20061617 Ver 1_More Info Letter_20070405

~~ s:~E~~-~~ Michael F. Easley, Governor
~~ ~ William G. Ross Jr., Secretary
G~j ~ ~ ~~~ ~ North Carolina Department of Environment and Natural Resources
~ ..[. Alan W. Klimek, P.E. Director
Division of Water Quality
Apri15, 2007
CERTIFIED MAIL: RETURN RECEIPT REQUESTED
Mr. Greg Ferguson
Mercury Development, LLC
5660 Six Forks Road, Suite 202
Raleigh, NC 27609
Subject Property: Wendell Falls Development & Interchange
REQUEST FOR MORE INFORMATION
Dear Mr. Ferguson:
On October 13, 2006, the Division of Water Quality (DWQ) received your application dated September 26, 2006,
to impact 5.2 acres of 404/wetland, 3,4161inear feet of stream, and 355,450 square feet of Neuse River basin
protected riparian buffer, to construct the proposed Wendell Falls residential subdivision, commercial
development, road improvements, and US Highway 64/264 interchange. On October 13, 2006, the DWQ
received the Public Notice issued October 13, 2006, for the project. On January 26, 2007, and February 9, 2007,
the DWQ received additional information. As a result, we submitted a March 27, 2007 correspondence that
identified the information that we still required to process your application. In that correspondence, we indicated
that a follow up letter with the remainder of the requirements relating to the interchange and Wendell Falls
Parkway would follow. The items below fulfill that requirement. Please provide the information requested below
so that we can complete processing of your application.
General Comments
1. As previously indicated in our March 27, 2007 correspondence, we require a complete set of roadway
design plans to adequately review your application.
Your application states that sites 1 and 4 have already been permitted and mitigation provided for. In
addition, it does not state that sites 5 & 6 have been already permitted. As previously indicated in several
communications, the DWQ has clearly stated that the impact sites for the interchange (Site 4) and
corresponding Wendell Falls Parkway (Site 1) have not been previously permitted. On the other hand, the
impacts for Sites 5 and 6 may well have been permitted by the NCDOT project. Yet, your application
seems to indicate the reverse. Please provide a set of DOT as-built plans for the section of US 64 where
the proposed interchange is located. We need to compare what was built by DOT at Sites 5 & 6 versus
what your application is requesting.
In reviewing the plans, it is not clear if the cut-fill slopes presented in your application corresponds to the
plans presented in the DOT application for the US 64 Bypass project. While we agree that mitigation
for the proposed impact sites was obtained by DOT, since DOT never completed the design of the
interchange, or the bridge on the proposed Wendell Falls Parkway, the amount of final mitigation
required for this permit application maybe different. Once final impact calculations are developed for
NorthCarolina
JVaturally
North Carolina Division of Water Quality 1650 Mail Service Center Raleigh, NC 27699-1650 Phone [phone] Customer Service
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your project, we can compare those numbers to the mitigation that you have received from DOT. At that
time, we can make the determination if sufficient mitigation is available, or if additional maybe required.
4. In reviewing your application it is not clear how your impacts were calculated. In addition, while the
permit drawings show proposed impacts to wetlands, those same drawings do not show any proposed
impacts to protected riparian buffers. In your impact tables you show impacts to buffers for Sites 1, 4, 5,
and 6, however the corresponding permit drawings do not indicate any impacts at these locations. Please
provide drawings that show impacts to all jurisdictional waters and protected riparian buffers.
In reviewing the application it is not clear how impacts for the project were calculated. Specifically, since
no hatched (or other method) of displaying impacts was not shown for buffers, it is not possible to
determine how impact calculation was done. For the proposed impacts to wetlands and streams, the maps
do display proposed impacts, and as such, lead the reviewer to believe that similar methods were used for
buffers. However, it is not possible to definitely determine that fact. In addition, it is not clear if the
impacts presented in your application include impacts for: 1) all cut/fill slopes, 2) rip rap dissipater pads,
and 3) construction access/impacts. Thus, please provide additional information that details how impacts
were developed including either a narrative discussion, or a graphical representation that shows impacts
for rip rap dissipater pads in streams, and anticipated construction impacts expected from both earth
moving activities as well as access requirements.
6. Please indicate in your application if sufficient right-of--way exists for construction of the interchange.
Review of the DOT application indicates there might not be sufficient Right-of--Way especially in the
Northwest corner of the interchange. Since DOT is not an applicant on this application, all the land
proposed for impact must be owned by the applicant or in an already existing DOT right-of--way.
In reviewing your table of impacts, there appears to be redundant tables. There are two tables. The first
table indicates wetland, stream, and buffer impacts for Sites 1-6. The second table indicates impacts to
wetlands, streams, and buffers for the same sites 1-6, yet gives differing impact quantities. Please explain
the apparent discrepancy.
After reviewing the application, it is unclear what the proposed typical roadway section for Wendell Falls
Parkway is supposed to be. In reviewing the application it appears that a four lane divided section is
proposed through the Wendell Falls development with atwo-lane road from Martin Pond Road to Poole
Road. However, no typical cross section information is presented in the application to verify that
conclusion. In addition, the purpose of this road is still unclear. If the purpose of the road is serve the
development exclusively, then a two lane or a four lane divided road (with a narrow median width) is
likely warranted. However, it is our understanding that the road will serve a dual function: one being to
serve the development and two as a local thoroughfare road. To that end; it is our understanding that 'a six
lane typical maybe required in the future. Furthermore, it is our understanding that it may the desire of
some to build a roadway of sufficient width and corresponding median to support future widening "to the
middle". While the DWQ understands the potential need for a thoroughfare road in this area, and could
potentially support a wider roadway typical if its purpose is to provide that function, the supporting traffic
modeling is needed to approve the larger impacts that the road will require. In addition, a preliminary
evaluation of the roadway's ultimate terminus will also be required for us to assess potential secondary
and cumulative impacts.

