detention
basins for control of urban runoff quality. Nonpoint Source Branch. EPA-440/5-87-001.
16. US Environmental Protection Agency, 1988. Design manual for constructed wetlands
and aquatic plant systems for wastewater treatment. EPA/625/1-88/022.
17. Van Der Valk, A.G, C.B. Davis, J.L. Baker, and C.E. Beer, 1979. Natural Fresh water
wetlands as nitrogen and phosphorus traps for land runoff. Wetland Functions and
Values: The state of our understanding. IN: P.E. Greeson, J.R. Clark, and J.E. Clark, eds.
Pp.457-467.
18. Welcomme, R.L. 1976. Some General and theoretical consideration on fish yields.
Journal of Fish Biology. 8:351-364.
19. Wharton, C.H., W.M. Kitchens, E.C. Pendleton, and T.W. Sipe. 1982. The ecology of
bottomland hardwood swamps of the Southeast: A community profile. FWS/OBS-81/37.
20. Winters, T.C., 1981. Uncertainties in estimating the water balance of lakes. Water
Resources Bulletin. 17:82-115.
21. Zedler, J.B. and M.E. Kentula. 1986. Wetlands Research Plan. USEPA. EPA/600/3-
86/009. NTIS Number PB-86-158-656/AS.

Nucor Steel - Hertford
Characterization of
Intermittent Stream Channel Impacts and Stormwater Ponds

The following is a general characterization of "waters of the United States" that are proposed to be
impacted as part of the development of the Nucor Steel - Hertford Mill. The characterization is
based upon field inspections of the site by biologists with Newkirk Environmental, Inc.
' Impacts within the Nucor Tract (excluding the utility corridor) are confined to the upper limits of
three linear drainages, which have been identified as jurisdictional "Waters of the United States".
Each of these drainages ultimately transition into narrow forested wetlands associated with, and
draining to, the Chowan River. In review of the difference between the upper and lower reaches of
these drainages, Nucor has made several revisions to site plans so as to avoid impacts to the lower
' reaches of these drainages where values and functions are greater. A majority of the proposed
impacts to the upper reaches of these systems are directly related to the construction of stormwater
detention ponds, associated with the mill.
The portions of the drainages proposed to be impacted are virtually without vegetation and are
characterized as temporarily flooded wet weather gullies. Following rainfall events, runoff from
adjacent land is collected in the gullies, temporarily inundates the sites, and is carried to the lower
elevations and eventually to the Chowan River. During dry periods, the gullies may maintain
minimal levels of saturation until collected water has been transferred or evaporated. It is not
' uncommon for the sites to be completely dry for extended periods. As a result of natural erosion that
occurs within the bottom of the gullies, very little organic material is present or able to accumulate.
Considering site conditions and characteristics of the identified areas, the primary functions of these
-gullies are short-term flood storage and the transport of stormwater. The natural gradient of the
' channels does not permit significant groundwater recharge or allow for extended periods of ponding,
which would permit settling of sediment or particulate.
' The stormwater ponds to be constructed as part of the mill facility are designed to perform the same,
and in most cases enhanced, hydrologic functions performed by the existing gullies that are to be
impacted. The three proposed ponds (A1, 131 and C1) are designed to have vegetated littoral shelves
that will provide water quality benefits to downstream wetlands and waters. As designed, each of
these ponds will provide enhanced abilities to remove suspended solids, nutrients and pollutants.
Additionally, each pond is designed to temporarily hold the runoff from a 10-year 24-hour rainfall
' event and release the water over a period of several days. Using this process, the downstream
wetlands and water will receive water but at a more controlled rate with less likelihood of erosion
' and/or sediment collection. Also, the water released will have accumulated in the ponds for some
period of time, thereby allowing sediments, nutrients, and pollutants to settle out thereby improving
the water quality.
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NEWKIRK
ENVIRONMENTAL, INC

' Summary of Mitigation Search
Newkirk Environmental, Inc.
July 19, 1999

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As part of the mitigation plans for Nucor Steel - Hertford County, Newkirk Environmental, Inc.
along with The Triangle Group completed comprehensive searches of a four county (Hertford, Gates,
Bertie and Chowan) area to identify potential restoration sites suitable and available for use in the
Compensatory Mitigation Plan for Nucor Steel - Hertford. Following are summaries of both
consultants regarding the results of these searches.
Newkirk Environmental, Inc.'s searches were completed in three phases:
1) Aerial reconnaissance by small plane;
2) Search of Hertford County "prior converted" sites; and
3) Review of Edenton Bay Restoration Project.
On March 12, 1999, Newkirk Environmental, Inc. and Nucor representatives flew the
Chowan River basin, both north and south of the project site, to identify potential mitigation
sites. Focus was placed on identifying potential restoration sites affected by ditching, road
construction, or filling. The results of this search found that the wetlands associated with the
Chowan River and adjacent lands are well defined and easily recognizable from the air. No
obvious sites with characteristics of impacts or potential restoration were identified.
Additionally, Newkirk Environmental, Inc. and The Triangle Group met with representatives,
county sponsors and landowners of the Edenton Bay Restoration project located in Chowan
County. The Edenton Bay Restoration Project is an ongoing effort to restore and enhance
functions and values of impacted wetland systems and protect high value systems in the area
of Edenton, North Carolina. Nucor explored the possibilities of becoming a partner with the
project as well as exploring opportunities of adding additional acreage and restoration sites
to the designated project area. Complexities associated with funding and structure of the
existing project make partnering difficult. A search for additional wetland restoration sites
to be added to the Edenton Bay project did not identify any areas that were available or
feasible.
Savannah, GA Office
340 Eisenhower Drive
Building 200, Suite 201
Savannah, GA 31406
[phone]
Facsimile: [phone]
E-Mail: NewkirkGA®ac,' -om
Charleston, SC Office
192 East Bay Street
Suite 201
Charleston, SC 29401
[phone]
Facsimile: [phone]
E-Mail: [e-mail]
Hendersonville, NC Office
300 N. Main Street, Suite 205
Post Office Box 2876
Hendersonville, NC 28793
[phone]
Facsimile: [phone]
E-Mail: [e-mail]

During the week of June 21-25, Newkirk Environmental, Inc. searched for and reviewed
potential restoration sites within Hertford County. This search was completed using soil
surveys and information, aerial photography and county mapping resources. Conversations
and meetings with the county Natural Resource Conservation Service (Mr. Greg Hughes)
' were conducted to learn of "prior converted" sites on record. Additionally, Newkirk
Environmental, Inc. staff reviewed ortho-photographs of the county. Sites identified by
either, or both, the county or the NRCS were visited in the field to make preliminary
' assessments of restoration potential. Only a few sites were identified as having potential and
upon a field review, it is the opinion of Newkirk Environmental, Inc. that none of the sites
is suitable or appear to be a strong candidate for successful restoration. The Triangle Group
has completed extensive searches and reviews of the sites identified by Newkirk
' Environmental, Inc. as well as 29 additional sites in Bertie, Gates and Chowan Counties. A
full description and discussion of each researched site is included in The Triangle Group
1 chart that follows:

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RESTORATION SITE SEARCH DETAIL CHART BY COUNTY
The Triangle Group, LLC
During the period of June 28 - July 16, The Triangle Group conducted a mitigation site search in areas of
Bertie, Chowan, Hertford and Gates Counties that are within approximately 12 miles of the Nucor plant
site in Hertford County. The search targeted agricultural sites in that area for the following reasons:
• Agricultural sites are often the most cost-effective sites to restore and have high rates of
success.
• The benefits to water quality from restoring such sites are well documented and defendable
from a regulatory standpoint.
Sites were located in each county using soils and aerial photography data, along with conversations and
meetings with state and local agencies and government data on the properties. After gathering data on the
sites, field reviews were completed to visually inspect each site. In some cases, the property owner was
contacted to request permission onto the property. Preliminary assessments made based on these visits
follow. For each site, the county, owner, acreage, soil types present and a determination of suitability is
give.
BERTIE COUNTY
Site # County Owner Tract # Acres Soils
1 Bertie Mr. Wood Beasley T49 20 Bibb
2 Bertie Mr. Howard Brown T623 4 Tomotle
3 Bertie Mrs. Ramona Miller T320 8 Tomotle
4 Bertie Mr. Earnest Evans T1096 15.2 Rains
5 Bertie Inez Robertson/Milton
Robertson T 4 18.8 Rains
6 Bertie Robertson Bros., Inc. T411 18.46 Pante o
Bertie Catherine Henry T110 6 Rains
7 Bertie D. L. Askew T20 12 Rains 77771

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Site Descriptions: Bertie
Site # Site Description
1 This site contains several drains that were once used as irrigation ponds and have since been
drained. These drains are not considered restorable due to their existing jurisdictional wetland
status. There are also problems with an existing center pivot irrigation system that uses these
areas as a travel lane.
2 Site 2 and 3 are very close together and were considered for their PC status and hydric soils.
After a field study, these sites were determined to have too much slope and divided the existing
farm fields severely for continued farming activities.
3 Site 3 also is quite isolated from existing drainages and adjacent wetland areas.
4 This site is considered too isolated from nearby drainages and is reverting back to natural
vegetation.
5 Site 5 contains Rains soils on the majority of the tract and contains the headwaters of a nearby
drain. Soils exhibit hydric characteristics such as low chroma and mottles. This site was not
selected since hydrological modifications would affect adjacent landowners and the site was not
contiguous with adjacent wetland areas.
6 This site contains a large ditched creek with adjacent Pantego and Rains soils. Soils are hydric
and the area is contiguous with a wetland drain. Several landowners hold this site. Therefore,
restoring it back to wetlands would require lengthy, and probably unsuccessful negotiation if just
one owner objected to the project.
7 This site has hydric soils and is adjacent to a large wetland drainage. However, this site has too
much slope and not enough acreage for mitigation requirements.
GATES COUNTY
Site # County Owner Tract # Acres Soils Description
1 Gates Fort Island -------- 5-10 Pactolus with - not suitable
(location) Ballahack inclusions
2 Gates Dou htie -------- 15-20 Icaria - not suitable
3 Gates Sherwood Eason -------- 5-10 Icaria inclusions - not for sale
4 Gates Todd Lewis T41, 200+ Various - not suitable
T1319 h drics
5 Gates Gurney Harrell T260 20.9 Ballahack - not for sale
6 Gates Charles Harrell T266 22.8 Ballahack - not for sale
7 Gates Todd Lewis T48 200+ Bladen - presently
unavailable
8 Gates Tim Plyler -------- 50+ Bladen - presently
unavailable
9 Gates Ellen Riddick T121 30+ Bladen - presently
unavailable
10 Gates Catherine Hofler T63 25+ Bladen inclusions - not selected
11 Gates Umphlett family T400 43+ Bladen inclusions - presently
unavailable

F.,

Site # Site Description (Continued)
12 Gates Ivey Locke T107 9+ Icaria - not for sale
13 Gates Sherwood Eason T25 21+ Roanoke, Torhunta - not for sale
14 Gates Mary Ellen Eure T277 26+ Roanoke - not for sale
15 Gates Mary Hall T591 50+ various - presently
unavailable
16 Gates Gerald Greene T240 24.05 Bladen - presently
unavailable
17 Gates Galen Swinson T324 30+ Roanoke - not selected
18 Gates Joseph Duke Harrell T261 14.08 Roanoke - presently
unavailable
19 Gates Herbert Skinner ---------- 15+ Bladen - presently
unavailable
I Site Descriptions: Gates

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Site # Site Description
1 This site has too few h dric soil inclusions and does not meet miti ation acre requirements.
2 Site 2 is not close enough to a drain and would affect the hydrology of adjacent landowners if
restored.
3 This site is not associated with any stream and is not for sale.
4 This site south of Gatesville is adjacent to a large bottomland wetland and is ditched. It was
learned that the owner is already restoring this tract due to an enforcement action by the USCOE
and it is not available for other work.
5 This PC site is ideal for wetland restoration and meets the mitigation acre requirements. A field
study showed that the site has hydric soils and is adjacent to a drainage and bottomland swamp.
Hydrological modifications would restore the wetland hydrology. Attempts to purchase were
made; the property is not for sale for any price.
6 This PC site is ideal for wetland restoration and meets the mitigation acre requirements. A field
study showed that the site has hydric soils and is adjacent to a drainage and bottomland swamp.
Hydrological modifications would restore the wetland hydrology. Attempts to purchase were
made; the property is not for sale for anrice.
7 This site has hydric Bladen soil and is located near a drainage. Hydrologic trespass concerns
may make the site unsuitable.
8 This site has hydric Bladen soil. The site is located near a drainage and Merchants Mill Pond. A
ossibili exists here, although the site is presently unavailable.
9 This site has hydric Bladen soil. The site is located near a drainage north of Merchants Mill
Pond. Numerous owners resent difficulty in acquisition.
10 This site has Bladen soil near Merchants Mill Pond state park, but there are too few hydric soil
inclusions.
11 Much of the land is composed of Bladen soils. 1 drained pine plantation is present. The
property is presently unavailable.

