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June 5, 2007
MEMORANDUM
To: Sylvester Percival, Project Engineer, City of Raleigh Public Works Department
From: Rob Ridings, NC DWQ Transportation Permitting Unit ;e
Subject: Scoping comments on proposed widening and realignment to Falls Of Neuse Road (SR 2000) in Wake
County, NCDOT TIP No. U-4901.
Reference your correspondence dated May 30, 2007 in which you requested comments for the referenced project.
Preliminary analysis of the project reveals the potential for multiple impacts to jurisdictional streams, wetlands, and
riparian buffers in the project area. More specifically, impacts to:
Stream Name River Basin &
Subbasin Stream Classifications Stream Index Number
UTs to Falls Lake NEU 02 WS-IV, B, NSW, CA 27-(5.5)
Neuse River (& UTs NEU 02 WS-IV, NSW 27-(20.7)
Further investigations at a higher resolution should be undertaken to verify the presence of other streams and/or
jurisdictional wetlands in the area. In the event that any jurisdictional areas are identified, the Division of Water
Quality requests that the applicant consider the following environmental issues for the proposed project:
Project Specific Comments:
1. Falls Lake and the Neuse River are NSW waters of the State. DWQ is very concerned with sediment
and erosion impacts that could result from this project. DWQ recommends that highly protective sediment
and erosion control BMPs be implemented to reduce the risk of nutrient runoff to these waters. DWQ
requests that road design plans provide tfeatment of the storm water runoff through best management
practices as detailed in the most recent version of NC DWQ Stormwater Best Management Practices.
2. Review of the project reveals the presence of surface waters classified as Water Supply Critical Area in
the project study area. Given the potential for impacts to these resources during the project implementation,
the DWQ requests that the applicant strictly adhere to North Carolina regulations entitled "Design Standards
in Sensitive Watersheds" (15A NCAC 04B .0124) throughout design and construction of the project. This
would apply for any area that drains to streams having WS CA (Water Supply Critical Area) classifications.
Should a bridge project be located within the Critical Area of a Water Supply, the applicant will be required
to design, construct, and maintain hazardous spill catch basins in the project area. The number of catch
basins installed should be determined by the design of the bridge, so that runoff would enter said basin(s)
rather than flowing directly into the stream, and in consultation with the DWQ.
3. This project is within the Neuse River Basin. Riparian buffer impacts should be avoided and minimized
to the greatest extent possible pursuant to 15A NCAC 2B.0233.
NorthCarolin
Transportation Permitting Unit aAmIall ,
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone: [phone] / FAX [phone] / Internet: http://h2o.enr.state,nc.us/ncwetlands
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
An Equal Opportunity/Affirmative Action Employer- 50% Recycled/10% Post Consumer Paper
I
General Project Comments:
1. The environmental document should provide a detailed and itemized presentation of the proposed impacts
to wetlands and streams with corresponding mapping. If mitigation is necessary as required by 15A NCAC
2H.0506(h), it is preferable to present a conceptual (if not finalized) mitigation plan with the environmental
documentation. Appropriate mitigation plans will be required prior to issuance of a 401 Water Quality
Certification.
2. Environmental assessment alternatives should consider design criteria that reduce the impacts to streams
and wetlands from storm water runoff. These alternatives should include road designs that allow for
treatment of the storm water runoff through best management practices as detailed in the most recent
version of NC DWQ Stormwater Best Management Practices, such as grassed swales, buffer areas,
preformed scour holes, retention basins, etc.
3. After the selection of the preferred alternative and prior to an issuance of the 401 Water Quality
Certification, the applicant is respectfully reminded that they will need to demonstrate the avoidance and
minimization of impacts to wetlands (and streams) to the maximum extent practical. In accordance with
the Environmental Management Commission's Rules 11 5A NCAC 2H.0506(h)), mitigation will be
required for impacts of greater than 1 acre to wetlands. In the event that mitigation is required, the
mitigation plan should be designed to replace appropriate lost functions and values. The NC Ecosystem
Enhancement Program may be available for use as wetland mitigation.