Site Specific Comments
Site 1
Your application indicates that this site was previously permitted and mitigated. This site was previously
identified in the DOT application for the US 64 Bypass of Knightdale and shown with preliminary design.
That design showed only preliminary "footprint" impacts and did not include hydraulic design or final
roadway design information. The purpose of that design detail was to ensure that DOT's design for the rest of
the project allowed for maximal avoidance and minimization of impacts to resources. Mitigation was
acquired by DOT to offset future anticipated impacts if the interchange were to be built at a later date.
In reviewing the application, it appears that the bridge located on Site 1 may be shorter than the one proposed
in the DOT application for the US 64 Bypass. Please provide documentation that either indicates that the
bridge is of equal length, or explains the rationale for a shorter bridge.
• Culvert C4 appears to convey stormwater from the interchange gore area to the outside of the fill slope.
However, it does appear to provide for diffuse flow and non-erosive velocities prior to stormwater entering
the protected riparian buffer. Please modify your design to correct this problem, or submit additional
information to demonstrate that appropriate stormwater design for adherence to the buffer rules has been
achieved.
Site 3
This crossing appears to include an arch culvert, or similar spanning structure. Based on our experience,
these types of structures can cause significant stream instability as well as roadway structural instability
unless they are anchored into existing shallow bedrock. It is not clear in the application if this structure does
that. In addition, it is a standing DOT policy (one which we support), that these types of structures be
anchored to shallow bedrock. Please provide the geologic data to support use of this structure.
The plans for this section of stream indicate significant stream sinuosity exists in the area of the crossing.
Given that placing a sinuous stream in a straight culvert can substantial steepen the effective slope of the
stream and promote stream instability, we would prefer to see a small bridge at this location. We are open to
possible culvert designs that allow for stream stability through the use of downstream cross vanes and
possible floodplain culverts.
Site 4
The permit drawings indicate that this site was previously permitted and mitigated. That is not completely
accurate. This site was previously identified in the DOT application for the US 64 Bypass of Knightdale and
shown with preliminary design. That design showed only preliminary."footprint" impacts and did not include
hydraulic design or final roadway design information. The puipose of that design detail was to ensure that
DOT's design for the rest of the project allowed for maximal avoidance and minimization of impacts to
resources. Mitigation was acquired by DOT to offset future anticipated impacts if the interchange were to be
built at a later date.
It is not clear if the entire stormwater collection system is shown on the drawings. Please indicate if the entire
system is shown. It is expected that the aforementioned roadway design drawings will provide that
information.
• The proposed stormwater discharges (L10, and L14) into the interchange gore area do not provide for diffuse
flow at non-erosive velocities. Please add appropriate flow spreader devices to the discharge locations and
provide sufficient information to demonstrate they are designed to required flow spreader design criteria.

Culvert C2 appears to pick up and discharge untreated stormwater to the stream. Please provide information
to indicate otherwise, or redesign the system to provide treatment prior to discharging of stormwater directly
into the stream.
• On Sheet 2 of 2 the drawings do not indicate if the proposed stormwater discharge (a 900 CSP pipe) was
previously approved with the DOT project.
Site S
Does the proposed design incorporate changes to the already approved and constructed DOT project? If so,
please detail what they are. A complete set up DOT as-builts may provide sufficient information.
Site 6
For Sheet 1 of 2, does the proposed design incorporate changes to the already approved and constructed DOT
project? If so, please detail what they are. A complete set up DOT as-builts may provide sufficient
information.
For sheet 2 of 2, this site clearly has additional impacts beyond what was approved for the DOT project.
While the design appears to be acceptable, the drawings do not indicate where the new impacts to wetlands,
streams, and buffers occur relative to the already constructed DOT project. Please provide updated drawings
that show this information.
Please be advised that this fulfills our commitment identified in our March 27, 20071etter. In addition, and as
stated in previous correspondence, this letter only addresses the application review and does not authorize any
impacts to wetlands, waters or protected buffers. Please be aware that any impacts requested within your
application are not authorized (at this time) by the DWQ. Please call Ms. Cyndi Karoly or Mr. Ian McMillan at
919-733-1786, or John Hennessy at 919-733-5694, if you have any questions regarding or would like to set up a
meeting to discuss this matter.
mce ly,
~~ ~ .
o E. Hennessy, Supe
Transportation Permitti nit -
Cc: Ian McMillian, DWQ
Lauren Cobb, DWQ Raleigh Regional Office
USACE Raleigh Regulatory Field Office
File Copy
Todd Preuninger, Withers & Ravenel, 111 MacKenan Drive, Cary, NC 27511
Jerry Lindsey, NCDOT