20231194 Ver 1_20231194 Ver 1_More Info Requested_20240212_20240408

DocuSign Envelope ID: 427D3F51-52A2-48E4-A1E3-91BCEC7E037E
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
February 12, 2024
DWR # 20231194
Wake County
Raleigh Durham Airport Authority
Attn: Mr. Michael Landguth
1000 Trade Drive, PO 80001
Raleigh NC 27623
Delivered via email to: [e-mail]
Subject: REQUEST FOR ADDITIONAL INFORMATION
Runway 5L/23R Replacement Project
Dear Mr. Landguth:
On January 9, 2024 the Division of Water Resources (Division) received your application requesting a
401 Individual Water Quality Certification from the Division for the subject project. The Division has
determined that your application is incomplete and cannot be processed. The application is on -hold
until all of the following information is received:
1. The application documents and the Environmental Assessment (EA) both include a statement that
"The Airport Authority would handle any groundwater encountered by installing appropriate
dewatering features on -site, as needed. If any potentially contaminated groundwater were
encountered during dewatering, the Airport Authority would properly test and treat the water prior
to discharge in accordance with the NPDES permit and local dewatering and groundwater discharge
approval and permit requirements." Please explain:
a. Where are excavation activities expected to occur below the groundwater table? The Division is
concerned that excavation activities may have the potential to affect the hydrology of adjacent
streams or wetlands.
b. What criteria is being set to determine if groundwater should be tested?
c. What pollutants are proposed for testing?
d. What is the proposed method for "treatment prior to discharge"?
e. Where are the proposed discharge locations for groundwater (clean or treated)? If the
proposed discharge locations are into erosion control or post construction stormwater
measures, have those measures been designed for the possibility of additional, and possibly
continuous, flow?
f. Has RDU discussed this proposed procedure/protocol with the NCDEMLR Industrial Stormwater
staff to confirm that this will be allowed under the Airport's existing NPDES industrial
stormwater permit?
� � North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORn CARC WAA ^\\\\\\ 919.707.9000
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DocuSign Envelope ID: 427D3F51-52A2-48E4-A1E3-91BCEC7E037E Runway 5L/23R Replacement Project
DWR# 20231194
Request for Additional Information
Page 2 of 4
g. Reference has been made to local dewatering and groundwater discharge approval and permit
requirements. Please specify what requirements this is referencing.
2. The application and EA both state that blasting will occur at the borrow site. Please explain how the
adjacent streams and buffers will be protected during blasting activities.
3. The application and EA both discuss the use of water from Brier Creek Reservoir for
hydrocompression. The EA states that if conditions such as a drought occur during construction
activities and water from Brier Creek Reservoir is not sufficiently available, other sources would be
utilized. Please explain what specific criteria will be used to determine when other sources of water
will be necessary.
4. Plan sheet C04.05.01 shows the "Approximate location of Brier Creek Reservoir Water Intake".
Please clarify if there will be any impacts to jurisdictional waters or Neuse Buffers for the purpose of
this intake.
5. Please provide a signed and notarized 0&M form for the Stormwater Management Plan.
6. Pursuant to 15A NCAC 02H.0506(b) "a 401 Water Quality Certification may only be issued upon
determining that the proposed activity will comply with state water quality standards which includes
designated uses, numeric criteria, narrative criteria and the state's antidegradation policy, as
defined in rules of 15A NCAC 02B .0200... In assessing whether the proposed activity will comply
with water quality standards, the Division shall evaluate if the proposed activity: (2) would cause or
contribute to a violation of water quality standards; (3) would result in secondary or cumulative
impacts that cause or contribute to, or will cause or contribute to, a violation of water quality
standards;"
Based on the plans provided, it appears that some remaining segments of streams and wetlands
that are downstream of the proposed project area may be indirectly impacted by the rerouting of
surface flow and any expected infiltration/shallow subsurface flow in the final stormwater
management plan. Specifically, it appears that stream S23, S25 above the proposed outfall of Dry
Pond 4, W24 and S26 have the potential for indirect impacts from rerouting of existing flow. Please
provide an analysis of the potential for indirect impacts to these areas and/or adjust the application
impacts to account for the loss of function for these areas.
