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HomeMy WebLinkAbout20100375 Ver 1_Application_20100518s s" STATE OF NORTH CAROLINA DEPARTMENT OF TRANSPORTATION BEVERLY EAVES PERDUE GOVERNOR May 12, 2010 Ms. Amy Euliss NC DENR Division of Water Quality 585 Waughtown Street Winston-Salem, NC 27107 Mr. Andrew Williams US Army Corps of Engineers 6508 Falls of the Neuse Suite 120 Raleigh, NC 27615-6814 (Two Copies) 1®®375 Subject: Guilford County, Farragut Street (SR 9901) Off Randleman Rd near 1-40 Project Number # 7B.204111 To Whom It May Concern: 0 '5D 44 18 2p ?O D? 0S APR?AIi Anvq? )BY,o?? 1%0? EUGENE A. CONTI, JR. SECRETARY The North Carolina Department of Transportation (NCDOT) proposes to place riprap around the bents of a bridge on Farragut Street (SR 9901) in Guilford County. The riprap is necessary in order to stop scouring around the base of the bents and therefore maintain the structural integrity of the bridge. This activity will result in permanent impacts to South Buffalo Creek. The NCDOT anticipates that the activity will be authorized under Nationwide Permit (NWP) 3 . This application is intended as a request for written authorization from the US Army Corps of Engineers for the Nationwide 3 as described under General Condition #27. This package is also being forwarded to the NC Division of Water Quality as a courtesy notification and for review of applicability of a request for an exemption of the Jordan Lake Buffer Rules. The following information is being provided to satisfy conditions of the Nationwide Permit and General Water Quality Certification. P.O. Box 14996 Greensboro, NC 27415-4996 Telephone No. (336) 334-3192 Fax No. (336) 334-3637 PROJECT INFORMATION Road Name SR Number Project Length miles Classification Farra ut Street SR 9901 N/A Subdivision River Basin: DWQ ID Water Quality Desi nation % Impervious Surface Cape Fear 16-11-14-2 WS-V; NSW N/A Buffer Rules' Buffer Rule Conditions (where applicable) Yes Jordan Lake Buffer b Protected Species Present Mapped Historic Properties CAMA AEC Essential Fishery Habitat No No No No ' Separate documentation attached as needed: ' See the attached Endangered Species Review Sheet for further information Applicable - See the attached Historic Review Letter for further information RIPRAP PLACEMENT Site Station N/A Stream Type Perennial Existing Stream 45 feet Proposed 45 feet Width Stream Width Construction Place Class II riprap in stream at base of Dewatering N/A Method bents utilizing a mini-escavator with "thumb". Device' A turbidity curtain will be utilized to minimize turbidity. No equipment is proposed to be in the stream. Burial Depth N/A E/C Plan N/A Date Construction As soon as practicable Duration One week Date Impacts ft. A roximatel 60 total linear feet of permanent stream impacts. Special Conditions Restoration Plan Within 15 working days of the project completion any disturbed area adjacent to the stream will be L I restored and seeded. When RCP = reinforced concrete pipe; CMP = Corrugated metal pipe; CMPA = Corrugated metal pipe arch; E/C = Erosion control. 'A less intrusive dewatering device may be used in lieu of the one proposed. MINIMIZATION INFORMATION . Impacts will be minimized, by strict enforcement of Best Management. Practices for the protection. of surface waters and wetlands, restrictions against the staging. of equipment in or adjacent to waters of. the US, and coordination (including a pre-construction meeting) with the Division Environmental Officer. MITIGATION INFORMATION Stream mitigation is not anticipated, as the impacts to any individual stream do not exceed 150 feet Wetland mitigation is not anticipated, as wetland impacts do not exceed 0.10 acres and do not occur in a unique natural wetland. APPLICATION INFORMATION Enclosed please find the Pre-construction Notification Form and supporting documentation for the above referenced project. If you have any questions or need any additional information, please contact Jerry Parker at (336) 256-2063. Your time and effort are appreciated. Sincerely, &r.