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12 Good site but learned after negotiations that the tract is not for sale.
13 Good site but learned after negotiations that the tract is not for sale.
14 Good site but learned after negotiations that the tract is not for sale.
15 An old drained and site. Presently unavailable.
16 Available hydrology is questionable.
17 Unlisted phone number, contacted property operator and inquired about possibilities. Presently
unavailable.
18 Possibility of hydrologic trespass in field to the south.
19 Available hydrology is questionable.
CHOWAN COUNTY
Site # County Owner Tract # Acres Soils
1 Chowan C.A. Perry & Son,
Inc. T239 19.3 Roanoke
2 Chowan George Jordan
(operator) T328 19.3 Roanoke
3 Chowan Rudolph Perry I T354 89.4 Roanoke
Site Descriptions: Chowan

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Site # Site Description
1 This site has Roanoke soils that are hydric but are precipitation driven. Rolling topography is a
concern here.
2 This site has Roanoke soils and could possibly work, although on-site creation is a better
alternative.
3 This site has Roanoke soils that are hydric but are precipitation driven and are not ideal for
wetland restoration.
I HERTFORD COUNTY
11 Site # County Owner Tract # Acres Soils Description 1'1

1 Hertford J.D. Flowers T1157 30+ Leaf - presently unavailable
2 Hertford E. W. Jones T292 17+ Leaf - presently unavailable
3 Hertford 11 owners/Bazemore T306 16+ Leaf - presently unavailable

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Site Descriptions: Hertford
Site # Site Description
1 Although precipitation driven, this site, which is on the upper portion of a 75 ac field could be
utilized without hydrologic trespass on the lower part of the field. Available hydrology is
questionable.
2 This site does not appear to demonstrate restorable jurisdictional hydrology.
3 Too many owners (11 counted in NRCS listing).

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CORPS OF ENGINEERS - WILMINGTON DISTM&10'" dK""ol
COMPENSATORY HARDWOOD MITIGATION GUMF+R LS (12/8/93)
1. IMPACT AREA / REFERENCE AREA EVALUATION
A. PHYSICAL CHARACTERISTICS
B. FUNCTIONS AND VALUES
C. IDENTIFY MITIGATION NEEDS IN ACCORDANCE WITH COEMMGATION POLICY
'
U. SPECIFIC GOALS/STRUCTURE DESIGN/SUCCESS CRITERIA
A. PHYSICAL CHARACTTRISTICS OF SITE
1. SOILS: SUITABLE TO SUPPORT TARGET PLANT SPECIES
a. PHYSICAL
' b. CHEMICAL
2. HYDROLOGY: SATURATED WITHIN 12 INCHES OF THE SURFACE, PONDED,
OR FLOODED AT LEAST 12.S% OF THE GROWING SEASON UNDER
i REASONABLY AVERAGE CLIMATIC CONDMONS
3. GEOMORPHOLOGY: SUITABLE TO MEET HYDROLOGY REQUIREMENT
s. CONTOURS
b. ELEVATION
a DRAINAGE / CONNECTION WITR SURFACE WATERS
B. 111OLOGICALIVEGETATIONAL CHARACTER15MCS OF SITE DESIGN
' i. SPECIES SELECTION: HARDWOOD SPECIES NATIVE TO AREA
2. NUMBERS OF INDIVIDUAL TREES: A MDi]% M OF 320 TREESIACRE
SURVIMG FOR 3 YEARS
3. UP TO 10% OF SITE SPECIES COMPOSMION MAY BE COMPRISED OF
' SOFTWOOD SPECIES
4. TREE COMPOSITION: MINIMUM OF 6 HARDWOOD SPECIES WITH NO
MORE THAN 20% OF ANY ONE SPECIES
III. SELECTION OF SITE
A. SUTTABUM OF LOCATION: ECOLOGICALLY ACCEPTABLE
B. SUFFICIENT SIZE TO SATISFY MITIGATION NEED
' C. PHYSICAL CHARACTERISTICS
1. HYDROLOGY
2. SOUS
3. SLOPE

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8. VEGETATION SAMPLE PLOT REQUIREMENTS
a. 4-3 ACRE MITIGATION SITE: MINIMUM OF TWO 0.0S ACRE SAMPLE
PLOTS/ACRE OF MITIGATION SITE
b. 3-10 ACRE MITIGATION SITE: MINIMUM OF ONE OAS ACRE SAMPLE
PLOT/ACRE OF MITIGATION SITE
c. GREATER THAN 10 ACRE MTIGATION SITE: MINIMUM OF ONE 0.05
ACRE SAMPLE PLOT/2 ACRES OF MITIGATION SITE
d. PLOT DATA MUST BE REPRESENTATIVE OF ENTIRE SITE OR
COMMUNITIES OF ENTIRE SITE
e. SAMPLE PLOT REQUMEMENTS TO BE ULTIMATELY DETERMINED ON
A CASE-BY-CASE BASIS
C. MONITORING WELL REQUIREMENTS
1. NUMBER, LOCATION, AND NSTALLA77ON TECHNIQUE TO BE DETERMINED
BY SITE CONDITIONS
2. ALTERNATIVE HYDROLOGY MONITORING
a. OBSERVATION/PHOTO DOCUMENTATION OF SATURATION AND/OR
INUNDATION
b. STREAM GAUGE DATA RELATED TO SITE ELEVATIONS (FLOODING)
V. TRACKING SYSTEM MOTirWRING
A. FINAL DESIGN SPECIFICATIONS: SUBMITTED PRIOR TO INITIATION OF
CONSTRUCTION
B. A6 BUILT REPORT: SUBMITTED WMH N 30 DAYS OF MITIGATION SITE
COMPLETION AND SERVES AS OFFICIAL NOTICE OF COMPLETION OF
MITIGATION CONSTRUCTION
1. FINAL ELEVATIONS
2. PHOTOGRAPHS
3. SAMPLE PLOT LOCATIONS
4. WELL AND GAUGE LOCATIONS (IF APPLICABLE)
S. PROBLEMS/RESOLUTION
6. OTHER INFORMATION AS DEEMED APPROPRIATE
7. PLANTING DESIGN
C. ANNUAL MONITORING
1. CONDUCTED AUGUST SEPTT.MBER OF BACK YEAR UNML VEGETA7WE
SUCCESS CRITERIA MET
2. REPORT SUBMITTED WITHIN 30 DAYS OF SITE MONITORING
a. PHOTOGRAPHS
b. SAMPLE PLOT DATA
c. WELL DATA (IF APPLICABLE)
d. PROBLEMS/RESOLUTION
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VI. REMEDIAL ACTION: DEVIATIONS FROM ACCEPTED MITIGATION PLAN MUST BE
COORDINATED WITWAPPROVED BY THE CORPS OF ENGINEERS
A. UNSUCCM.FAJL VEGETATION SURVIVAL
1. REPLANTING
2. SPECIES MODIFICATIONS
B. HYDROLOGY PROBLEMS
1. TOO WET
2. TOO DRY
C. VANDALISM
D. ANIMAL DEPREDATION
E. NUISANCE PLANT SPECIES
VII. PERFORMANCE BOND TO ENSURE COMPLIANCE WITH PERMIT MITIGATION
REQUIREMENTS
VIII. FINAL DISPOSITION OF MOPE, RTY/PERMANENCE OF INTENTIONS
A. CONSERVATION EASEMENT
B. DEED RESTRICTIONS
C. DONATION TO CONSERVATION AGENCIESIORGANIZATIONS
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IV. SPECIFIC CONSIDERATIONS
A. PHYSICAL SITE. PREPARATION REQUIREMENTS
1. HYDROLOGY
2. FERTILIZER NEEDS
3. pllULImE
4. DRAINAGE
5. ELEVATION
6. EROSION CONTROL MEASURES
B. VEGETATION REQUIREMENTS
1. SPECIES SELECTION: HARDWOOD SPECIES NATIVE TO AREA
2. NUMBERS OF INDIVIDUAL TREES: A MINIMUM OF 320 TREES/ACRE
SURVIVING FOR 3 YEARS
3. TYPE OF STOCK
a. BARE ROOT: PREFERRED
1) 1 YEAR OLD, 12 TO 18 INCHES HIGH
2) 1/4 INCH OR GREATER DIAMETER ROOT COLLAR
3) 4 OR MORE LATERAL ROOTS
4) HEALTHY
b. ROOT BALL: ACCEPTABLE
c. SEED: CONDITIONALLY ACCEPTABLE
4. AVAILABII.ITY
a. SEASON
b. NUMBERS
e. STOCK ORIGINILOGLSTICS
5. SOURCES OF STOCK: PREFERRED SOURCE(S) WITHIN 200 MUM NORTH OR
SOUTH OF SIZE
6. PLANTING REQUIREMi•JM
a. DENSITY OF PLAN 1NGS: MIKIMUM OF 320 TREESIACRE
b. SPECIES COMPOSITION: MINIMUM OF 6 HARDWOOD SPECIES WITH
NO MORE THAN 20% OF ANY ONE SPECIES
c. PLANTING TAME: DECEMBER THROUGH MARCH
d. PLANTING PROCEDURES: SITE SPFCIFIC, PROPER SILVICULTURAL
TECHNIQUES TO BE EMPLOYED
7. OTHER CONSIDERATIONS: SITE DISTRIBUTION OF SPECIES SHOULD BE
BASED ON SPECIES GROWTH RATE AND HYDROGEOMORPHOLOGY OF
TIM SITE
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Soil Survey of Hertford County, Map 9,
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NEWKIRK
GNVIRONMGNTAL. INC
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150 Acre preservation Site
Hertford County, NC

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Soil Survey Map
SCALE 1 inch = 2000 feet

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U. S. DEPARTMENT OF AGRICULTURE
Soil Conservation Service
Technical Guide
Section II-A-2
June 1991
HYDRIC SOILS
Hertford County, North Carolina
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Hydric codes (HC):
Vegetation codes (VC) :
1 = Hydric soils, only because of saturation for a
significant period during the growing season;
2 = Hydric soils that are frequently flooded for long or
very long periods during the growing season; and
3 = Hydric soils that are ponded for long or very long
periods during the growing season.
1 = Hydric soils that support woody vegetation under
natural conditions; and
2 . Hydric soils that do not support woody vegetation under
natural conditions.
IMPORTANT NOTES: (1) Hydric soils in this county cannot be farmed under natural conditions
without removing woody vegetation or hydrology manipulation. (2) Some map units and included soils
listed as hydric soils in this county may not meet the definition of hydric soils and wetlands because
the hydrology has been altered through drainage or other manipulations.
A. Map units that are all hydric soils or have hydric soils as a major component.
Map Unit
Symbol HC VC Map Unit Name

BB 1,2, 1 Bibb soils
3
DO 112, 1 Dorovan soils
3
LF 1 1 Leaf loam
Ra 1 1 Rains fine sandy loam
Ro 1 1 Roanoke loam
To 1 1 Tomotley fine sandy loam
We 1,2, 1 Wehadkee silt loam
3
Wn 1,2. 1 Wilbanks silty clay loam
3
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Hertford County
B. Map units with inclusions of hydric soils or have wet spots.
Map Unit Hydric Normal location
Symbol Map Unit Name Inclusion HC VC Inclusion
Ata Altavista fine sandy Tomotley 1 1 depressions
loam, 0 to 2 percent
slopes
Ln Lenoir loam Leaf 1 1 depressions
Rains 1 1 depressions
Ly Lynchburg fine sandy Rains 1 1 depressions
loam

Nucor Steel Hertford County
Stormwater Design Calculations
Basir: B2B
Using Pond C1
Basin CharacW(•jstics
Total Basin Area (Ta)= 3,780,137.• sf= 88.78 ac Percent Impervious ,;I)= 45.77 %
(falTaj
.mpervious Area ila)= 1,730,203 st= 35.72 ac
Permanent Pool Calculations (Pond fD
' Select Permanent Pool Depthz_ ^ .S ft 90% TSS Removal W,'O Vegetative Filter= 3.20.
From SPJDA Table Attached - 5' deep ? 45.77% Imp.
Permanent Prot Top Elevation- .:30.25; ft
' Bottorr, Elevation= 25.25; it
Top of Dike Elevation= 35;0'11
' Required Surface
Area (SA)= 20.964 sf= 2.78 ac Actual Surface Area
(TSSl100)"Ta Provided= -;4 1QA400. sf
(3.20!100)"86.78= 120,964 sf= 2.78 ac
Per. Pool Volume= 738:582 cf
1" Storm Volume (Pond C1)
Volume to be drawn down from 2 to 5 days.
' Runoff Coefficient (Rv)= 0.46 Win. 1" Storm Stage= 31.15 ft
(0.05+0.009*1)
(0.05+0.0C9*45.7 )= 0.46 in An
' 1" Storm Volume (Vel)= 3.34 ac-It 145,515 cf
(1 **Rv*Ta)
(0.083*0 46'86.78)= 3.34 ao-tt 145,516 cf
' Select orifice size to discharge runoff from 1" rain event and caicutate drawdown time.
(Drawdown time must be between 2 to 5 days to meet stcmmater BMP.)
Crifice CoefSaent (Cd)= 0.6
Orifice Size (d)= 4 in
Orifice Area= 0A9 sf
9° 32.2 Wsecz Drawdown Time= 3.9 d OK
head (h)= 1.07 ft (Must be more than 2 days and less then 3 days)
' *Discharge (Q)= 0.43 cfs
'Discharge from orifice sized above for runoff from the 1" rair. event.