7. The grading plans appear to show silt fences as an erosion control measure where early clearing and
grubbing will occur in upper portions of streams. It is unclear how the stream flow/groundwater
flow will be managed in these areas while clearing and grubbing are occurring and whether silt fence
placed across flowing streams/ groundwater sources is sufficient to protect downstream waters.
Please see sheet C01.00.03 and C01.00.05 for examples.
8. In various places within the project plans, outlet stabilization for riser basins and dry ponds are
shown but it is unclear if these areas have been accounted for in the impact amounts. See sheet
CO2.02.15 for an example.
9. Sheet CO2.02.16 shows two outlet structures with riprap stabilization from Riser Basin #83 that are
not in line with stream. The Division has significant concerns about whether the proposed design
adequately protects downstream waters and protected buffers.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-161 1
NCRTH CARoLwA A 919.707.9000
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DocuSign Envelope ID: 427D3F51-52A2-48E4-A1E3-91BCEC7E037E Runway 5L/23R Replacement Project
DWR# 20231194
Request for Additional Information
Page 3 of 4
10. On sheet CO2.03.16, the outlet of Dry Pond 2 is shown as perpendicular to and impacting the stream
channel. Please realign this outlet to ensure that downstream waters and buffers are adequately
protected from long term erosion.
11. Please provide an construction sequence detailing how fill will be placed in Pond 10 to ensure that
downstream water quality will be protected.
12. Please note that the general notes for the project include a statement that "CLEARING OPERATIONS
FOR ANY GIVEN DRAINAGE AREA MAY OCCUR AS SOON AS THE SILT FENCING REQUIRED PER THE
APPROVED PLANS IS INSTALLED FOR THAT DRAINAGE AREA. SEDIMENT SKIMMER BASINS DO NOT
HAVE TO BE COMPLETED FOR CLEARING TO BEGIN." It is the Division's experience that projects that
involve significant clearing areas with significant topographic relief cause/contribute to downstream
water quality violations. Please revise the construction sequence to ensure that clearing and
grubbing activities will be adequately managed by appropriate erosion control measures so as to not
cause or contribute to downstream water quality violations.
Please note that additional information may be required upon the Division's review of your response to
the items noted above.
Pursuant to Title 15A NCAC 02H .0502(e), the applicant shall furnish all of the above requested
information for the proper consideration of the application. Please respond in writing within 30
calendar days of receipt of this letter by submitting all of the above requested information through this
link: https://edocs.deg.nc.gov/Forms/Supplemental-Information-Form (note the DWR# requested on
the link is referenced above).
If all of the requested information is not received within 30 calendar days of receipt of this letter, the
Division will be unable to approve the application and it will be denied as incomplete. The denial of this
project will necessitate reapplication to the Division for approval, including a complete application
package and the appropriate fee.
Please be aware that you have no authorization under the Section 401 of the Clean Water Act/ Buffer
Rules for this activity and any work done within waters of the state may be a violation of North Carolina
General Statutes and Administrative Code.
Please contact Sue Homewood at 336-813-1863 or [e-mail] if you have any
questions or concerns.
Sincerely,
Docu Signed by:
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Stephanie Goss, Supervisor
401 & Buffer Permitting Branch
D � � North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-161 1
NORTH CARCLINA 919.707.9000
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DocuSign Envelope ID: 427D3F51-52A2-48E4-A1E3-91BCEC7E037E
Electronic cc: Jim Novak, RDU
Bill Sandifer, RDU
Bob Zarzecki, S&EC
Lyle Phillips, USACE Raleigh Regulatory Field Office
Gabriela Garrison, NCWRC
DWR 401 & Buffer Permitting Branch file
Runway 5L/23R Replacement Project
DWR# 20231194
Request for Additional Information
Page 4 of 4
Filename: 20231194 RDU Runway Replacement - Wake - Addinfo.docx
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-161 1
NCRTH CARCLwA A 919.707.9000
gaparhnaM of EmirnnmanW quay