- J.M. Mills, P.E. Division Engineer, Division 7 Enclosures CC: Tim Powers, Bridge Maintenance NCDOT Barry Harrington, NCDOT S. Lane Hall, NCDOT o?or, WATFROG y o ? Office Use Only: Corps action ID no. DWQ project no. Form Version 1.3 Dec 10 2008 Pre-Construction Notification PCN Form A. Applicant Information 1. Processing 1a. Type(s) of approval, sought from the Corps: Permit El Section 10 Permit ®Section 404 tb. Specify Nationwide Permit (NWP) number: 3 or General Permit (GP) number: 1c. Has the NWP or GP number been verified by the Corps? ? Yes ® No 1d. Type(s) of approval sought from the DWQ (check all that apply): ® 401 Water Quality Certification - Regular ? Non-404 Jurisdictional General Permit ? 401 Water Quality Certification - Express ® Riparian Buffer Authorization le. Is this notification solely for the record because written approval is not required? For the record only for DWQ 401 Certification: ® Yes ? No For the record only for Corps Permit: ? Yes ®No If. Is payment into a mitigation bank or in-lieu fee program proposed for mitigation of impacts? If so, attach the acceptance letter from mitigation bank or in-lieu fee program. ? Yes ® No 1g. Is the project located in any of NC's twenty coastal counties. If yes, answer 1h below. ? Yes ® No 1 h. Is the project located within a NC DCM Area of Environmental Concern (AEC)? ? Yes ® No 2. Project Information 2a. Name of project: Farragut Street SR 9901 2b. County: Guilford 2c. Nearest municipality / town: Greensboro 2d. Subdivision name: N/A 2e. NCDOT only, T-I.P. or state project no: WBS # 7B.204111 3. Owner Information 3a. Name(s) on Recorded Deed: 3b . Deed Book and Page No. 3c. Responsible Party (for LLC if applicable): 3d. Street address: 3e. City, state, zip: 3f. Telephone no.: 3g. Fax no.. 3h. Email address: Page 1 of 11 PCN Form -Version 1.3 December 10, 2008 Version 4. Applicant Information (if different from owner) 4a. Applicant is: ® Agent ? Other, specify: 4b. Name: J. M. Mills 4c. Business name (if applicable): Division Engineer NCDOT Division Seven 4d. Street address: P.O. Box 14996 4e. City, state, zip: Greensboro, NC 27415 4f. Telephone no.: 336 `334-3297 4g. Fax no.. 4h. Email address: 5. Agent/Consultant Information (if applicable) 5a. Name: Jerry Parker 5b. Business name (if applicable): Division Environmental Supervisor 5c. Street address: P.O. Box 14996 5d. City, state, zip: Greensboro, NC 27415 5e. Telephone no.: 336 256-2063 5f. Fax no.: 5g. Email address: Page 2 of 11 PCN Form - Version 1.3 December 10, 2008 Version B. Project Information and Prior Project History 1. Property Identification 1 a. Property identification no. (tax PIN or parcel ID): N/A Latitude: 36.0332107 N Longitude: - .1b. Site coordinates (in decimal degrees): 79.8130460 W (DD.DDDDDD) (-DD.DDDDDD) 1c. Property size::... N/A acres . 2.. Surface Waters 2a. Name of nearest body of water (stream, river, etc.) to UT to South BuffaloCreek proposed project: 2b. Water Quality Classification of nearest receiving water: WS-V; NSW. 2c. River basin: Cape Fear 3. Project Description 3a. Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of this application: Commercial and Business Area 3b. List the total estimated acreage of all existing wetlands on the property: 0 3c. List the total estimated linear feet of all existing streams (intermittent and perennial) on the property: 60 feet 3d. Explain the purpose of the proposed project: Secure support pilings of bridge. Scouring has occurred at base of pilings and is jepardrzing the structural integrity of interior bents # 1 and # 2. 3e. Describe the overall project in detail, including the type of equipment to be used: The bents will receive Class II riprap placed around the lower area of the bents. A turbidity curtain will be used to limit onsle turbidly. Riprap will be brought in by mini-escavator with a "thumb" and placed around bents.No equipment is proposed to be in the stream. 