' . ` •'00 IY.?° 1.IN, POND MAINTENANCE REQUIREMENTS
'
Name: Nucor Steel -Hertford County Project No.:
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Responsible Party: Giffin Daughtridge, Nucor Corporation Phone No: 25 -2
all a-79K
Address: North Carolina-09"
-216 NOfth
I. Maintenance Requirements: Maintenance of the system components is necessary to the
continued operability of the stormwater management facilities. The following are
1 minimum requirements which the maintenance staff of the owner's group will be required
to follow to maintain the stormwater pond management system.
' 1. Monthly or after every runoff producing rainfall event, whichever comes first:
a. Inspect the trash rack, if applicable, remove accumulated debris;
repaidreplace if it is not functioning.
b. Inspect and clear orifice of any obstructions.
C. Inspect the pond slopes and grassed inlet and outlet swales: remove
1 trash, and repair eroded areas before the next rainfall event.. Check outlet
pipe for obstructions and clear as required.
2. Quarterly:
a. Inspect the collection system (i.e. catch basins, piping, grassed swales)
for proper functioning. Accumulated trash will be cleared from basin
grates, basin bottoms, and piping will be checked for obstructions and
cleared as required.
b. Pond inlet and outlet pipes will be checked for undercutting, rip rap or
other energy dissipation structures will be replaced, and broken pipes will
be repaired.
3. Semi Annually:
a. Accumulation sediment from the bottom of the outlet structure will be
' removed.
b. The pond depth will be checked at various points. If depth is reduced to
75% of original design depth or 3 feet, whichever is greater, sediment will
be removed to at least the original design depth.
' 4. General:
a. All components of the wetland pond system will be kept in good working
1 order. Repair or replacement components will meet the original design
specifications as per the approved stormwater plan.
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%M WL%MTA%CLP1CAU143&= 0 OW MAW REG01WOOOM
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POND MAINTENANCE REQUIREMENTS
b. Mowing of the side slopes will be accomplished according to the season.
Maximum grass height shall be 6".
C. Cattails are encouraged along the pond perimeter, however they will be
removed when they cover more than 50% the surface area of the pond.
d. The orifice/pump is designed to draw down the pond in 2-5 days. If
drawdown is not accomplished in this time, the system will be checked for
clogging. The source of the clogging will be found and eliminated.
5. Deficiencies or inoperable conditions must be reported to the Project Engineer. If
resolution to the deficiency can not be implemented within 15 days, notification
shall be given to the Division of Environmental Management, Washington
Regional Office, phone [phone].
I acknowledge and agree by my signature below that I am responsible for the performance of
the above maintenance procedures..
Signature:" Date:
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WMCE WIL%DA/A%CLERKK\14]O"7WOND MAINT RE0012690.DOC

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STATE OF NORTH CAROLINA ) -DECLARATION OF
RESTRICTIVE COVENANTS
COUNTY OF HERTFORD ) FOR COMPENSATORY MITIGATION
THIS DECLARATION OF RESTRICTIVE COVENANTS (the "Declaration") is made
as of the day of , 1999, by NUCOR CORPORATION ("Declarant").
WITNESSETH:
WHEREAS Declarant is the owner of certain real property located in Hertford County,
'
North Carolina, containing approximately 900 acres and more particularly described on Exhibit
' A attached hereto (the "Property"); and
' WHEREAS, in consideration of the issuance of Department of Army Permit No.
(the "Permit") to Declarant by the United States Army Corps of Engineers,
Wilmington District (the "USACE") and as part of Declarant's Revised Compensatory Wetlands
Mitigation Plan dated September 22, 1999 (the "Compensatory Mitigation Plan") and for the
protection of the Property's scenic, conservation and environmental values, and for other good
and valuable consideration, the receipt and sufficiency of which is hereby acknowledged,
Declarant has agreed to create certain designated wetlands on the Property (such created
wetlands are hereinafter collectively called the "Wetlands"), and to preserve an uplands buffer
between the Wetlands and proposed development activities (the "Buffer"), and Declarant has
agreed to place restrictive covenants on the Property so that the Wetlands and the Buffer shall
remain in their natural state; and
' WHEREAS, the Wetlands and Buffer are more fully shown on a drawing by Datel
Engineering Company, Inc. entitled Nucor Steel, Site Development, Environmental and Wetland
' Layout Plan dated June 21, 1999 and revised July 9, 1999, which is hereby incorporated by
reference (the "Site Plan");
' NOW, THEREFORE, Declarant hereby declares that the Property shall be held,
transferred, conveyed, leased, used, or otherwise disposed of subject to the following restrictive
covenants which shall run with the land.
' WETLANDS TO BE CREATED
' Declarant will create.certain Wetlands identified on the Site Plan as Wetlands Creation
Area, which consist of approximately seven acres.
cHAR2\516075_ 2

BUFFER AREA TO BE PRESERVED
Declarant will preserve certain uplands within the Property as a Buffer between the
Wetlands and proposed development activities. Declarant will maintain a Buffer as shown on
the Site Plan of 100 feet from the edge of the Wetlands.
RESTRICTIVE COVENANTS
Except as permitted in this Declaration, Declarant covenants that the following activities
shall be prohibited in the Wetlands and Buffer:
' 1. There shall be no draining, filling, excavating, dredging, clearing, burning,
cultivating, erecting or constructing, or destruction, cutting, mowing or harming of any
vegetation, except as may be required by the Compensatory Mitigation Plan.
' 2. There shall be no introduction of exotic species of vegetation.
3. There shall be no construction or placement of any building, mobile home, road,
1 trail, path, asphalt or concrete pavement, antenna, utility pole, or any other temporary or
permanent structure or facility.
4. There shall be no dumping or storage of soil, trash, ashes, garbage, waste,
abandoned vehicles, appliances, machinery, or hazardous substances, or toxic or hazardous
waste, or any placement of underground or above ground storage tanks.
' 5. There shall be no changing the grade or elevation, or pollution, alteration,
depletion or extraction of surface waters, alteration of natural water courses, or any activity
' detrimental to water purity or that would alter natural water levels, drainage sedimentation and/or
flow, or cause soil degradation or erosion, except as may be required by the Compensatory
' Mitigation Plan.
PERMITTED ACTIVITIES WITHIN WETLANDS
Notwithstanding the foregoing Restrictive Covenants, Declarant will be permitted, but
not required, to undertake the following activities within the Wetlands and Buffer:
1. To allow access to the Wetlands and Buffer for activities such as hiking, bird
watching, fishing, hunting, which cumulatively have small impacts upon, and are consistent with,
' the continuing natural condition of the Wetlands and Buffer.
2. To remove diseased or unsafe vegetation.
' 3. To allow the discharge of stormwater into the Wetlands as permitted by state and
federal regulatory agencies.
CHAM\516075_ 2 2
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4. To allow creation activities in the Wetlands and/or Buffer pursuant to the Permit
and Compensatory Mitigation Plan.
5. To allow environmental and property studies, including without limitation, the
' taking of surface water, vegetation, and soil samples.
ADDITIONAL TERMS AND CONDITIONS
1. The USACE, and any successor agency, shall have the right, upon reasonable
prior notice to Declarant, to enter upon the Property at reasonable times to inspect the Wetlands
and Buffer and to take actions necessary to verify compliance with this Declaration.
2. It is expressly understood and agreed that this Declaration, and the restrictive
' covenants set forth herein, do not grant or convey to members of the general public any rights of
ownership, entry, access to, or use of the Property, the Wetlands, or the Buffer. These restrictive
covenants are created solely for the protection of the Wetlands and Buffer. The Declarant retains
ownership of the Property and all rights appertaining thereto, including the right to use the
Property for all purposes not inconsistent with the restrictive covenants set forth in this
' Declaration. Actual use of or entry upon the Property by any person or entity other than those
who are expressly granted rights in this Declaration shall constitute and be deemed a trespass or
other violation under the common law or applicable statutes of the State of North Carolina.
3. This Declaration and the restrictive covenants set forth herein shall be binding
upon Declarant, its successors, and assigns and all subsequent owners, lessees, or other occupiers
' or users of the Property. The term Declarant, as used herein, includes all such assignees,
successors and subsequent owners of the Property.
.
4. This Declaration is intended to ensure continued compliance with the
Compensatory Mitigation Plan and Permit issued by the United States of America, U.S. Army
' Corps of Engineers, Wilmington District. Accordingly, the Declarant grants to the USACE
and/or the United States Department of Justice, a discretionary right to enforce these restrictive
covenants in a judicial action against any persons or entities violating or attempting to violate
these restrictive covenants; provided, however, that no violation of these restrictive covenants
shall result in a forfeiture or reversion of title. In any enforcement action, an enforcing agency
shall be entitled to a complete restoration for any violation, as well as any other judicial remedy
to which it may be entitled, including injunctive relief. An enforcing agency shall also be
entitled to costs and attorneys' fees in any enforcement action in which it obtains relief.
5. Declarant, its successors, and assigns shall include the following notice on all
deeds, deeds of trusts and other legal instruments used to convey an interest in the Property
' containing a portion of the Wetlands or Buffer:

CHARZ\516075_ 2 3

NOTICE: This Property is subject to the Declaration of
Restrictive Covenants recorded in Book at Page in
the Office of the Register of Deeds for Hertford County, North
Carolina.
6. The perimeter boundary of the Wetlands and Buffer shall be permanently marked
by signs stating, "Protected Natural Area," or by a similar, permanent marking system.
7. Declarant shall have the right to sell, transfer or convey its right, title and interest
' in and to the Property, or any portion thereof, and following any such disposition, Declarant shall
be relieved of all subsequent responsibilities or liabilities undertaken by it herein with respect to
the Property (or portion thereof) so disposed, and shall not thereafter be liable or responsible to
' any party with regard to any right or covenant set forth herein; provided, however, that any
subsequent owner shall be responsible for all of the obligations of Declarant set forth herein.
' 8. Invalidation of any one of the covenants or restrictions set forth herein shall in no
way affect any other provisions of this Declaration, which shall remain in full force and effect.
' 9. Nothing contained in this Declaration shall be held or construed to impose similar
restrictions or covenants on any adjoining land or neighboring property of Declarant, now or
hereafter owned.
10. Except as required by the Compensatory Mitigation Plan, Declarant shall not be
required to mitigate or correct any damages to or destruction of the Wetlands or Buffer due to
circumstances beyond its reasonable control, including, without limitation, acts of God, fire,
flood, hurricanes, storms, winds, unauthorized or wrongful acts of third parties, acts of war, riot,
' insurrections or civil disorders.
IN WITNESS WHEREOF, Declarant, Nucor Corporation, has caused this Declaration to
' be executed by a Vice President, attested by its Secretary or Assistant Secretary, and its
Corporate Seal to be affixed hereto, all as of the day and year first above written.
NUCOR CORPORATION
' Attested By:
Secretary
(SEAL)
cHAM\516075_2 4

r
STATE OF NORTH CAROLINA
COUNTY OF MECKLENBURG
I, , Notary Public for said County and State,
certify that personally came before me this day and
acknowledged that he is Secretary of Nucor Corporation, a corporation, and that by
authority duly given and as the act of the corporation the foregoing instrument was signed in its
name by its President, sealed with its corporate seal, and attested by himself as its
Secretary.
Witness my hand and official seal, this the day of '1999.
(Official Seal)
Notary Public
My Commission Expires:
cxnx2\516075_ 2
5

STATE OF NORTH CAROLINA ) DECLARATION OF
RESTRICTIVE COVENANTS
COUNTY OF HERTFORD )
THIS DECLARATION OF RESTRICTIVE COVENANTS (the "Declaration") is made
' as of the day of , 1999, by NUCOR CORPORATION ("Declarant").
' WITNESSETH:
WHEREAS, Declarant is the owner of certain real property located in Hertford County,
North Carolina, containing approximately 900 acres and more particularly described on Exhibit
A attached hereto (the "Property"); and
WHEREAS, for the protection and preservation of the Property's wetlands, and for the
protection of the Property's scenic, conservation and environmental values, and for other good
and valuable consideration, Declarant has determined to preserve certain designated wetlands on
' the Property (such preserved wetlands are hereinafter collectively called the "Wetlands"), and to
preserve an uplands buffer between the Wetlands and proposed development activities (the
"Buffer"), and Declarant has determined to place restrictive covenants on the Property so that the
Wetlands and the Buffer shall remain substantially in their natural state; and
WHEREAS, the Wetlands and Buffer are more fully shown on a drawing by Datel
Engineering Company, Inc. entitled Nucor Steel, Site Development, Environmental and Wetland
Layout Plan dated June 21, 1999 and revised July 9, 1999, which is hereby incorporated by
' reference (the "Site Plan");
NOW, THEREFORE, Declarant hereby declares that the Property shall be held,
I transferred, conveyed, leased, used, or otherwise disposed of subject to the following restrictive
covenants which shall run with the land.
WETLANDS TO BE CREATED
Declarant will preserve the Wetlands, which are denominated on the Site Plan as Preserved
' Wetlands[Water of the U.S.
BUFFER AREA TO BE PRESERVED
Declarant will preserve certain uplands within the Property as a Buffer between the
Wetlands and proposed development activities. Declarant will maintain a Buffer as shown on
the Site Plan of predominantly 100 feet from the edge of the Wetlands. In the event it is
necessary for Declarant to intrude upon the Buffer as shown on the Mitigation Plan, it will
promptly establish another buffer area on the Property the same size as the area of the Buffer
CHAR2\ESD\CORP\516075 1

upon which it has intruded. In all events, Declarant shall maintain at all times a minimum Buffer
of at least fifty feet.
RESTRICTIVE COVENANTS
Except as permitted in this Declaration, Declarant covenants that the following activities
shall be prohibited in the Wetlands and Buffer:
' 1. There shall be no draining, filling, excavating, dredging, clearing, burning,
cultivating, erecting or constructing.
2. There shall be no introduction of exotic species of vegetation.
' 3. There shall be no construction or placement of any building, mobile home, road,
trail, path, asphalt or concrete pavement, antenna, utility pole, or any other temporary or
' permanent structure or facility.
4. There shall be no dumping or storage of soil, trash, ashes, garbage, waste,
' abandoned vehicles, appliances, machinery, or hazardous substances, or toxic or hazardous
waste, or any placement of underground or above ground storage tanks.
5. There shall be no changing the grade or elevation, impairing the flow of
circulation of waters, reducing the reach of waters, or any other discharge or activity requiring a
permit under the clean water or water pollution control laws and regulations, as amended.
PERMITTED ACTIVITIES WITHIN WETLANDS
' Notwithstanding the foregoing Restrictive Covenants, Declarant will be permitted, but
not required, to undertake the following activities within the Wetlands and Buffer:
' 1. To allow access to the Wetlands and Buffer for activities such as hiking, bird
watching, fishing, hunting, which cumulatively have small impacts upon, and are consistent with,
' the continuing natural condition of the Wetlands and Buffer.
2. To allow limited underbrushing of vegetation to create pedestrian pathways, to
create nature trails with elevated boardwalks or bridges, or other similar activities, which
cumulatively have small impacts upon, and are consistent with, the continuing natural condition
of the Wetlands and Buffer.
3. To remove diseased or unsafe vegetation.
4. To allow the discharge of stormwater into the Wetlands as permitted by state and
federal regulatory agencies.
CHAR2\ESDICORP\516075_ 1 2

5. To allow environmental and property studies, including without limitation, the
taking of surface water, vegetation, and soil samples.
6. To maintain existing dirt roads.
' ADDITIONAL TERMS AND CONDITIONS
' 1. After recording, this Declaration and the restrictive covenants set forth herein may
be altered by issuance or modification of a permit pursuant to applicable USACE regulations and
' policy, and such issuance and/or modification shall automatically become a part of this
Declaration.
' 2. Declarant may from time to time request to trade in other real property that is not
encumbered by conservation easements or covenants for property contained in the Wetlands and
Buffer (or any portion thereof), provided that such substitute real property is of equivalent
' function and value of the Property herein, and is placed under equivalent conservation
restrictions, and provided further that Declarant obtains the approval of the USACE.
' 3. Any permit application, or request for certification or modification, which may
affect the Wetlands or Buffer, made to any governmental entity with authority over wetlands or
other waters of the United States, shall expressly reference and include a copy of this
Declaration.
' 4. The USACE, and any successor agency, shall have the right, upon reasonable
prior notice to Declarant, to enter upon the Property at reasonable times to inspect the Wetlands
and Buffer and to take actions necessary to verify compliance with this Declaration.
' 5. It is expressly understood and agreed that this Declaration, and the restrictive
covenants set forth herein, do not grant or convey to members of the general public any rights of
' ownership, entry, access to, or use of the Property, the Wetlands, or the Buffer. These restrictive
covenants are created solely for the protection of the Wetlands and Buffer. The Declarant retains
ownership of the Property and all rights appertaining thereto, including the right to use the
Property for all purposes not inconsistent with the restrictive covenants set forth in this
Declaration. Actual use of or entry upon the Property by any person or entity other than those
who are expressly granted rights in this Declaration shall constitute and be deemed a trespass or
' other violation under the common law or applicable statutes of the State of North Carolina.
' 6. This Declaration and the restrictive covenants set forth herein shall be binding
upon the Declarant, its successors, and assigns and all subsequent owners, lessees, or other
occupiers or users of the Property. The term Declarant, as used herein, includes all such
assignees, successors and subsequent owners of the Property.
7. The Declarant grants to the USACE and/or the United States Department of
Justice, a discretionary right to enforce these restrictive covenants in a judicial action against any
persons or entities violating or attempting to violate these restrictive covenants; provided,
' CHARMSMORAS 16075 1 3
1
however, that no violation of these restrictive covenants shall result in a forfeiture or reversion of
title. In any enforcement action, an enforcing agency shall be entitled to a complete restoration
for any violation, as well as any other judicial remedy to which it may be entitled, including
injunctive relief. An enforcing agency shall also be entitled to costs and attorneys' fees in any
' enforcement action in which it obtains relief.
8. Declarant, its successors, and assigns shall include the following notice on all
' deeds, deeds of trusts and other legal instruments used to convey an interest in the Property
containing a portion of the Wetlands or Buffer:
' NOTICE: This Property is subject to the Declaration of
Restrictive Covenants recorded in Book at Page in
' the Office of the Register of Deeds for Hertford County, North
Carolina.
' 9. The perimeter boundary of the Wetlands and Buffer shall be permanently marked
by signs stating, "Protected Natural Area," or by a similar, permanent marking system.
' 10. Declarant shall have the right to sell, transfer or convey its right, title and interest
in and to the Property, or any portion thereof, and following any such disposition, Declarant shall
be relieved of all subsequent responsibilities or liabilities undertaken by it herein with respect to
the Property (or portion thereof) so disposed, and shall not thereafter be liable or responsible to
any party with regard to any right or covenant set forth herein; provided, however, that any
' subsequent owner shall be responsible for all of the obligations of Declarant set forth herein.
11. Invalidation of any one of the covenants or restrictions set forth herein shall in no
' way affect any other provisions of this Declaration, which shall remain in full force and effect.
12. Nothing contained in this Declaration shall be held or construed to impose similar
' restrictions or covenants on any adjoining land or neighboring property of Declarant, now or
hereafter owned.
' 13. Declarant shall not be required to mitigate or correct any damages to or
destruction of the Wetlands or Buffer due to circumstances beyond its reasonable control,
including, without limitation, acts of God, fire, flood, hurricanes, storms, winds, unauthorized or
wrongful acts of third parties, acts of war, riot, insurrections or civil disorders.
fl

CHARMSMOR.M516075_ 1 4

IN WITNESS WHEREOF, Declarant, Nucor Corporation, has caused this Declaration to
be executed by a Vice President, attested by its Secretary or Assistant Secretary, and its
Corporate Seal to be affixed hereto, all as of the day and year first above written.
' Attested BY:
NUCOR CORPORATION
' Secretary
(SEAL)

7

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CHARZESMORA516075_ 1 5

r
STATE OF NORTH CAROLINA
COUNTY OF MECKLENBURG
I, . Notary Public for said County and State,
certify that personally came before me this day and
acknowledged that he is Secretary of Nucor Corporation, a corporation, and that by
authority duly given and as the act of the corporation the foregoing instrument was signed in its
name by its President, sealed with its corporate seal, and attested by himself as its
Secretary.
Witness my hand and official seal, this the day of '1999.
(Official Seal)
Notary Public
My Commission Expires:
CHARZESMORM516075_ 1
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November 16, 1999
tv1i . Dave Lekson
f
NEWKIRK
EmuoNmTAL, INc
U.S. Army Corps of Engineers
Washington Regulatory Field Office
107 Union Drive, Suite 202
Washington, NC 27889
RE: Action 1D No. 199811324
Revised Wetland Mitigation Plan
Dear Mr. Lekson,

57
Enclosed you will find the Revised Compensatory Wetland Mitigation Plan for
the Nucor Steel Recycling Mill in Hertford County. This plan includes changes to the
September 22, 1999 Mitigation Plan as discussed in recent telephone conversations and
your letter dated November 10, 1999. This revised mitigation plan now provides a
greater level of detail for the previously proposed actions, and without making significant.
changes to the scope of tl;v Revised Compensatory Wetland Mitigation Plan, addresses
all issues and comments raised by the commenting agencies.
With the requested revisions, we believe that the information included in this
Revised Compensatory- Wetland Mitigations Plan now meets the requirements that allow
the U. S. Army Corps of Engineers to proceed with the issuance of the Section 404
permit, Section 10 Permit, and associated permit conditions.
item 17 from your letter requests that "All plat sized draE=rings must be submitted
or. a disc." This disc is being prepared and will be submitted to the U.S. Army Corps of
Engineers under a separate 'letter

Charleston, SC Office
' 192 East Bay Street
Suite 201
Charleston, SC 29401
[phone]
' Facsimile: [phone]
E-Mail: [e-mail]
Hendersonville, NC Office
Post Office Box 2876
Hendersonville, NC 28793
[phone]
Facsimile: [phone]
NewkirkNC @ aol.com

Savannah, GA Office
340 Eisenhower Drive
Building 200, Suite 201
Savannah, GA 31406
[phone]
Facsimile: [phone]
E-Mail: [e-mail]

Mr. Dave Lekson
November 16, 1999
Page Two
Please do not hesitate to call me at [phone] if we may be of further
assistance in this matter or if you have any questions regarding the submitted
information.
Sincerely,
,6z--LR. Clement Riddle
Project Biologist
cc:
? John Dorney
Deborah Sawyer
Doug Huggett
Mike Delaney
Russ Lea
Chad Prior
enclosures:
CLEARWATER ENVIRONMENTAL
CONSULTANTS, INC.
300 N. Main Street, Suite 202
Hendersonville, NC 28792
[phone]
FAX [phone]
Mr. John Dorney
NC Division of Water Quality
2321 Crabtree Blvd
Raleigh, NC 27604-2260
LETTER OF TRANSMITTAL
DATE:
12-22-03 PROJECT: NUCOR
ATTENTION:
RE: Wetland Mitigation
Fall Monitoring Report
DWQ Project No. 990231
WE ARE SENDING YOU ? ATTACHED ? UNDER SEPARATE COVER VIA THE FOLLOWING ITEMS:
WGr,
COPIES DATE NO. DESCRIPTION /
3 12-22-02 Wetland Mitigation 2003 Fall Monitoring Report
e

0
140
114 TER no,
r
THESE ARE TRANSMITTED AS CHECK BELOW:
_W 11UN
® For approval ? Approved as submitted ? Resubmit copies for approval
? For your use ? Approved as noted ? Submit copies for distribution
® As requested ? Returned for corrections ? Return corrected prints
? For review and comment ? Materials returned after loan to us ?
REMARKS:
Enclosed are 3 copies of the wetland mitigation 2003 Fall monitoring report for Nucor Steel.
Please do not hesitate to contact me if you have any questions or comments regarding enclosed report.
COPY TO: SIGNED:
EARWATER ENVIRONMENTAL CONSULTANTS, INC.
Clement R'Jdle.
0
CLEARWATER ENVIRONMENTAL
CONSULTANTS, INC.
300 N. Main Street, Suite 202
Hendersonville; NC 28792
[phone]
FAX [phone]
Mr. John Dorney
NC Division of Water Quality
2321 Crabtree Blvd
Raleigh, NC 27604-2260
LETTER OF TRANSMITTAL
DATE:
7-22-02 PROJECT: NUCOR
ATTENTION:
RE: Mitigation As-built
DWQ Project No. 990231
WE ARE SENDING YOU ? ATTACHED ? UNDER SEPARATE COVER VIA THE FOLLOWING ITEMS:
COPIES DATE NO. DESCRIPTION
3 7-22-02 Wetland Mitigation As-Built Report
THESE ARE TRANSMITTED AS CHECK BELOW:
? For approval
? For your use
® As requested
? For review and comment
? Approved as submitted
? Approved as noted
? Returned for corrections
? Materials returned after loan to us
? Resubmit
? Submit _
R
?
copies for approval
copies for distribution
JUL 2 5 2002
REMARKS:
Enclosed are 3 copies of the As-built miti
port for Nucor Steel.

Please do not hesitate to contact me if you have any questions or comments regarding enclosed report.
COPY TO:
AL CONSULTANTS, INC.
COO
r4erj4'd, e"`y

r4l-c
PLATE MILL
AS-BUILT REPORT
7-ACRE WETLAND CREATION
July 16, 2002
Prepared for:
Nucor Steel
1505 River Road
Cofield, NC
27922
Prepared by:
ClearWater Environmental Consultants, Inc.
300 North Main Street, Suite 202
. Hendersonville, NC 28792
ILA
r U=C3FQ
It'5 our Nature"
JUL'2 5 2002 =
1
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LIST OF FIGURES
Figure 1 Site Plan ....................................................................................40
Figure 2 150-Acre off-site Preservation ..........................................................41
Figure 3 Wetland Creation Area ...................................................................42
ii

LIST OF PHOTOGRAPHS

' Photograph 1. Overview of Creation Area, Spring 2002 ..................................................................
Photograph 2. Overview of Creation Area, Spring 2002 .................................................................. 19
19
Photograph 3. Creation Area, Transect No. 1, Plot 1, 2002 ............................................................. 20
Photograph 4. Creation Area, Transect No. 1, Plot 2, 2002 .............................................................
Photograph 5. Creation Area, Transect No. 1, Plot 3, 2002.. . 20
21
Photograph 6. Creation Area, Transect No. 2, Plot 1, 2002 ............................................................. 21
Photograph 7. Creation Area, Transect No. 2 Plot 2, 2002 .............................................................
Photograph 8. Creation Area, Transect No. 3, Plot 1, 2002.. . 22
22
Photograph 9. Creation Area, Transect No. 3, Plot 2, 2002 ............................................................. 23
Photograph 10. Creation Area, Transect No. 3, Plot 3, 2002 ............................................................
Photograph 11. Pond Cl, Plot 1, 2002 ............................................................................................... 23
24
Photograph 12. Pond Cl, Plot 2, 2002 ............................................................................................. 24
' Photograph 13. Pond Cl, Plot 3, 2002 .............................................................................................
Photograph 14. Pond Cl, Plot 4, 2002 ............................................................................................. 25
25
Photograph 15. Pond Cl, Plot 5, 2002 ............................................................................................. 26
Photograph 16. Pond Cl, Plot 6, 2002 .............................................................................................
Photograph 17. Pond Cl, Plot 7, 2002 ............................................................................................. 26
27
Photograph 18. Pond B1, Plot 1, 2002 ............................................................................................. 27
' Photograph 19. Pond B1, Plot 2, 2002 ...................................................................................:......... 28
Photograph 20. Pond B1, Plot 3, 2002 ............................................................................................. 28
Photograph 21. Pond Bl, Plot 4, 2002 ............................................................................................. 29
' Photograph 22. Pond Bl, Plot 5, 2002 ................................................................. ....
29
Photograph 23. Pond Bl, Plot 6, 2002 .............................................................................................
Photograph 24. Pond B1, Plot 7, 2002 ....... 30
30
......................................................................................
Photograph 25. Pond B1, Plot 8, 2002 . ......
31