4. In accordance with the Environmental Management Commission's Rules { 15A NCAC 2H.0506(h)),
mitigation will be required for impacts of greater than 150 linear feet to any single perennial stream. In the
event that mitigation is required, the mitigation plan should be designed to replace appropriate lost
functions and values. The NC Ecosystem Enhancement Program may be available for use as stream
mitigation.
5. DWQ is very concerned with sediment and erosion impacts that could result from this project. The
applicant should address these concerns by describing the potential impacts that may occur to the aquatic
environments and any mitigating factors that would reduce the impacts.
6. If a bridge is being replaced with a hydraulic conveyance other than another bridge, DWQ believes the use
of a Nationwide Permit may be required. Please contact the US Army Corp of Engineers to determine the
required permit(s).
7. If an old bridge is removed, no discharge of bridge material into surface waters is allowed unless otherwise
authorized by the US ACOE. Strict adherence to the Corps of Engineers guidelines for bridge demolition
will be a condition of the 401 Water Quality Certification.
8. Bridge supports (bents) should not be placed in the stream when possible.
9. Whenever possible, the DWQ prefers spanning structures. Spanning structures usually do not require work
within the stream or grubbing of the streambanks and do not require stream channel realignment. The
horizontal and vertical clearances provided by bridges allow for human and wildlife passage beneath the
structure, do not block fish passage and do not block navigation by canoeists and boaters.
10. Bridge deck drains should not discharge directly into the stream. Stormwater should be directed across the
bridge and pre-treated through site-appropriate means (grassed swales, pre-formed scour holes, vegetated
buffers, etc.) before entering the stream. Please refer to the most current version of NC DWQ Stormwater
Best Management Practices.
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11. If concrete is used during construction, a dry work area should be maintained to prevent direct contact
between curing concrete and stream water. Water that inadvertently contacts uncured concrete should not
be discharged to surface waters due to the potential for elevated pH and possible aquatic life and fish kills.
12. If temporary access roads or detours are constructed, the site shall be graded to its preconstruction contours
and elevations. Disturbed areas should be seeded or mulched to stabilize the soil and appropriate native
woody species should be planted. When using temporary structures the area should be cleared but not
grubbed. Clearing the area with chain saws, mowers, bush-hogs, or other mechanized equipment and
leaving the stumps and root mat intact allows the area to re-vegetate naturally and minimizes soil
disturbance.
13. Placement of culverts and other structures in waters, streams, and wetlands shall be below the elevation of
the streambed by one foot for all culverts with a diameter greater than 48 inches, and 20 percent of the
culvert. diameter for culverts having a diameter less than 48 inches, to allow low flow passage of water and
aquatic life. Design and placement of culverts and other structures including temporary erosion control
measures shall not be conducted in a manner that may result in dis-equilibrium of wetlands or streambeds
or banks, adjacent to or upstream and down stream of the above structures. The applicant is required to
provide evidence that the equilibrium is being maintained if requested in writing by DWQ. If this
condition is unable to be met due to bedrock or other limiting features encountered during construction,
please contact the NC DWQ for guidance on how to proceed and to determine whether or not a permit
modification will be required.
14. If multiple pipes or barrels are required, they should be designed to mimic natural stream cross section as
closely as possible including pipes or barrels at flood plain elevation and/or sills where appropriate.
Widening the stream channel should be avoided. Stream channel widening at the inlet or outliet end of
structures typically decreases water velocity causing sediment deposition that requires increased
maintenance and disrupts aquatic life passage.
15. If foundation test borings are necessary; it should be noted in the document. Geotechnical work is
approved under General 401 Certification Number 3624/Nationwide Permit No. 6 for Survey Activities.
16. Sediment and erosion control measures sufficient to protect water resources must be implemewed and
maintained in accordance with the most recent version of North Carolina Sediment and Erosion Control
Planning and Design Manual and the most recent version of NCS000250.
17. All work in or adjacent to stream waters should be conducted in a dry work area unless otherwise approved
by NC DWQ. Approved BMP measures from the most current version of NCDOT Construction and
.Maintenance Activities manual such as sandbags, rock berms, cofferdams and other diversion: structures
should be used to prevent excavation in flowing water.