4. Jurisdictional Determinations 4a. Have jurisdictional wetland or stream determinations by the Corps or State been requested or obtained for this property / ? Yes ® No ? Unknown project (including all prior phases) in the past? Comments: 4b. If the Corps made the jurisdictional determination, what type Preliminary ? Final E] of determination was made? 4c. If yes, who delineated the jurisdictional areas? Agency/Consultant Company: Name (f known): Other: 4d. If yes, list the dates of the Corps jurisdictional determinations or State determinations and attach documentation. 5. Project History 5a. Have permits or certifications been requested or obtained for ? Yes ®No ? Unknown this project (including all prior phases) in the past? 5b. If yes, explain in detail according to "help file" instructions. Page 3 of 11 PCN Form - Version 1.3 December 10, 2008 Version 6. Future Project Plans 6a. Is this a phased project? ? Yes ®No 6b. If yes, explain. Page 4 of 11 PCN Form - Version 1.3 December 10, 2008 Version C. Proposed Impacts Inventory 1. Impacts Summary Ia. Which sections were completed below for your project (check all that apply): ? Wetlands ® Streams - tributaries ® Buffers ? Open Waters ? Pond Construction 2. Wetland Impacts If there are wetland impacts proposed on the site, then complete this question for each wetland area impacted. 2a. 2b. 2c. 2d. 2e. .2f. Wetland impact Type of jurisdiction number - Type of impact Type of wetland Forested (Corps - 404, 10 Area of impact Permanent (P) or (if known) DWQ - non-404, other) (acres) Temporary W1 ? P ? T ? Yes ? Corps ? No ? DWQ W2 ? P ? T ? Yes ? Corps ? No ? DWQ W3 ? P ? T ? Yes ? Corps ? No ? DWQ W4 ? P ? T ? Yes ? Corps ? No ? DWQ W5 ? P ? T ? Yes ? Corps ? No ? DWQ ? Yes ? Corps W6 ? P ? T ® No ? DWQ 2g. Total wetland impacts 2h. Comments: 3. Stream Impacts If there are perennial or intermittent stream impacts (including temporary impacts) proposed on the site, then complete this question for all stream sites impacted. 3a. 3b. 3c. 3d. 3e. 3f. 3g. Stream impact Type of impact Stream name Perennial Type of jurisdiction Average Impact number - (PER) or (Corps - 404, 10 stream length Permanent (P) or intermittent DWQ - non404, width (linear Temporary (T) (INT)? other) (feet) feet) S1 ®P ? T Riprap in stream South Buffalo Creek ® PER [I INT ® Corps ® DWQ 45 ft 60 feet S2 ? P ? T ? PER ? Corps ? INT ? DWQ S3 ? P ? T ? PER ? Corps ? INT ? DWQ ? PER ? Corps S4 ? P ? T ? INT ? DWQ ? PER ? Corps S5 ? P ? T ? INT ? DWQ ? PER ? Corps S6 ? P ? T ? INT ? DWQ 3h. Total stream and tributary impacts 60 feet 3i. Comments: Page 5 of 11 PCN Form -Version 1.3 December 10, 2008 Version 4. Open Water Impacts If there are proposed impacts to lakes, ponds, estuaries, tributaries, sounds, the Atlantic Ocean, or any other open water of the U.S. then individually list all open water impacts below. 4a. Open water impact number - Permanent (P) or Temporary T 4b. Name of waterbody (if applicable) 4c. Type of impact 4d. Waterbody type 4e. Area of impact (acres) Ot ?P?T 02 ?P?T 03 ?P?T 04 ?P?T 4f. Total open water impacts 4g. Comments: 5. Pond or Lake Construction If pond or lake construction proposed, then complete the chart below. 5a. Pond ID 51b. Proposed use or purpose of 5c. Wetland Impacts (acres) 5d. Stream Impacts (feet) 5e. Upland (acres) number pond Flooded Filled Excavated Flooded Filled Excavated Flooded P1 P2 5L Total 5g. Comments: 5h. Is a dam high hazard permit required? ? Yes ? No If yes, permit ID no: 5i. Expected pond surface area (acres): 5j. Size of pond watershed (acres): 5k. Method of construction: Page 6 of 11 PCN Form - Version 1.3 December 10, 2008 Version 6. Buffer Impacts (for DWQ) If project will impact a protected riparian buffer, then complete the chart below. If yes, then individually list all buffer impacts below. If an impacts require mitigation, then you MUST fill out Section D of this form. 6a. ? Neuse ?Tar-Pamlico ®Other: Jordan Project is in which protected basin? ? Catawba ? Randleman 6b. 6c. 6d. 6e. 6f. 6g. Buffer impact number - Reason Buffer Zone 1 impact Zone 2 