C04_Attachment 5 Environemental Assessment_1232SA26R0032.pdf

FINAL

ENVIRONMENTAL ASSESSMENT

CREEK BED AND LOWER ROAD REPAIRS AT THE

EASTERN REGIONAL RESEARCH CENTER (ERRC)

WYNDMOOR, PA

PREPARED BY

STV INCORPORATED

STV Project No. 30-1902

STV Project No. 30-19705

February 8, 2019 i

TABLE OF CONTENTS

SECTION 1.0 INTRODUCTION

1.1 GENERAL

1.2 DESCRIPTION OF THE PROJECT AREA

1.3 PURPOSE OF AND NEED FOR PROPOSED ACTION

1.4 PROCEDURAL REQUIREMENTS

1.5 POTENTIALLY SIGNIFICANT ISSUES

1.5.1 Surface Waters

1.5.2 Soils

1.5.3 Utilities

1.6 POTENTIAL PERMITS AND APPROVALS

1.6.1 Stormwater Management Permits

1.6.2 Water Obstruction Permit

1.7 OTHER CHAPTERS OF THIS ENVIRONMENTAL ASSESSMENT

SECTION 2.0 ALTERNATIVES CONSIDERED INCLUDING THE PROPOSED ACTION

2.1 STREAM RESTORATION

2.1.1 Build Alternative

2.1.2 No Build Alternative

2.2 ROAD IMPROVEMENTS

2.2.1 Build Alternative

2.2.2 No Build Alternative

2.3 WALKING PATH

2.3.1 Build Alternative

2.3.2 No Build Alternative

SECTION 3.0 EXISTING ENVIRONMENTAL CONDITIONS

3.1 LAND RESOURCES

3.1.1 Geology

3.1.2 Soils

3.1.3 Topography

3.2 WATER RESOURCES

3.2.1 Surface Waters

3.2.2 Wetlands

3.2.3 Floodplains

3.2.4 Groundwater

3.3 BIOLOGICAL RESOURCES

3.3.1 Vegetation

3.3.2 Wildlife

3.3.3 Rare, Threatened and Endangered Species

3.4 CULTURAL RESOURCES

3.5 AIR QUALITY

3.6 NOISE

3.7 INFRASTRUCTURE

3.7.1 Utilities

3.7.2 Transportation and Parking

3.8 HAZARDOUS MATERIALS/WASTE AND SOLID WASTE

3.8.1 Hazardous Materials/Waste

3.8.2 Solid Waste

3.9 RECREATION

3.10 ENVIRONMENTAL JUSTICE

SECTION 4.0 ENVIRONMENTAL CONSEQUENCES

ii

4.1 STREAM RESTORATION

4.1.1 Build Alternative

4.1.2 No Build Alternative

4.2 ROAD IMPROVEMENTS

4.2.1 Build Alternative

4.2.2 No Build Alternative

4.3 WALKING PATH

4.3.1 Build Alternative

4.3.2 No Build Alternative

SECTION 5.0 UNAVOIDABLE ADVERSE IMPACTS

SECTION 6.0 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES

SECTION 7.0 CUMULATIVE EFFECTS

SECTION 8.0 LIST OF PREPARERS & REVIEWERS

SECTION 9.0 REFERENCES

iii

TABLE OF CONTENTS (CONTINUED)

TABLES

Table 1 – Document Summary Table 2 – Project Area Soils Table 3 – Construction Suitability Chart Table 4 – Potential Species of Concern

FIGURES

Figure 1 – Project Location Map (USGS) