U-3605

Beverly Eaves Perdue
Governor
KAVID &00113 V"I mil
A
NC®ENR
North Carolina Department of Environment and Natural Resources
D v slon of Water Quality
Charles Wakild P E
Director
February 16 2012
To Melba McGee Environmental Coordinator Office of Legislative and Intergovernmental Affairs
From Rob Ridings NC Division of Water Quality "I ransportation Permitting Unit
Subject Scopmg comments on proposed Town of Clayton project East Front Street Extension in
Johnston County NCDOT TIP No U 3605 State Clearinghouse Project No 12 0179
Dee Freeman
Secretary
Reference your correspondence dated received February 7 2012 in which you requested comments for
the referenced project Preliminary analysis of the project reveals the potential for impacts to streams and
jurisdictional wetlands in the project area More specifically impacts to
Stream Name
River Basin &
Stream Classifications
Stream Index
303(d) Listing
Subbasin
Number
UT Neuse River
NEU 02
WS IV NSW
27 (38 5)
Yes
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 Town of Clayton consider the following environmental issues
for the proposed project
Protect Specific Comments
The Neuse River is class WS N NSW 303(d) waters of the State The Neuse River is on the 303(d)
list for impaired use for aquatic life due to turbidity NCDWQ is very concerned with sediment and
erosion impacts that could result from this project NCDWQ recommends that the most protective
sediment and erosion control BMPs be implemented in accordance with Design Standards in
Sensitive Watersheds (15A NCAC 04B 0124) to reduce the risk of further impairment to the Neuse
River NCDWQ requests that road design plans provide treatment of the storm water runoff through
best management practices as detailed in the most recent version of NCDWQ Stormwater Best
Management Practices
This project is within the Neuse River Basin Riparian buffer impacts shall be avoided and minimized
to the greatest extent possible pursuant to 15A NCAC 213 0233 New development activities located
in the protected 50 foot wide riparian areas within the basin shall be limited to uses identified
within and constructed in accordance with 15A NCAC 2B 0233 Buffer mitigation may be required
for buffer impacts resulting from activities classified as allowable with mitigation within the Table
of Uses section of the Buffer Rules or require a variance under the Buffer Rules A buffer mitigation
Transportation and Permitting Unit
1650 Mail Service Center Raleigh North Carolina 27699 1617
Location 512 N Salisbury St Raleigh North Carolina 27604
Phone [phone] \ FAX [phone]
Internet www ncwaterquality orq
An Equal Opportunity \ ABirmative Action Employer
NorthCarolina

plan including nse of the NC Ecosystem Enhancement Program must be provided to NCDWQ prior
to approval of the Water Quality Certification Buffer mitigation may be required for buffer impacts
resulting from activities classified as allowable with mitigation within the Table of Uses section
of the Buffer Rules or require a variance under the Buffer Rules A buffer mitigation plan including
use of the NC Ecosystem Enhancement Program must be provided to NCDWQ prior to approval of
the Water Quality Certification
General Project Comments
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 impact statement alternatives shall consider design criteria that reduce the impacts to
streams and wetlands from storm water runoff These alternatives shall include road designs that
allow for treatment of the storm water runoff through best management practices as detailed in the
most recent version of NCDWQ s Stormwater Best Management Practices Manual July 2007 such
as grassed swales buffer areas preformed scour holes retention basins etc
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 { 15A 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 shall 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
stream In the event that mitigation is required the mitigation plan shall be designed to replace
appropriate lost functions and values The NC Ecosystem Enhancement Program may be available
for use as stream mitigation
Future documentation including the 401 Water Quality Certification Application shall continue to
include an itemized listing of the proposed wetland and stream impacts with corresponding
mapping
6 NCDWQ is very concerned with sediment and erosion impacts that could result from this project
The applicant shall address these concerns by describing the potential impacts that may occur to the
aquatic environments and any mitigating factors that would reduce the impacts
An analysis of cumulative and secondary impacts anticipated as a result of this project is required
The type and detail of analysis shall conform to the NC Division of Water Quality Policy on the
assessment of secondary and cumulative impacts dated April 10 2004
8 The applicant is respectfully reminded that all impacts including but not limited to bridging fill
excavation and clearing and rip rap to jurisdictional wetlands streams and riparian buffers need to
be included in the final impact calculations These impacts in addition to any construction impacts