impact Permanent (P) for impact Stream name mitigation (square feet) (square feet) or Temporary required? M B1 ? PEE] T Temporary road South Buffalo Creek ? Yes ®No 300 sf of temp. impacts 200 sf of temp. impacts B2 ?P?T ?Yes ? No B3 ?P?T ?Yes ? No 6h. Total buffer impacts 300 sf of temp. impacts 200 sf of temp. impacts 6i. Comments: Total impact of the temporary road will be less than 2500 sf. NCDOT is requesting an exemption from the Jordan buffer rules as stated in Table of Uses in 15A NCAC 02B.0267(9). Temporary road will not exceed 10 ft in width and will be restored by reseeding, mulching and/or coir fiber matting as needed. D. Impact Justification and Mitigation 1. Avoidance and Minimization 1a. Specifically describe measures taken to avoid or minimize the proposed impacts in designing project. Best Management Practices will be utilized during construction. Temporary roads were designed to minimize impact in buffer area. 1b. Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques. .Impacts will be minimized by utilization of Best Management Practices and by utilizing a turbidity curtain. Also, see 6i. Pre- construction meeting with Environmental Superevisor will take place prior to commencing construction. Utilization of a mini- escavator with a "thumb" will eliminate the need for any equipment in the stream. 2. Compensatory Mitigation for Impacts to Waters of the U.S. or Waters of the State 2a. Does the project require Compensatory Mitigation for ? Yes ®No impacts to Waters of the U.S. or Waters of the State? 2b. If yes, mitigation is required by (check all that apply): ? DWQ ? Corps ? Mitigation bank 2c. If yes, which mitigation option will be used for this project? ? Payment to in-lieu fee program ? Permittee Responsible Mitigation 3. Complete if Using a Mitigation Bank 3a. Name of Mitigation Bank: 3b. Credits Purchased (attach receipt and letter) Type Quantity Page 7 of 11 PCN Form - Version 1.3 December 10, 2008 Version 3c. Comments: 4. Complete if Making a Payment to In-lieu Fee Program 4a. Approval letter from in-lieu fee program is attached. ? Yes 4b. Stream mitigation requested: linear feet 4c. H using stream mitigation, stream temperature: ? warm ? cool ?cold 4d. Buffer mitigation requested (DWQ only): square feet 4e. Riparian wetland mitigation requested: acres 4f. Non-riparian wetland mitigation requested: acres 4g. Coastal (tidal) wetland mitigation requested: acres 4h. Comments: 6. Complete if Using a Permittee Responsible Mitigation Plan 5a. If using a permittee responsible mitigation plan, provide a description of the proposed mitigation plan. 6. Buffer Mitigation (State Regulated Riparian Buffer Rules) - required by DWQ 6a. Will the project result in an impact within a protected riparian buffer that requires buffer mitigation? ? Yes ®No 6b. If yes, then identify the square feet of impact to each zone of the riparian buffer that requires mitigation. Calculate the amount of mitigation required. Zone 6c. Reason for impact 6d. Total impact (square feet) Multiplier 6e. Required mitigation (square feet) Zone 1 3 (2 for Catawba) Zone 2 1.5 6f. Total buffer mitigation required: 6g. If buffer mitigation is required, discuss what type of mitigation is proposed (e.g., payment to private mitigation bank, permittee responsible riparian buffer restoration, payment into an approved in-lieu fee fund). 6h. Comments: Page 8 of 11 PCN Form -Version 1.3 December 10, 2008 Version E. Stormwater Management and Diffuse Flow Plan (required by DWQ) 1. Diffuse Flow Plan 1 a. Does the project include or is it adjacent to protected riparian buffers identified ® Yes ? No within one of the NC Riparian Buffer Protection Rules? 1b. If yes, then is a diffuse flow plan included? If no, explain why. Comments: Impacts in the buffer will be temporary and qualify for an exemption as ? Yes ® No described in 15 NCAC 0213.0267 (9) 2. Stonmwater Management Plan 2a. What is the overall percent imperviousness of this project? N/A % 2b. Does this project require a Stonmwater Management Plan? ? Yes ®No 2c. If this project DOES NOT require a Stormwater Management Plan, explain why: No i ncreased permanent impervious coverage is anticipated. Therefore, stormwater flow will not increase. 