' Photograph 26. Pond B1, Plot 9, 2002 .............................................................................................
Photograph 27. Pond B1, Plot 10, 2002 ........................................................................................... 31
32

'

' Photograph 28. Pond B1, Plot 11, 2002 ........................................................................................... 32
Photograph 29. Pond Al, Plot 1, 2002 ............................................................................................. 33
Photograph 30. Pond Al, Plot 2, 2002 ............................................................................................. 33
Photograph 31. Pond Al, Plot 3, 2002 ............................................................................................. 34
Photograph 32. Pond Al Plot 4, 2002 .............................................................................................. 34
Photograph 33. Pond Al, Plot 5, 2002 ............................................................................................. 35
Photograph 34. Pond A3, Plot 1, 2002 ............................................................................................. 35
Photograph 35. Pond A3, Plot 2, 2002 ............................................................................................. 36
Photograph 36. Pond A3, Plot 3, 2002 ............................................................................................. 36
Photograph 37. Pond A3, Plot 4, 2002 ............................................................................................. 37
Photograph 38. Pond A3, Plot 5, 2002 ............................................................................................. 37
iii

Photograph 39. Pond A3, Plot 6, 2002 ............................................................................................. 38
Photograph 40. Pond A3, Plot 7, 2002 ............................................................................................. 38
Photograph 41. transition area from existing wetland to creation area ............................................. 38
Photograph 42. transition area from existing wetland to creation area ............................................. 38

iv
1
EXECUTIVE SUMMARY
' Nucor Steel (Nucor) was issued a Department of the Army Permit (No. 199811324), a N.C.
Division of Water Quality 401 Certification (990231), and a Division of Coastal Management
' Permit (79-99) to construct a railroad crossing and stormwater management ponds in unnamed
intermittent tributaries of the Chowan River and wetlands adjacent to Brooks Creek in Hertford
' County, North Carolina. As a special condition to these permits, Nucor is required to implement
mitigation measures outlined in the Revised Compensatory Wetlands Mitigation Plan Plantation for
' Nucor Steel Plate Recycling Mill, Hertford County, November 8, 1999. The Mitigation Plan
includes creation of a seven acre bottomland hardwood wetland and creation of 2.68 acres of littoral
' shelves along the periphery of four stormwater ponds, as well as the preservation of 150 acres of
swamp forest along the Chowan River and 14.68 acres of wetlands on-site. These mitigation
' efforts are required to offset unavoidable impacts to 2.32 acres of jurisdictional freshwater
wetlands. The as-built monitoring was conducted in May 2002, after construction and planting of
' the mitigation areas. Nucor will continue to monitor these areas for the next five years and report
the results annually to the U.S. Army Corps of Engineers (USACE), N.C. Division of Water
Quality (DWQ), and the N.C. Division of Coastal Management (CAMA).

1
1.0 INTRODUCTION
' Nucor Steel (Nucor) was issued a Department of the Army Permit (No. 199811324), a N.C.
Division of Water Quality 401 Certification (990231), and a Division of Coastal Management
' Permit (79-99) to construct a railroad crossing and stormwater management ponds in unnamed
intermittent tributaries of the Chowan River and wetlands adjacent to Brooks Creek in Hertford
' County, North Carolina (Figure 1). As a special condition to these permits, Nucor is required to
implement mitigation measures outlined in the Revised Compensatory Wetlands Mitigation Plan
' Plantation for Nucor Steel Plate Recycling Mill, Hertford County, November 8, 1999.
The Mitigation Plan schedules activities to offset unavoidable impacts to 2.32 acres of jurisdictional
freshwater wetlands/Waters of the U.S. Jurisdictional wetlands are defined by 33 CFR Part
' 328.3(b) and are protected by The Clean Water Act (33 CFR 1344) which is administered and
enforced by the U.S. Army Corps of Engineers (USACE). Mitigation efforts for the project include
' the following:
• 7-acre wetland creation area
• Pond C1 includes 0.604-acres of littoral shelf.
• Pond B 1 includes a 0.917-acres littoral shelf.
• Pond Al includes 0.839-acres littoral shelf.
' Pond A3 includes a 0.504-acres littoral shelf.
' 14.87-acres of Preserved Wetlands on-site
• 150 acres of preserved wetlands off-site
Planting of hydrophytic tree species was conducted at the seven acre wetland creation area
and hydrophytic herbaceous species were planted on the littoral shelves at ponds Al, Bl, C1 and
A3 (Figure 1). Hardwood saplings include the following species bald cypress (Taxodium

6
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distichum), green ash (Fraxinus pennslyvanica), laurel oak (Quercus laurifolia), swamp chestnut
' oak (Quercus michauxii), water tupelo (Nyssa biflora), willow oak (Quercus phellos), and water
oak (Quercus nigra). Wax myrtle (Myrica cerifera) was planted along the transition area between
' the wetland area and the upland area. Herbaceous species planted on the littoral shelves included
pickerel weed (Pontedaria cordata), arrow arum (Peltandra virginica), soft rush (Juncos effusus),
' lizard's tail (Saururus cernuus), shallow sedge (Carex lurida) and uptight sedge (Carex stricta).
' Mitigation monitoring of vegetation will be conducted again at the end of this growing season
(August/September 2002).
Planting of hardwood saplings at creation area was conducted in winter of 2002. Planting
of herbaceous species was conducted in Pond B1 in the spring of 2001 and ponds C1, A3, and half
of pond Al were planted in spring 2002. The remainder of Pond Al was planted in June of 2002.
' A total of 5,150 seedling tree species as described above were planted on at least 6 x 10-foot center
spacings (or 726 trees per acre) and approximately 51,885 herbaceous species were planted on 18-
inch spacings per the Revised Compensatory Wetlands Mitigation Plan for Nucor Steel Plate
Recycling Mill (1999). Monitoring of wetlands and littoral shelves associated with the
impoundments are to be carried out for five years with a regulatory review after the fifth year to
determine success. This report summarizes the as-built conditions for the spring of 2002.
Mitigation monitoring was conducted in May 2002.
' On-site preservation Mitigation Areas are shown on (Figure 1) and were permanently
protected by the filing of restrictive covenants that were recorded at the Hertford County courthouse
on March 5, 2001 (Deed Book 577; pages 226-230).
Off-site mitigation included the purchase of 150 acres of bottomland hardwood swamp
adjacent to the Chowan River (Figure 20. This land was purchased by Nucor and deeded to the
' North Carolina Wetland Restoration program on November 2, 1999.

2.0 PURPOSE
' In order to demonstrate successful mitigation, Nucor Steel wetland creation area is monitored for
both hydrology and vegetation. The following report describes the construction and planting of
' the created wetland and littoral shelves and establishment of hydrologic groundwater monitoring
wells during the 2002.
The purpose of the long term monitoring program is to quantify the developing structure of the
created bottomland hardwood and littoral shelf wetlands. Data collected will be used to determine
' the regeneration and survivability of planted wetland vegetation, as well as the success of wetland
mitigation efforts. Also a qualitative analysis will be formulated through observations of vegetative
' growth and wildlife usage throughout the mitigation areas. The goal of the proposed mitigation is
to offset impacts to on-site wetlands by replacing lost functions and values with equal or higher
' functions and values. The primary target functions to be replaced are stormwater storage and
filtration capacities, stormwater transfer, and habitat resources.

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3.0 METHODS
As described in the Revised Compensatory Wetlands Mitigation Plan Plantation for Nucor Steel
Plate Recycling Mill, Hertford County (November 1998) prepared for Nucor, monitoring of
wetland vegetation and hydrology was conducted on the mitigation areas. Photographs were taken
to document baseline conditions occurring within the wetlands mitigation sites for future
comparison.
The site was constructed over a year period beginning in the spring of 2001 and finishing in the
winter of 2002. Prior to excavation beginning, spot elevations within existing wetland "W/X" were
taken to set the target elevation for the creation area. The target elevation was approximately 29
feet msl. The site was graded to 28 feet and backfilled with approximately 1 foot of topsoil. The
as-built elevations indicate that the wetland creation area is mostly flat and averages an elevation
near 28.5.
As stated in Section 4.2.1.1 of the Revised Compensatory Wetlands Mitigation Plan Plantation for
Nucor Steel Plate Recycling Mill, the applicant will attempt to create a smooth transition between
the existing wetland and the created wetland. To accomplish this, five small ridge sections each
approximately five feet wide were excavated between the creation area and existing wetland area
(Photographs 41 and 42). This allows a continuous sheet flow of water from stormwater pond C1
to the existing wetland. Mr. David Lekson, USACE, made a site inspection on May 15, 2002 and
reviewed the possible locations to connect the existing wetland with the wetland creation area.
The following sections describe the methods that were used to monitor these elements within the
wetland creation/restoration sites.
9

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4.0 HYDROLOGY
4.1 Success Criteria
In accordance with federal guidelines for wetland mitigation, the success criteria for hydrology
states that the area must be inundated or saturated (within 12" of the surface) by surface or
groundwater for a consecutive 12.5% of the growing season. Areas inundated for less than 5% of
the growing season are always classified as non-wetlands. Areas inundated between 5% - 12.5%
of the growing season can be classified as wetlands depending upon factors such as the presence
of wetland vegetation and hydric soils. The Revised Compensatory Wetlands Mitigation Plan
Plantation for Nucor Steel Plate Recycling Mill, Hertford County (November 1998) set a target goal
of saturated soils for at least 22 days of the growing season.
The growing season in Hertford County begins March 28 and ends November 7. These dates
correspond to a 50% probability that temperatures will drop to 28°F or lower after March 28 and
before November 71. The growing season is 224 days; therefore, optimum hydrology requires
12.5% of this season, or at least 28 consecutive days. A consecutive 10% would be equivalent to
22.4 days (rounded to 22 days) and a consecutive 5% would be equivalent to 11.2 days (rounded
to 11 days). Local climate must also represent average conditions for the area.
4.2 Hydrologic Description
Five groundwater-monitoring gauges (Figure 3), one rain gauge and one reference wetland gauge
were installed in the spring of 2002 to evaluate hydrology in the wetland creation area, local
climate data, and reference wetland hydrology. The automatic monitoring gauges record daily
readings of groundwater depth. The Nucor Steel wetland site involved the construction of a
stormwater pond (C 1) adjacent to the wetland. Overflow from the pond enters into the wetland
I Soil Conservation Service, Soil Survey of Hertford County, North Carolina, p. 61.
10

I creation area using a 300-foot diffuser. This connectivity should provide adequate hydrologic
input along with rainfall and groundwater to sustain the necessary hydrology for wetland area.
The hydrologic monitoring should show the reaction of the groundwater and surface water levels
' to specific rainfall events.
4.3 Hydrologic Monitoring
The hydrologic monitoring results are being collected for the entire 2002 growing season and
a will be included in the Fall 2002 Mitigation Monitoring Report. The attached pictures (1-9)
show portions of the site inundated/and saturated during our site visit in May 2002

t

11

5.0 SPRING 2002 VEGETATION
1
The seven acre created wetland occurs on the southern site boundary between the railroad corridor
and adjacent to Bazemore Road (Figure 3). The site encompasses approximately 7 acres of created
wetland. Portions of this area have been planted with sapling species, including swamp chestnut
oak, green ash, willow oak, water tupelo, water oak, laurel oak and bald cypress. Three transects
with a total of seven plots were located within the creation area.