18. Sediment and erosion control measures should not be placed in wetlands and streams.
19. Borrow/waste areas should avoid wetlands to the maximum extent practical. Impacts to wedamds in
borrow/waste areas could precipitate compensatory mitigation.
20. While the use of National Wetland Inventory (NWI) maps, NC Coastal Region Evaluation of Vetland
Significance (NC-CREWS) maps and soil survey maps are useful tools, their inherent inaccuracies require
that qualified personnel perform onsite wetland delineations prior to permit approval.
21. Heavy equipment should be operated from the bank rather than in stream channels in order to iminimize
sedimentation and reduce the likelihood of introducing other pollutants into streams. This equdpment
should be inspected daily and maintained to prevent contamination of surface waters from leaking fuels,
lubricants, hydraulic fluids, or other toxic materials.
22. In most cases, the DWQ prefers the replacement of the existing structure at the same location with road
closure. If road closure is not feasible, a temporary detour should be designed and located to avoid wetland
impacts, minimize the need for clearing and to avoid destabilizing stream banks. If the structure will be on
a new alignment, the old structure should be removed and the approach fills removed from the 100-year
floodplain. Approach fills should be removed and restored to the natural ground elevation. The area
should be stabilized with grass and planted with native tree species. Tall fescue should not be used in
riparian areas.
23. Riprap should not be placed in the active thalweg channel or placed in the streambed in a manner that
precludes aquatic life passage. Bioengineering boulders or structures should be properly designed, sized
and installed.
Thank you for requesting our input at this time. The applicant is reminded that issuance of a 401 Water Quality
Certification requires that appropriate measures be instituted to ensure that water quality standards are met and
designated uses are not degraded or lost. If you have any questions or require additional information, please contact
Rob Ridings at [phone].
cc: Eric Alsmeyer, US Army Corps of Engineers, Raleigh Field Office
Vince Rhea, NCDOT PDEA
Chris Militscher, Environmental Protection Agency
Travis Wilson, NC Wildlife Resources Commission
Gary Jordan, US Fish and Wildlife Service
Chris Murray, NCDOT Division 5
File Copy
6'itr1. Of ?aleigh
Worth Carolina
May 30, 2007
Rob Ridings
North Carolina Department of Environment & Natural Resources
1650 Mail Service Center
Raleigh, NC 27699
SUBJECT: Start of Study for Widening and Realignment of Falls of Neuse Road
City of Raleigh, Wake County, North Carolina (TIP U-4901)
Dear Mr. Ridings,
The City of Raleigh is initiating the project development, environmental analysis, and
engineering studies for the Widening and Realignment of Falls of Neuse Road. See Figure 1 for
project location. The project is included in the 2007-2013 North Carolina Transportation
Improvement Program (TIP) as TIP No. U-4901 and is scheduled for right of way acquisition
beginning in fiscal year 2009 and construction beginning in fiscal year 2011.
The City has selected URS Corporation as their engineering consultant for this study.
Figure 2 depicts the study area for the proposed project. By receipt of this information, we are
requesting your review and comments on the action. We would appreciate any information you
might have that would be helpful in evaluating potential impacts to the natural, human, or
physical environmental. If applicable, please identify any permits or approvals that may be
required by your agency. A scoping meeting will be scheduled in the immediate future to discuss
the proposed project in more detail. In order to include your comments in our materials for this
meeting, we would appreciate your response by .lame 25, 2007.
It is anticipated that an Environmental Assessment will be prepared for this project in accordance
with the National Environmental Policy Act. If you have any questions concerning the project,
please contact me at [phone].
Sincerely,
C=
Syl ester Percival, EI, Project Engineer
City of Raleigh, Public Works Department
Enclosures
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City of Raleigh
North Carolina A? Legend N
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Project Location
'iTY S
S
--- Interstate
US Route 0 0.5 1 2 3
NC Highway Miles
Local Road
Widening and Realignment of Figure 1
Falls of Neuse Road ------ County Boundary
Wake County a Municipal Boundary
Date: May 2007 Project Location