2d. If this project DOES require a Stormwater Management Plan, then provide a brief, narrative description of the plan: ? Certified Local Government 2e. Who will be responsible for the review of the Stormwater Management Plan? ® DWQ Stonmwater Program ? DWQ 401 Unit 3. Certified Local Government Stormwater Review 3a. In which local government's jurisdiction is this project? N/A ? Phase II 3b. Which of the following locally-implemented stormwater management programs ? NSW El USMP apply (check all that apply): ? Water Supply Watershed ? Other: 3c. Has the approved Stonmwater Management Plan with proof of approval been T ? Yes ®No attached? 4. DWQ Stonmwater Program Review ? Coastal counties ? HQW 4a. Which of the following state-implemented stormwater management programs apply ? ORW (check all that apply): ? Session Law 2006-246 ? Other: 4b. Has the approved Stonmwater Management Plan with proof of approval been attached? ? Yes ®No 5. DWQ 401 Unit Stormwater Review 5a. Does the Stormwater Management Plan meet the appropriate requirements? ? Yes ? No 5b. Have all of the 401 Unit submittal requirements been met? ? Yes ? No Page 9 of 11 PCN Form -Version 1.3 December 10, 2008 Version F. Supplementary Information 1. Environmental Documentation (DWQ Requirement) la. Does the project involve an expenditure of public (federaVstate/local).funds or the ® Yes ? No use of public (federal/state) land? 11b. If you answered "yes" to the above, does the project require preparation of ari ' environmental document pursuant to the requirements of the National or State ? Yes ®No (North Carolina) Environmental Policy Act (NEPA/SEPA)? 1c. If you answered "yes" to the above, has the document review been finalized by the State Clearing House? (If so, attach a copy of the NEPA or SEPA final approval ? Yes ? No letter.) Comments: 2. Violations (DWQ Requirement) 2a. Is the site in violation of DWQ Wetland Rules (15A NCAC 2H .0500), Isolated Wetland Rules (15A NCAC 2H .1300), DWQ Surface Water or Wetland Standards, ? Yes ® No or Riparian Buffer Rules (15A NCAC 2B .0200)? 2b. Is this an after-the-fact permit application? ? Yes ® No 2c. If you answered "yes" to one or both of the above questions, provide an explanation of the violation(s): 3. Cumulative Impacts (DWQ Requirement) 3a. Will this project (based on past and reasonably anticipated future impacts) result in ? Yes ®No additional development, which could impact nearby downstream water quality? 3b. If you answered "yes" to the above, submit a qualitative or quantitative cumulative impact analysis in accordance with the most recent DWQ policy. If you answered "no," provide a short narrative description. 4. Sewage Disposal (DWQ Requirement) 4a. Clearly detail the ultimate treatment methods and disposition (non-discharge or discharge) of wastewater generated from the proposed project, or available capacity of the subject facility. NA Page 10 of 11 PCN Form - Version 1.3 December 10, 2008 Version 5. Endangered Species and Designated Critical Habitat (Corps Requirement) 5a. Will this project occur in or near an area with federally protected species or ? Yes ® No habitat? 5b. Have you checked with the USFWS concerning Endangered Species Act ? Yes No impacts? ? Raleigh 5c. If yes, indicate the USFWS Field Office you have contacted. ? Asheville 5d. What data sources did you use to determine whether your site would impact Endangered Species or Designated Critical Habitat? US Fish and Wildlife Web Site 6. Essential Fish Habitat (Corps Requirement) 6a. Will this project occur in or near an area designated as essential fish habitat? ? Yes ® No 6b. What data sources did you use to determine whether your site would impact Essential Fish Habitat? N/A 7. Historic or Prehistoric Cultural Resources (Corps Requirement) 7a. Will this project occur in or near an area that the state, federal or tribal governments have designated as having historic or cultural preservation ? Yes ® No status (e.g., National Historic Trust designation or properties significant in North Carolina history and archaeology)? 