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Vegetation monitoring was conducted in accordance with the Comprehensive Wetland
Determination Methodologies as described in the US Army Corps of Engineers Wetland
Delineation Manual 1987. Three line transects were established along a baseline transect generally
oriented perpendicular to Bazemore Road. Sample plots were permanently established at random
within 300-foot intervals in 7-acre creation area and at 200 to 300 foot intervals along the littoral
shelves. All transects and plots were marked with stakes painted a fluorescent color to facilitate
identification and future monitoring. Vegetative species composition and dominance were
measured within each sample plot. Trees were monitored within 30=foot radius circular plots.
Herbaceous vegetation was monitored within 5-foot radius circular plots. All herbaceous species
were identified and the percent areal cover recorded for each.
5.1 Success Criteria
Success Criteria states that there must be a minimum mean density of 320 characteristic trees
species/acre surviving for at least three years in the wetland creation area of the site.
Characteristic tree species are those species planted along with natural recruitment of other
naturally occurring hydrophytic species. Sweetgum and red maple will not be considered in the
tally of the 320 trees per acre. No quantitative sampling success requirements were developed for
the herbaceous and shrub assemblages as part of the vegetation success criteria per the November
2002 mitigation plan.
12

5.2 Description of Species
The following tree species were planted in the Wetland Creation Area:
Quercus michauxii, Swamp Chestnut Oak
Quercus nigra, Water Oak
Quercus phellos, Willow Oak
Fraxinus pennsylvanica, Green Ash
Quercus laurifolia, Laurel Oak
Nyssa aquatica, swamp tupelo
Taxodium distichum, Bald Cypress
The following herbaceous species were planted on the littoral shelves:
Juncus effusus, Soft Rush
Pontederia cordata, Pickerel Weed
Peltandra virginica, Arrows arum
Carex lurida, shallow sedge
Carex stricta, uptight sedge
5.3 AS-BUILT VEGETATION DATA
-r k! 1 7_-nr+rc (`rnnfinn Aran (Plnntarl Trawl
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1 25 1 0 1 1 7 9 44 44 676
2 3 23 0 0 6 10 8 50 50 769
3 6 6 5 9 2 3 7 38 38 584
4 2 5 4 5 6 1 6 29 29 446
5 4 2 3 2 1 2 3 17 17 261
6 2 4 6 1 8 1 1 23 23 354
7 4 7 9 4 4 4 9 41 41 631
I Average Tree Density 531
13

'J

1

Tnhla 9 1 iftnral ShplvPs

Plot # Soft
Rush
% cover Pickerel
weed
% cover Arrows
arum
% cover Lizard's tail
ai
cover shallow
sedge
% cover uptight
sedge
% cover Total
Areal
Cover

otes
C1 1 1 1 1 4
C2 1 1 1 3
C3 1 1 1 1 4
C4 1 1 1 1 1 5
C5 1 1 1 1 4
C6 2 1 1 1 5
C7 1 1 1
Al I
A2 15 3
A3 8 2 4 Panicum s 15%, unknown 1 10%
A4 2
A5 1 12
B1 5 1 1 1 1
B2
B3 15
B4 5
B5
B6 15
B7
B8
B9
B10
611
B12 1
3A1 1 1 1 1
3A2 l l 1 1 Red maple
3A3 1 1 1 1 1 1 Red maple
3A4 1 1 1 1
3A5
3A6 1
1 1 1 1
Carex sp. 3%, Panicum sp. 5%,
Ludwigia 3%, Luzula multifllora
2%
3A7 2 Carex alba I%
14

1

5.4 Created Wetland Vegetation Conclusions
Seven acres were planted with 5,150 hardwood seedlings in March 2002 and seven vegetation
monitoring plots were established in the wetland creation area. The 2002 vegetation baseline
monitoring revealed an average density of 531 trees per acre, well above the 320 tree/acre
minimum requirements.
The littoral shelves encompass approximate 2.86 acres along the periphery of the four stormwater
ponds. The original mitigation plan indicated that there would be 2.43-acres of littoral shelves on
three ponds. During the construction of the ponds the actual sizes of the proposed ponds was a
slightly smaller than originally shown. On March 23, 2000, Nucor Steel submitted a letter to Mr.
David Lekson, USACE indicating that a fourth stormwater pond was being added with a littoral
shelf. The total acreage of the littoral shelves with the fourth pond increased to 2.68-acres (as-built
2.864-acres), which was greater than the original plan. The four ponds (B1, Al, A3, and Cl) were
planted and sampled using transects that parallel the ponds edge for a total of thirty one sample
plots. The littoral shelves were planted this spring and are typically 10 feet wide. As seen in the
attached photographs the vegetation herbaceous vegetation has been established on the littoral
shelves. Baseline monitoring at the littoral shelves indicates a successful attempt to introduce
aquatic vegetation to the shoreline of the stormwater ponds. We expect additional naturally
occurring herbaceous species to become more abundant and diverse in the future.
15
1

6.0 AS-BUILT SUMMARY 2002
In the wetland creation area, the applicant planted 5,150 seedlings as required by the Revised
' Compensatory Wetlands Mitigation Plan Plantation for Nucor Steel Plate Recycling Mill, Hertford
County, November 8, 1999. The 2002 vegetation baseline monitoring revealed an average
' density of 531 trees per acre, well above the 320 tree/acre minimum requirements. This is less
than the 726 tress per acre that were delivered and planted. We may establish an additional
plot(s) in the future to identify greater variability in the location of the planted species.
Five hydrologic ground water monitoring wells are placed in the creation area and the well data
for the complete growing season will be included with the Fall 2002 monitoring report. The Fall
' 2002 monitoring report will also include an evaluation of local climate conditions as well.
I Nucor Steel will continue monitoring the site to evaluate hydrologic and vegetation success for
the next five years and submit those reports to the appropriate agencies on an annual basis.

1

16

1
1
1
1
1
1
1
1
1
1
7.0 LITERATURE CITED
Corps of Engineers Wetlands Delineation Manual, 1987. by Environmental Laboratory.
Department of Army. Waterways experiment Station. Vicksburg, Mississippi. 99 pp. plus
appendices.
Natural Resources Conservation Service, Hertford County Soil Survey, 1984.
Radford, Alhes, and Bell, Manual of the Vascular Flora of the Carolinas, 1968. University of North
Carolina Press, Chapel Hill.
Revised Compensatory Wetlands Mitigation Plan Plantation for Nucor Steel Plate Recycling Mill,
Hertford County, November 8, 1999.
17

LJ

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i
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PHOTOGRAPHS
18

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3 1
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Photograph 1. Overview of 7-acre creation Area, May 2002. Facing NE Transect 3

Loom 4 _ f
Photograph 2. Overview of 7-acre creation Area, May 2002. Facing NE. Transect I
19
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19w 77
_v 41

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Photograph 4. Creation Area, Transect No. 1, Not 2, May 2002. i4acmg NE
20
Photograph 3. Creation Area, Transect No. 1, Plot 1, May 2002. Facing NE

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Photograph 5. Creation Area, Transect No. 1, Plot 3, May 2002. Facing NE

P.m
.

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495

Photograph 6. Creation Area, Transect No. 2, Plot 4, May 2002. Facing NE
21
Photograph 7. Creation Area, Transect No. 2, Plot 5, May 2002. Facing NE
a? ..
xt i
S,y
P hotogaph 8. creation Area, Transect No. 3, Plot 6, May 2002. Facing NE
z
3.4
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22

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Photograph 9. Creation Area, Transect No. 3, Plot 7, May 2002. Facing NE

A.w
71

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V

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_
Photograph
Photograph 10. Pond C 1 Plot 1. May 2002. Facing North

23

24

72-

Photograph 14. Pond C 1 Plot 5. May 2002. Facing North
25

Photograph 13. Pond C 1 Plot 4. May 2002. Facing East
AL
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Photograph 15. Pond C 1 Plot 6 May 2002. Facing North East.

Photograph 16. Pond C 1 Plot 7 May 2002. Facing East.

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26
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Photograph 18. Pond B 1 Plot 2 May 2002. Facing north.
27
Photograph 17. Pond B 1 Plot 1 May 2002. Facing east.

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-i6
Photograph 20. Pond B 1 Plot 4 May 2002. Facing south.
28
Photograph 19. Pond B 1 Plot 3 May 2002. Facing south.

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Photograph 22. Pond B 1 Plot 6 May 2002. Facing southeast.
29
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Photograph 21. Pond B 1 Plot 5 May 2002. Facing south.

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Photograph 23. Pond B 1 Plot 7 May 2002. Facing north.
,m.
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Photograph 24. Pond B 1 Plot 8 May 2002. Facing west.
30

31
Photograph 27. Pond B 1 Plot 11 July 2002. Facing north.
.? ?,? ? r• yC.?w K ,'*?,[1 ??,, a',A?9G??. ? . ??Frla ?;?'t"e"r4 V
?, ?__ 94 ?y??vi ,? - k ?? ?j??? i•'? ?, .' ?A ter ?-, '?S'.
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Photograph 28. Pond B 1 Plot 12 July 2002. Facing north.
32
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Photograph 29. Pond Al Plot 1 May 2002. Facing north.
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Photograph 30. Pond Al Plot 2 May 2002. Facing north.

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Photograph 32. Pond Al Plot 4 May 2002. Facing north
34

Photograph 31. Pond Al Plot 3 May 2002. Facing north
Y
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Photograph 33. Pond Al Plot 5 May 2002. Facing north.
ti~
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Photograph 34. Pond A3 Plot 6 May 2002. Facing northeast.
35
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Photograph 35. Pond A3 Plot 2 May 2002. Facing North East.

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Photograph 36. Pond A3 Plot 3 May 2002. Facing east.
36

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Photograph 38. Pond A3 Plot 5 May 2002. Facing east.
37
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Photograph 37. Pond A3 Plot 4 May 2002. Facing east.
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67
Photograph 39. Pond A3 Plot 6 May 2002. Facing north.
-art

Photograph 40. Pond A3 Plot 7 May 2002. Facing north.

38
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Photograph 41. Five foot 5 wide connection from existing wetland to 7 acre creation area.
Photograph 42. Five foot 5 wide connection from existing wetland to 7 acre creation area.

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150 Acre Preservation Site

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Location Map
150 Are Preservation Site

I Hertford County, N.C. Mintonsville Quad
Figure 2

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__GO
CLEARWATER ENVIRONMENTAL
CONSULTANTS, INC.
300 N. Main Street, Suite 202
Hendersonville, NC 28792
[phone]
FAX [phone]
Mr. John Dorney
NC Division of Water Quality
2321 Crabtree Blvd
Raleigh, NC 27604-2260
LE
IF.-TRANSMITTAL
PFr, 3
DATE: COR
12-30-02 W IEP UAIIn' SECTION
ATTENTION:
RE: Wetland Mitigation
Fall Monitoring Report
DWQ Project No. 990231
WE ARE SENDING YOU ? ATTACHED ? UNDER SEPARATE COVER VIA THE FOLLOWING ITEMS:
COPIES DATE NO. DESCRIPTION
3 12-30-02 Wetland Mitigation Fall Monitori n Report
THESE ARE TRANSMITTED AS CHECK BELOW:
® For approval
? For your use
® As requested
? For review and comment
REMARKS:
? Approved as submitted
? Approved as noted
? Returned for corrections
? Materials returned after loan to us
? Resubmit copies for approval
? Submit copies for distribution
? Return corrected prints
Enclosed are 3 copies of the wetland mitigation 2002 Fall monitoring report for Nucor Steel.
Please do not hesitate to contact me if you have any questions or comments regarding enclosed report.
COPY TO: SIGNED:
CLEARWATER ENVIRONMENTAL CONSULTANTS, INC.
1
1
TABLE OF CONTENTS
LIST OF FIGURES ............................................................................................................................... 3
LIST OF PHOTOGRAPHS ................................................................................................................. .4
EXECUTIVE SUMMARY ...................................................................................................................5
1.0 INTRODUCTION ........................................................................................................................... 6
2.0 PURPOSE ........................................................................................................................................8
3.0 METHODS .................................................................................................................................... ..9
4.0 PROJECT HISTORY .................................................................................................................. ..9
5.0 HYDROLOGY ............................................................................................................................. 10
5.1 Success Criteria ............................................................................................................... 10
5.2 Hydrologic Description .................................................................................................. 10
5.3 Results of Hydrologic Monitoring ................................................................................. 11
5.4 Conclusions ..................................................................................................................... 12
6.0 FALL 2002 VEGETATION ......................................................................................................... 12
6.1 Success Criteria ................................................................................................................ 13
6.2 Description of Species ..................................................................................................... 13
6.3 Vegetation Data ................................................................................................................ 14
6.4 Created Wetland Vegetation Conclusions ....................................................................... 16
7.0 SUMMARY 2002 ......................................................................................................................... 16
8.0 LITERATURE CITED .................................................................................................................. 17
PHOTOGRAPHS ................................................................................................................................ 18
APPENDIX A Depth to Groundwater Depths
11

LIST OF FIGURES
Figure 1 Site Location Map
Figure 2 Site Plan
Figure 3 Wetland Creation Area
Figure 4a Rainfall 30 - 70 Percentile Graph (Edenton 30 Year WETS data)
Figure 4b Rainfall 30 - 70 Percentile Graph (Lewiston 30 Year WETS data)
iii

1

LIST OF PHOTOGRAPHS
Photograph 1. Overview of Creation Area, Fall 2002 ...................................................................... 19
Photograph 2. Overview of Creation Area, Fall 2002 ...................................................................... 19
Photograph 3. Creation Area, Transect No. 1, Plot 1, 2002 ............................................................. 20
Photograph 4. Creation Area, Transect No. 1, Plot 2, 2002 ............................................................. 20
Photograph 5. Creation Area, Transect No. 1, Plot 3, 2002 ............................................................. 21
Photograph 6. Creation Area, Transect No. 2, Plot 1, 2002 ............................................................. 21
Photograph 7. Creation Area, Transect No. 2 Plot 2, 2002 .............................................................. 22
Photograph 8. Creation Area, Transect No. 3, Plot 1, 2002 ............................................................. 22
Photograph 9. Creation Area, Transect No. 3, Plot 2, 2002 ............................................................. 23
Photograph 10. Creation Area, Transect No. 3, Plot 3, 2002 ............................................................ 23
Photograph 11. Pond Cl, Plot 1, 2002 ............................................................................................... 24
Photograph 12. Pond Cl, Plot 2, 2002 ............................................................................................. 24
Photograph 13. Pond Cl, Plot 3, 2002 ............................................................................................. 25
Photograph 14. Pond Cl, Plot 4, 2002 ............................................................................................. 25
Photograph 15. Pond Cl, Plot 5, 2002 ............................................................................................. 26
Photograph 16. Pond Cl, Plot 6, 2002 ............................................................................................. 26
Photograph 17. Pond Cl, Plot 7, 2002 ............................................................................................. 27
Photograph 18. Pond Bl, Plot 1, 2002 ............................................................................................. 27
Photograph 19. Pond B1, Plot 2, 2002 ............................................................................................. 28
Photograph 20. Pond Bl, Plot 3, 2002 ............................................................................................. 28
Photograph 21. Pond Bl, Plot 4, 2002 ............................................................................................. 29
Photograph 22. Pond B 1, Plot 5, 2002 .................................................................... .
9
Photograph 23. Pond Bl, Plot 6, 2002 ............................................................................................. 30
Photograph 24. Pond Bl, Plot 7, 2002 ............................................................................................. 30
Photograph 25. Pond B1, Plot 8, 2002 .............................................................................................. 31
Photograph 26. Pond Bl, Plot 9, 2002 ............................................................................................. 31
Photograph 27. Pond Bl, Plot 10, 2002 ........................................................................................... 32
Photograph 28. Pond B1, Plot 11, 2002 ........................................................................................... 32
Photograph 29. Pond Al, Plot 1, 2002 ............................................................................................. 33
Photograph 30. Pond Al, Plot 2, 2002 ............................................................................................. 33
Photograph 31. Pond Al, Plot 3, 2002 ............................................................................................. 34
Photograph 32. Pond Al Plot 4, 2002 .............................................................................................. 34
Photograph 33. Pond Al, Plot 5, 2002 ............................................................................................. 35
Photograph 34. Pond A3, Plot 1, 2002 ............................................................................................. 35
Photograph 35. Pond A3, Plot 2, 2002 ............................................................................................. 36
Photograph 36. Pond A3, Plot 3, 2002 ............................................................................................. 36
Photograph 37. Pond A3, Plot 4, 2002 ............................................................................................. 37
Photograph 38. Pond A3, Plot 5, 2002 ............................................................................................. 37
Photograph 39. Pond A3, Plot 6, 2002 ............................................................................................. 38
Photograph 40. Pond A3, Plot 7, 2002 ............................................................................................. 38
1v