temporary or otherwise also need to be included as part of the 401 Water Quahty Certification
Application
9 Where streams must be crossed NCDWQ prefers bridges be used in lieu of culverts However we
realize that economic considerations often require the use of culverts Please be advised that
culverts should be countersunk to allow unimpeded passage by fish and other aquatic organisms
Mo eo er in areas where high quality we *land., or .1 ear•is a e impacted a b idge ma} pro ✓e
preterable When applicable the applicant should not install the bridge bents in the creek to the
maximum extent practicable
10 Whenever possible NCDWQ 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 shall allow for human and
wildlife passage beneath the structure Fish passage and navigation by canoeists and boaters shall
not be blocked Bridge supports (bents) should not be placed in the stream when possible
1 i Bridge deck drains shall not discharge directly into the stream Stormwater shall 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
NCDWQ s Stormwater Best Management Practices
12 Sediment and erosion control measures should not be placed in wetlands or streams
13 Borrow /waste areas should avoid wetlands to the maximum extent practical Impacts to wetlands in
borrow /waste areas will need to be presented in the 401 Water Quality Certification and could
precipitate compensatory mitigation
14 The 401 Water Quality Certification application will need to specifically address the proposed
methods for stormwater management More specifically stormwater shall not be permitted to
discharge directly into streams or surface waters
15 Based on the information presented in the document the magnitude of impacts to wetlands and
streams may require an Nationwide (NW) Permit application to the Corps of Engineers and
corresponding 401 Water Quality Certification Please be advised that a 401 Water Quality
Certification requires satisfactory protection of water quality to ensure that water quality standards
are met and no wetland or stream uses are lost Final permit authorization will require the submittal
of a formal application by the applicant and written concurrence from NCDWQ Please be aware
that any approval will be contingent on appropriate avoidance and minimization of wetland and
stream impacts to the maximum extent practical the development of an acceptable stormwater
management plan and the inclusion of appropriate mitigation plans where appropriate
16 If concrete is used during construction a dry work area shall be maintained to prevent direct contact
between curing concrete and stream water Water that inadvertently contacts uncured concrete shall
not be discharged to surface waters due to the potential for elevated pH and possible aquatic life and
fish kills
17 If temporary access roads or detours are constructed the site shall be graded to its preconstruction
contours and elevations Disturbed areas shall be seeded or mulched to stabilize the soil and
appropriate native woody species shall be planted When using temporary structures the area shall
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
18 Unless otherwise authorized placement of culverts and other structures in waters and streamsshall
be placed 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
nches to -allow to flov passage of water and aquatic life Desigp and piacerre�i* of cal ✓erts and
other structures including temporary erosion control measure. 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 NCDWQ If this condition is unable to
be met due to bedrock or other limiting features encountered during construction please contact
NCDWQ for guidance on how to proceed and to determine whether or not a permit modification
will be required
19 If multiple pipes or barrels are required they shall be designed to mimic natural stream cross section
as closely as possible including pipes or barrels at flood plain elevation floodplain benches and /or
sills may be required where appropriate Widening the stream channel should be avoided Stream
channel widening at the inlet or outlet end of structures typically decreases water velocity causing
sediment deposition that requires increased maintenance and disrupts aquatic life passage
20 Sediment and erosion control measures sufficient to protect water resources must be implemented
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
21 All work in or adjacent to stream waters shall be conducted in a dry work area 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 shall be used to
prevent excavation in flowing water
22 While the use of National Wetland Inventory (NWI) maps NC Coastal Region Evaluation of
Wetland 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
23 Heavy equipment should be operated from the bank rather than in stream channels in order to
minimize sedimentation and reduce the likelihood of introducing other pollutants into streams This
equipment shall be inspected daily and maintained to prevent contamination of surface waters from
leaking fuels lubricants hydraulic fluids or other toxic materials
24 Riprap shall 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
25 Riparian vegetation (native trees and shrubs) shall be preserved to the maximum extent possible
Riparian vegetation must be reestablished within the construction limits of the project by the end of
the growing season following completion of construction

Thank Vou 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 919 807 6403
cc Tom Steffens US Army Corps of Engineers Washington Field Office (electronic copy only)
Dnnald Wells Soil & Environmental Cnncultants
File Copy

Department of EnN ironment and Natural Resources
Project Revie" Form
1 rclect Number count\ Date ReLerved Date Response Due
This project is being reviewed as indicated below
ReLyional Office
Sections
In House Review
Asheville
✓ An
Marine Fisheries _ Waste Mgmt
c
Fayetteville
Water
_ Coastal Management _ Ai Quality
Mooresville
Aquifer Protection
Water Resources Management
Raleigh
Land Quality Engineer
_ Watei Suppl} Section
Washington
Parks & Recreation
Wilmington
_ Water Quality
_ Winston Salem
/ Water Quality (DOT)
Wildlife
r� Wildlife (DOT)
Date
In HOnSC Reviewer /A enm
Response (check all applicable)
No objection to project as proposed
Insufficient information to complete review
No comment
Other (specify or attach comments)
RETURN TO
Melba McGee
Ens ironmental Re-, ie" Coordinator
217 W Jones Street 1601 Mail Service Center
Raleigh, NC 27603 1601
in
r�' ryrynn tt s
7� '-,AND