7b. What data sources did you use to determine whether your site would impact historic or archeological resources? National Historic Register Web Site 8. Flood Zone Designation (Corps Requirement) 8a. Will this project occur in a FEMA-designated 100-year floodplain? ? Yes ®No 8b. If yes, explain how project meets FEMA requirements: 8c. What source(s) did you use to make the floodplain determination? NC Floodplain Mapping Information System J.M. Mills ' f1 .?1 %iezo I nptr? li t/A t' Si V A t 5-13-10 Date Applicant/Agent s Printed Name pp can gen s gna ure (Agent's signature is valid only if an authorization letter from the applicant is provided.) Page 11 of 11 PCN Form -Version 1.3 December 10, 2008 Version Guilford County Bridge #328 SR 9901 Farragut Street Location 1.74 mile East of Jct SR 4121 (Randleman Rd) A Bridge Scour Assessment preformed on November 30, 2009 has reviled that Countermeasures are required at Interior Bents #1 and #2. Report species that Class It Rip-Rap be placed around Interior Bents #1 and #2. Prepared By: 1 U b? Bridge MaintenanceTQ44- Approved By: Division Bridge Engineer Stream Banks Date 3-// Zo/ d Date 3-11-2a/(J page 1 of 5 Guilford County Bridge #328 SR 9901 Farragut Street Location 1.74 mile East of Jct SR 4121 (Randleman Rd) Construction Sequence for West end of bridge. 1 Place turbidity curtain in stream around work area. 2 Remove 20 foot section of guardrail in the north west quadrant of bridge. 3 Dump Class II Rip Rap behind guardrail at opening. 4 Use backhoe to push Rip Rap down the slope. 5 Use mini excavator to construct access road and place rip rap around H-Piles. road turbidity curtain Stream Banks page 2 of 5 Guilford County Bridge #328 SR 9901 Farragut Street Location 1.74 mile East of Jct SR 4121 (Randleman Rd) Construction Sequence for west end of bridge. 6 Grade distrubed areas. 7 Seed, mulch and place coir fiber mat as needed. 8 Replace guardrail. 9 Remove turbidity curtin. Stream Banks page 3 of 5 Guilford County Bridge #328 SR 9901 Farragut Street Location 1.74 mile East of Jct SR 4121 (Randleman Rd) Construction Sequence for East end of bridge. 1 Place turbidity curtain in stream around work area. 2 Remove chain link fence access road. Dump Class 11 Rip Rap for placement around interior bent. Use equipment to push Rip Rap close to bridge. Use mini excavator to construct access road and place rip rap around H-Piles. page 4 of 5 . . Guilford County Bridge #328 SR 9901 . Farragut Street Location 1.74 mile East of Jct SR 4121 (Randleman Rd) Construction Sequence for East end of bridge. 6 Grade distrubed areas. 7 Seed, mulch and place coir fiber mat as needed. 8 .,Repair chain link fence. 9 Remove turbidity curtin. turbidity curtain wSUUUeu deeds page 5 of 5 w 3 s t ?a 4 [ p ?m Lf0 ? OI EAixI L c?eov eVe G 5, ¢., q€a $ b. w at 3 $^pa,?a"pa w I ..^!!?w. ? xo Er.e Ww 4 I Wh"4 . q.] g ^. 'Y Q4 P bF'S'.,O 4' q °i AWN Ffll 4xLY C '^-?' ? ?i yt. GInMI 1.14 f?? x wnu fu $ -2?.+s e"re? ?-a ?. ? c }n`?`? ?d ? ? g31^por 1?8 ?.?Lf I p .? 4 Y f 6B C ^f 9'*?, WM'v'ct5v wMnritET a;,??_' I " - -K 6b_ ?p c `c 6 IISEU?.f41 ? Ta ? 771? E RlryAL4!(CS PA"d sl. f 1-y,e f o \ sEOOEDFIELD WE(HwILO wa(E)ral B k Tx?.,Mp G 220 133 _ .a / lid, @'W4 C?J 54F (IFf F I e 'N f/ rep8" N ILRY\? mm _ ?tm --'T ' i ¢ys`ne I s9 e6/ T. f e _ ? 4 °'g ? - £°o. 'g un rF? ? `' -: fx 3 B.3 k.._. __ 3 . p?, u 4 Swn.« _ , ? -' ` ? ' { ?Cl^ J ?1 I t' ? ? 1' ?" //°y/ ? ? f 3 T ? 1 ' ?? i .i 4 \. t ^i LTC^f: ?t 4. . ?• .X.. /8 ? i 4 1? Vi. ? ? < t °' " cETmrr ? 3a ?8? _ i b ? 4$ A ? ..; C? vlYm M1' i3 y 1 n - v I spa.-? 4 ? ? W ''?"s Po. I 5 +*mf _._ ? u S r 2 Farragut Street- Interior bents on west side Farragut Street-Interior bents on east side Farragut Street- West side interior bent showing the effects of scouring