EXECUTIVE SUMMARY

Nucor Steel (Nucor) was issued a Department of the Army Permit (No. 199811324), a N.C.
' Division of Water Quality 401 Certification (990231), and a Division of Coastal Management
Permit (79-99) to construct a railroad crossing and stormwater management ponds in unnamed
' intermittent tributaries of the Chowan River and wetlands adjacent to Brooks Creek in Hertford
County, North Carolina. As a special condition to these permits, Nucor is required to implement
mitigation measures outlined in the Revised Compensatory Wetlands Mitigation Plan for Nucor
Steel Plate Recycling Mill, Hertford County, November 8, 1999. The Mitigation Plan includes
creation of a seven acre bottomland hardwood wetland and creation of 2.68 acres of littoral shelves
along the periphery of four stormwater ponds, as well as the preservation of 150 acres of swamp
' forest along the Chowan River and 14.68 acres of wetlands on-site. These mitigation efforts are
required to offset unavoidable impacts to 2.32 acres of jurisdictional freshwater wetlands. The as-
built monitoring was conducted in May 2002, after construction and planting of the mitigation
areas. This document is the first annual fall monitoring report. Nucor will continue to monitor
these areas for the next four years and report the results annually to the U.S. Army Corps of
' Engineers (USACE), N.C. Division of Water Quality (DWQ), and the N.C. Division of Coastal
Management (LAMA).

L I

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1
11
1

1.0 INTRODUCTION
Nucor Steel (Nucor) was issued a Department of the Army Permit (No. 199811324), a N.C.
Division of Water Quality 401 Certification (990231), and a Division of Coastal Management
Permit (79-99) to construct a railroad crossing and stormwater management ponds in unnamed
intermittent tributaries of the Chowan River and wetlands adjacent to Brooks Creek in Hertford
County, North Carolina (Figure 1). As a special condition to these permits, Nucor is required to
implement mitigation measures outlined in the Revised Compensatory Wetlands Mitigation Plan
for Nucor Steel Plate Recycling Mill, Hertford County, November 8, 1999.
The Mitigation Plan schedules activities to offset unavoidable impacts to 2.32 acres of jurisdictional
freshwater wetlands/Waters of the U.S. Jurisdictional wetlands are defined by 33 CFR Part
328.3(b) and are protected by The Clean Water Act (33 CFR 1344) which is administered and
enforced by the U.S. Army Corps of Engineers (USACE). Mitigation efforts for the project include
the following:
• 7-acre wetland creation area
• Pond C1 includes 0.604-acres of littoral shelf.
• Pond B 1 includes a 0.917-acres littoral shelf.
• Pond Al includes 0.839-acres littoral shelf.
• Pond A3 includes a 0.504-acres littoral shelf.
• 14.87-acres of Preserved Wetlands on-site
• 150 acres of preserved wetlands off-site
Planting of hydrophytic tree species was conducted at the seven acre wetland creation area (Figure
3) and hydrophytic herbaceous species were planted on the littoral shelves at ponds Al, B1, C1 and
A3 (Figure 2). Hardwood saplings include the following species bald cypress (Taxodium
6

1

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1

distichum), green ash (Fraxinus pennslyvanica), laurel oak (Quercus laurifolia), swamp chestnut
oak (Quercus michauxii), water tupelo (Nyssa biflora), willow oak (Quercus phellos), and water
oak (Quercus nigra). Wax myrtle (Myrica cerifera) was planted along the transition area between
the wetland area and the upland area. Herbaceous species planted on the littoral shelves included
pickerel weed (Pontedaria cordata), arrow arum (Peltandra virginica), soft rush (Juncus effusus),
lizard's tail (Saururus cernuus), shallow sedge (Carex lurida) and uptight sedge (Carex stricta).
Mitigation monitoring of vegetation will be conducted again at the end of this growing season
(August/September 2003).
Planting of hardwood saplings at creation area was conducted in March of 2002. Planting of
herbaceous species was conducted in Pond B1 in the spring of 2001 and ponds Cl, A3, and half of
pond Al were planted in spring 2002. The remainder of Pond Al was planted in June of 2002. A
total of 5,150 seedling tree species as described above were planted on at least 6 x 10-foot center
spacings (or 726 trees per acre) and approximately 51,885 herbaceous species were planted on 18-
inch spacings per the Revised Compensatory Wetlands Mitigation Plan for Nucor Steel Plate
Recycling Mill (1999). Monitoring of wetlands and littoral shelves associated with the
impoundments are to be carried out for five years with a regulatory review after the fifth year to
determine success. This report summarizes the first year results for the Fall of 2002. Mitigation
monitoring was conducted in October 2002.
The wetland preservation actions both on-site and off-site are completed and the details were
provided in the As-Built report dated July 16, 2002.
7
1

2.0 PURPOSE
In order to demonstrate successful mitigation, the wetland creation area must be monitored for
both hydrology and vegetation for a minimum of five years or until success criteria are fulfilled.
Success criteria are based on federal guidelines for wetland mitigation. The following report
details the results of hydrologic and vegetative monitoring during the Fall of 2002 at the Nucor
Steel Hertford County site as well as local climate conditions throughout the growing season.
The purpose of the long term monitoring program is to quantify the developing structure of the
created bottomland hardwood and littoral shelf wetlands. Data collected will be used to determine
the regeneration and survivability of planted wetland vegetation, as well as the success of wetland
mitigation efforts. Also a qualitative analysis will be formulated through observations of vegetative
growth and wildlife usage throughout the mitigation areas. The goal of the proposed mitigation is
to offset impacts to on-site wetlands by replacing lost functions and values with equal or higher
functions and values. The primary target functions to be replaced are stormwater storage and
filtration capacities, stormwater transfer, and habitat resources.

1

8
1

3.0 METHODS
' As described in the Revised Compensatory Wetlands Mitigation Plan for Nucor Steel Plate
Recycling Mill, Hertford County (November 1998) prepared for Nucor, monitoring of wetland
' vegetation and hydrology was conducted on the mitigation areas. Photographs were taken to
document baseline conditions occurring within the wetlands mitigation sites for future comparison.
The site was constructed over a year period beginning in the spring of 2001 and finishing in the
' winter of 2002. Prior to excavation beginning, spot elevations within existing wetland "W/X" were
taken to set the target elevation for the creation area. The target elevation was approximately 29
' feet msl. The site was graded to 28 feet and backfilled with approximately 1 foot of topsoil. The
as-built elevations indicate that the wetland creation area is mostly flat and averages an elevation
near 28.5.
The following sections describe the methods that were used to monitor these elements within the
' wetland creation/restoration sites.
' 4.0 PROJECT HISTORY
' Spring 2001 - Littoral shelf on Pond B 1 planted
March 2002 - 7-acre creation area planted
' April - June 2002 - Littoral shelf on ponds Cl, Al, and A3 planted
March - November 2002 - Hydrologic Monitoring (Year 1)
' October 2002 - Vegetation monitoring (Year 1)
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5.0 HYDROLOGY
5.1 Success Criteria
In accordance with federal guidelines for wetland mitigation, the success criteria for hydrology
states that the area must be inundated or saturated (within 12" of the surface) by surface or
groundwater for a consecutive 12.5% of the growing season. Areas inundated for less than 5% of
the growing season are always classified as non-wetlands. Areas inundated between 5% - 12.5%
of the growing season can be classified as wetlands depending upon factors such as the presence
of wetland vegetation and hydric soils. The Revised Compensatory Wetlands Mitigation Plan for
Nucor Steel Plate Recycling Mill, Hertford County (November 1998) set a target goal of saturated
soils for at least 22 days of the growing season.
The growing season in Hertford County begins March 28 and ends November 7. These dates
correspond to a 50% probability that temperatures will drop to 28°F or lower after March 28 and
before November 71. The growing season is 224 days; therefore, optimum hydrology requires
12.5% of this season, or at least 28 consecutive days. A consecutive 10% would be equivalent to
22.4 days (rounded to 22 days) and a consecutive 5% would be equivalent to 11.2 days (rounded
to 11 days). Local climate must also represent average conditions for the area.
1 5.2 Hydrologic Description

Five groundwater-monitoring gauges (Figure 3), one rain gauge and one reference wetland gauge
were installed in the spring of 2002 to evaluate hydrology in the wetland creation area, local
t Natural Resource Conservation Service, Soil Survey of Hertford County, North Carolina, p. 61.
10

7

climate data, and reference wetland hydrology. The automatic monitoring gauges record daily
readings of groundwater depth. The Nucor Steel wetland site involved the construction of a
stormwater pond (Cl) adjacent to the wetland. Overflow from the pond enters into the wetland
creation area using a 300-foot diffuser. This connection should provide adequate hydrologic
input along with rainfall and groundwater to sustain the necessary hydrology for wetland area.
The hydrologic monitoring should show the reaction of the groundwater and surface water levels
to specific rainfall events.
5.3

1

C'

C

n

Results of Hydrologic Monitoring
5.3.1 Site Data
The maximum number of consecutive days that the groundwater was within twelve
inches of the surface was determined for each gauge. This number was converted into a
percentage of the 224-day growing season. The results are presented in Table 1. Appendix
A contains a plot of the groundwater depth for each monitoring gauge and the surface
water depth recorded by the surface gauges. The maximum number of consecutive days is
noted on each graph. The individual precipitation events, shown on the monitoring well
graphs as bars, represent data collected from the rain gauge located in Cofield, N.C.
several miles to the west (the on-site rain gauge malfunctioned). The attached pictures (1-
9) show portions of the wetland creation area inundated/and saturated during our site visit
in October 2002.
Table 1 Hydrologic Monitoring 7-Acre Creation Area 2002
Permit Success Criteria
Monitoring
Gauge <5%
(<11 days) 5-8%
(11-18 days) 8-12.5%
(19-28 days) > 12.5%
(> 28 days) Actual Number of
Consecutive Days
Percent
Success Dates
GW1* No Data
GW2 • 36 % 82 days) March 28 - June 17
GW3 • 24% 55 days) March 28 - May 21
GW4 • 37% 83 days) March 28 - June 18
GW5 • 59% 133 days) March 28 - August 7
RW** • 9% 21 days) March 28 - April 17
*GW 1 is located in existing wetland W/X which is surrounaea by the creates wettano. wen manuncuuncu in avva.
2001 data shows 36 days of consecutive inundation/saturation.
**RW refers to the reference gauge located in the reference wetland.
11

0

H

C

5.3.2 Climatic Data
Figures 4a and 4b represents an examination of the local climate in comparison with
historical data in order to determine whether 2002 was "average" in terms of climate
conditions. The figures compare the local rainfall from 2002 with that of historical
rainfall (data collected between 1961 and 1990). The graph shows 2002 rainfall totals
from January 2002 through December 2002, which includes the growing, season for this
site. (Please note that the Lewiston and Edenton WETS Stations were used for the 30
year average on Figures 4a and 4b. The Hertford County WETS Station only has 11 years
of data available).
5.4 Conclusions
2002 represents the first full growing season that hydrologic data that has been examined. All of
the monitoring gauges in the created wetland show saturation and inundation for greater that 12.5
percent of the growing season and represent a successful initial hydrologic period. The monthly
rainfall totals are in the mostly average range with brief periods that extend above or below the
average range.
6.0 FALL 2002 VEGETATION
The seven acre created wetland is located on the southern edge of Nucor's property between the
railroad corridor and adjacent to Bazemore Road (Figure 2). The site encompasses approximately 7
acres of created wetland. Portions of this area have been planted with sapling species, including
swamp chestnut oak, green ash, willow oak, water tupelo, water oak, laurel oak and bald cypress.
Three transects with a total of seven plots were located within the creation area.
Vegetation monitoring was conducted in accordance with the Comprehensive Wetland
Determination Methodologies as described in the US Army Corps of Engineers Wetland
Delineation Manual 1987. Three line transects were established within the creation area and their
approximate location is shown on Figure 3. Sample plots were permanently established at random
12