Environmental Consultants, PA
Road Raleigh North Carolina 27614 Phone [phone] Fax [phone]
www SandEC com
TO N C Department of Administration January 26 2012
State Clearinghouse
1301 Mail Service Center
Raleigh NC 27699 1301
Attn Ms Valerie McMillan
RE REQUEST FOR ENVIRONMENTAL REVIEW SCOPING COMMENTS
TOWN OF CLAYTON PROPOSED EAST FRONT STREET EXTENSION PROJECT
JOHNSTON COUNTY NORTH CAROLINA NCDOT TIP # U 3605
Dear Ms McMillan
The purpose of this memo is to request scoping comments from the State Clearinghouse for an
Environmental Assessment to be completed under the National Environmental Policy Act
(NEPA) for the above referenced project The Town of Clayton is proposing to extend East Front
Street from its current eastern termination point eastward to and intersecting with NC 42 Figure
1 is a USGS base map with the location of the proposed road extension Funding for this work is
being provided by the Federal Highway Administration Preparation of an environmental review
under NEPA is required as a condition of receipt of those funds
The extension will consist of an approximate 3 220 ft long two lane asphalt road with two 12 foot
travel lanes curb and gutter along both sides of the road a storm drainage to collect and dispose
of runoff water traffic control lights signage and other necessary appurtenances Work
associated with the project will include but not be limited to clearing and disposal of trees and
other debris cutting and filling along the proposed route construction of storm drains and storm
water discharge features placement of concrete for curb and gutter placement and grading of
stone for the pavement base placement of asphalt pavement per the road section described above
and temporary and permanent seeding and other erosion control measures
The purpose of the project is to improve traffic flow into and from the east side of Clayton and
the central downtown business area There will be no habitable houses businesses institutions
or industries displaced as a result of the project Figure 2 is a site map with current aenal
coverage of the area with the proposed road extension shown
This environmental review is intended to assess the potential environmental impacts of the
proposal Mitigation measures will be identified as needed to avoid or minimize any identified
temporary or permanent adverse impacts Soil & Environmental Consultants P A (S &EC) will
be preparing on behalf of the Town of Clayton the environmental document for this proposal for
approval by the Federal Highway Administration (FHWA) The N C Department of
Transportation will oversee the environmental review at the local level on behalf of the FHWA
Any local state or federal agency any organized group or any interested individual may make
comments they believe should be considered during the environmental review for this project in
one or both of the following manners
(1) Questions may be directed to and / or written comments may be mailed or e mailed by
March 15 2012 to
Soil & Environmental Consultants PA

Attn Don Wells (e mail dwellsna sandec com phone — 919 846 5900)
11010 Raven Ridge Road
Raleigh N C 27614
(2) — The Town of Clayton will also hold a public meeting for the purpose of receiving comments
relative to the preparation of the environmental review for the proposed East Front Street
Extension project This public meeting has been scheduled to take place on January 31 2012 in
the council chambers of the Town Hall in Clayton NC All written comments received by the
specified date and any verbal comments received at the above noted meeting will be considered
during preparation of the environmental review for this protect
Thank you for consideration of this request
Donald Wells
NC Licensed Soil Scientist
cc Town of Clayton

Legend
Approximate Roadway Corridor -� ` \ l -i° i,':� ,
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Figure 1 - 0 2,000 4,000 8,000
Project No. 1:24,000 USGS Vicinity Ma
11781.G1 Feet
East Front Street
Project Mgr.: Extension
Dw Soil & Environmental Consultants, PA
Johnston County, NC
Scale: 11010 Raven Ridge Rd.- Raleigh, NC 27614
1" = 2,000' (919) 846 -5900 - (919) 846 -9467
Web Page: www.SandEC.com
1/26/2012 Clayton Quadrangle

Legend
Approximate Roadway Corridor
a
'� �.♦ r � Y �
w
0 400 800 1,600
Project No. 2010 Color Aerial Map
11781.G1 Feet
East Front Street
ow
Project Mgr.: Extension
Johnston County, NC Soil & Environmental Consultants, PA
Scale: 11010 Raven Ridge Rd.• Raleigh, NC 27614
1" = 400' (919) 846 -5900 • (919) 846 -9467
Figure 2. Web Page: www.SandEC.com
1126/2012 NCOneMap 2010 Aerial
s
r
�
a
'� �.♦ r � Y �
w
0 400 800 1,600
Project No. 2010 Color Aerial Map
11781.G1 Feet
East Front Street
ow
Project Mgr.: Extension
Johnston County, NC Soil & Environmental Consultants, PA
Scale: 11010 Raven Ridge Rd.• Raleigh, NC 27614
1" = 400' (919) 846 -5900 • (919) 846 -9467
Figure 2. Web Page: www.SandEC.com
1126/2012 NCOneMap 2010 Aerial