1

1

1
11
within 300-foot intervals in 7-acre creation area and at 200 to 300 foot intervals along the littoral
shelves. All transects and plots were marked with stakes painted a fluorescent color to facilitate
identification and future monitoring. Vegetative species composition and dominance were
measured within each sample plot. Trees were monitored within 30-foot radius circular plots.
Herbaceous vegetation was monitored within 5-foot radius circular plots. All herbaceous species
were identified and the percent areal cover recorded for each.
6.1 Success Criteria
Success Criteria states that there must be a minimum mean density of 320 characteristic trees
species/acre surviving for at least five years in the wetland creation area. Characteristic tree
species are those species planted along with natural recruitment of other naturally occurring
hydrophytic species. Sweetgum and red maple will not be considered in the tally of the 320 trees
per acre. No quantitative sampling success requirements were developed for the herbaceous and
shrub assemblages as part of the vegetation success criteria per the November 1999 Mitigation
Plan.
6.2 Description of Species
The following tree species were planted in the Wetland Creation Area:
Quercus michauxii,
Quercus nigra,
Quercus phellos,
Fraxinus pennsylvanica,
Quercus laurifolia,
Nyssa aquatica,
Taxodium distichum,
Swamp Chestnut Oak
Water Oak
Willow Oak
Green Ash
Laurel Oak
swamp tupelo
Bald Cypress
The following herbaceous species were planted on the littoral shelves:
Juncus effusus, Soft Rush
Pontederia cordata, Pickerel Weed
Peltandra virginica, Arrows arum
Carex lurida, shallow sedge
Carex stricta, uptight sedge
13

6.3 Vegetation Data

n

T-%hln 7 7_chrrrn rranfinn Area !Plantar) TrPP_ Survival)
?$ N-
7

p N
N CO Y
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1 25 2 0 1 1 6 3 38 44 584
2 3 23 0 0 2 8 8 44 50 677
3 4 6 2 3 2 3 6 26 38 400
4 2 4 1 2 1 1 5 16 29 246
5 4 1 1 1 1 2 1 11 17 169
6 2 4 4 0 7 1 1 19 23 292
7 4 7 3 4 4 4 9 35 41 538
' I Average Tree Density 415
Site notes: other species observe include Acer rubrum, Panicum dichotomiflorum,
Eleocharis microcarpa, Cyperus globules, and Cyperus iria. Standing water was present
' on the majority of the site at the time of monitoring.

14
L

H

'r &.1 1 1 i44?r?1 Chnlvnc fr. Gnnf Qarlhum Plntl

lot # - - - -

Soft Rush

% cover - - -

Pickerel

weed
% cover -- - - -

Arrows

arum
% cover - - -- -
Lizard's

tail

%
cover

shallow

sedge
% cover

uptight

sedge
% cover

Total

Areal
Cover ' Notes
6
C1 1 5 57 Scirpus cyperinus 1
unknown #1 50%
C2 10- unknown #1 10%
C3 3 unknown #1 3%
C4 2 27 unknown #1 25%
C5 7 42 unknown #1 35%
C6 35 unknown #1 35%
C7 2 12 o unknown #1 10%
Al 1 1
A2 20 20 43 Cyperus strigosus 2%,
unknown #1 1 %
A3 35 2 49 unknown #1 10%, Polygonum
h dro i eroides 1 %, C erus iris 1%
A4 1 6_ unknown #1 5%
A5 5 1 1 14 xO?o unknown #1 5%
Rhynchospora pallida I%
C erus stri onus 1
131 5 5 12, Typha latifolia 2%
B2 2 5 Typha latifolia3%
B3 1 7 10 Typha latifolia2%
B4 3 3
B5 3 3`-
B6 2 10 22'; Typha latifolia 10%
B7 2 1 4 -1 Typha latifolia I%
B8 4 6 _ Typha latifolia1 %
Eleocharis microca a 1%
B9 1 Cyperus globulosus 1 %
B10 1 1 ,
1311 1 1 w O
B12 3 4 Typha latifolia 1 %
3A1 1 10 41- unknown #1 30%
3A2 3 3 37 ' unknown #1 30%,
Ludwi is re ens 1 %
3A3 5 40- unknown #1 35 %
3A4 MISSING PLOT STAKE
3A5 2 2 14- unknown #1 10%
3A6 2 9 algLScirpus cyperinus 3%, Cyperus
globulosus I%, Ludwigia repens 1 %,
Luzula multifllora 2%
3A7 4 10 Scirpus cyperinus 4%, Carex alba 2%

15
1

i

6.4 Created Wetland Vegetation Conclusions
Seven acres were planted with 5,150 hardwood seedlings in March 2002 and seven vegetation
monitoring plots were established in the wetland creation area. The Fall 2002 vegetation
monitoring revealed an average density of 415 trees per acre, well above the 320 tree/acre
minimum requirements. Nucor will continue to monitor this site for the next four years.
The littoral shelves encompass approximate 2.86 acres along the periphery of the four stormwater
ponds. The four ponds (B1, Al, A3, and Cl) were planted and sampled using transects that parallel
the ponds edge for a total of thirty one sample plots. The littoral shelves were planted in the
Spring 2001 and Spring 2002 and are typically 10 to 12 feet wide. As seen in the attached
photographs the vegetation herbaceous vegetation has been established on the littoral shelves.
Baseline monitoring at the littoral shelves indicates a successful attempt to introduce aquatic
vegetation to the shoreline of the stormwater ponds. We expect additional naturally occurring
herbaceous species to become more abundant and diverse in the future.
7.0 SUMMARY 2002

1

Hydrologic monitoring indicated that the site is consistently meeting the success criteria. The
shortest period of inundation/saturation was 24 percent of the growing season. The gauges
indicated that inundation varied from 24 percent to 59 percent for the 2002 growing season. The
reference wetland site indicated saturation/inundation for 9 percent of the growing season. Four
of the seven vegetative plots indicated an average tree density of over 320 trees per acre. Total
average tree density across all seven plots was 415 trees per acre.
Nucor Steel will continue monitoring the site to evaluate hydrologic and vegetation success for
the next four years and submit those reports to the appropriate agencies on an annual basis.
16

1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
8.0 LITERATURE CITED
Corps of Engineers Wetlands Delineation Manual, 1987. by Environmental Laboratory.
Department of Army. Waterways experiment Station. Vicksburg, Mississippi. 99 pp. plus
appendices.
Natural Resources Conservation Service, Hertford County Soil Survey, 1984.
Radford, Alhes, and Bell, Manual of the Vascular Flora of the Carolinas, 1968. University of North
Carolina Press, Chapel Hill.
Revised Compensatory Wetlands Mitigation Plan for Nucor Steel Plate Recycling Mill, Hertford
County, November 8, 1999.
17
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PHOTOGRAPHS
18

a 1',s - ''?7
N
Photograph 1. Overview of 7-acre creation Area, October 2002. Facing NE Transect 3
19
Photograph 2. Overview of 7-acre creation Area, October 2002. Facing NE. Transect 1

0

KIP,
i

Photograph 4. Creation Area, Transect No. 1, Plot 2, October 2002. Facing NE
20
Photograph 3. Creation Area, Transect No. 1, Plot 1, October 2002. Facing NE

?. u
i..
Photograph 6. Creation Area, Transect No. 2, Plot 4, October 2002. Facing NE
21
Photograph 5. Creation Area, Transect No. 1, Plot 3, October 2002. Facing NE

Photograph 7. Creation Area, Transect No. 2, Plot 5, October 2002. Facing NE

Photograph 8. Creation Area, Transect No. 3, Plot 6, October 2002. Facing NE
22

'Oil
Photograph 9. Creation Area, Transect No. 3, Plot 7, October --002. Facing NE
,s
yi
0
Photograph 10. Pond C 1 Plot 1. October 2002. Facing North
23

Kip,
> .1_
ilv A,
_ t. .1 t
Photograph 11. Pond C 1 Plot 2. October 2002. Facing East

Photograph 12. Pond C 1 Plot 3. October 2002. Facing East
24

rr 14
4
EUAMAYNU7,Rt?
Photograph 13. Pond C I Plot 4. October 2002. Facing East
' .t i - 1 ty
-rq
?-
P.7otoL. aph 14. -id C 1 Plot 5. October 2002. Facing North
25
s

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Photograph 15. Pond C 1 Plot 6 October 2002. Facing north east.

Photograph 16. Pond C 1 Plot 7 October 2002. Facing Fay
26
Photograph 17. Pond B 1 Plot 1 October 2002. Facing east.
Photograph 18. Pond B 1 Plot 2 October 2002. Facing north.
27

19. Pond B 1 Plot 3 October 2002. Facing south.
28

mow" `
Photograph 20. Pond B 1 Plot 4 October 2002. Facing south.

a
29
Photograph 21. Pond B 1 Plot 5 October 2002. Facing south.
Photograph 22. Pond B 1 Plot 6 October 2002. Facing southeast.
II

1

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? t y C ESL wO ;_ 1 ? #-
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Photo,-raYci n?: i' = Ptct 7 October 2002. Facing noria

a

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i,
k.
'I' Photograph 24. Pond B1 Plot 8 October 2002. Facing west.
1 30

31

r yi4
Photograph 25. Pond B 1 Plot 9 October 2002. Facing west.
Photograph 26. Pond B 1 Plot 10 October 2002. Facing north.

41
Photograph 2i. Puna B Pict i i July 2002. Facm.4 aorta.
' ;v-!
Photograph 28. Pond B 1 Plot 12 July 2002. Facing north.
32

Photograph 30. Pond Al Plot 2 October 2002. Facing north.
33
Photograph 29. Pond Al Plot 1 October 2002. Facing north.

Photograph 31. Pond Al Plot 3 October 2002. Facing north
?f
71
Photograph 32. Pond Al Plot 4 October 2002. Facing north

34
r

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k,a3.
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A?i
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r? ? r r ? T
Photograph 34. r -ld -k- Piet 1 O.,;tober 2o0l Facing south" est.
35
Photograph 33. Pond Al Plot 5 October 2002. Facing north.

t
ti v
r r« ?R
41
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Photograph 3?. Pond _V; Plot 2 October 2002- Facing southwest.
Vii."
d
r,
Photograph 36. Pond A3 Plot 3 October 2002. Facing northwest.
36
NO PICTURE; Missing Plot Stake
Photograph 37. Pond A3 Plot 4 October 2002. Facing east.
4 ;? t
Photograph 38. Pond A3 Plot 5 October 2002. Facing northwest.
37

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t fl ,r _.u
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Photograph 39. Pond A3 Plot 6 Octot
ri
,er 2002. Facing east.
K t `?
t
et ."
1 ? A? ? FI
6Y
v .
L_apr !: ? : S ._ :'_ot ? tuber 2002. Facing east.
i
38

Figures

Nucor Steel CLEARWATER LOCATION MAP
Environmental Consultants, Inc.
Hertford County, 300 N. Main Street, Ste 202
Hendersonville, NC 28792 Figure 1
North Carolina 828-698-9800
Scale 1:275,000
1"s 4.34 mi ?
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UNDERWATER ANOMALY ~
TARGET CHOWAN-A a a ~ I 8 ~ ~ N
W/TN 200' BUFFER q~ W a a ~ W
o a ~
, , , , y , ? a °z °z ~ t/~ Q 4
,,,4•,; ~ ~ DOCK CK PORT ~ W ~ o ~ ~ DO ~ a~~Z~
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? I I . 4 I , f I , I I , . I FORESTRY I ~ SITE , \ _ 1 1 \ I f 1 \ , R , • .
1 1 ? , I I / f I / I 1 R \ I , , GEMEN , \ I ANA , ~ I\ ? ? f r t R I ? UFFE I I UPLANDS B I 100 ~ I ~ a W ~ ~ F ~ ~
( AREA f, , . r RES ~ ill - ~ • • • t 48,82 AC ~ ~ , °D ~ ~ ~ i
~ I I \ 1 I U o o a o
U.S. I , TERS OF THE i ~ I NT S/WA I RESTRY EQUIPME W~i~`~a 00. s < s I
PRESERVED WETLAND I \ FO RfT 1 r I ~ ~ ~ MANAGEMENT ;fAClL/TIES r' ~ ~ ~ W F,p
14.87 ACRES (DN SITE) ~ I \ I I AREA I I 1 _ I .l ~ D I ~ I ,
I \ I 1 S/WATERS OF THE U.S. ~ 1 ~ FiN/S ETLAND I H I AMB/fi~T - ~xrsriNC
IMPACTED W I ED •J \l pR I ~ ~ I po~cr FILL) I M MONITORING / NouSts / ~ rn N ~
1,71 ACRES (DN SITE ? I / SCR $ sr / ap EE ' I ~ SjpRAC L I ~ ~ ~ ~ ~ o I I sTAr~aN - i
T E U. S. ~ i OXYGEN / 4 A , TED WETLANDS/WATERS OF H ~ , 1 AREA I I ~
IMPAC ~ ~ ~ PLANT / ~ 1,, RES (CORRIDOR CROSSINGS) i m , FACILITY I ~ ~ i ? to ~ M N I ~ I 00 BUFFE
0,61 AC / O I i 1~• ~ fem. ~ . 1 ~ P^ V ~ ~ XOUSE ~
THE - 0 o NDS/WATERS OF U.S. , ~ a•
CREATED WETLA i ry ~
7,05 ACRES ~ i RESTRY FO ll ~ •cY~, k' I, I ~ ARCNAEOLO 1 Q
~ NACEMENT _ Il XIS ~-I . ~ .1 I I .
CAMA 75 AEC , AR.A S,ORMWATE ~ ~ POND B? l / , ~I ? I ',_I11 ~ ~ ~ ~
\ I , y ~ STORMWATER I\ ! \ I ~ i~- I Il ~ MILL SCALE ~ ri ~
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BRAWN D.P.S.
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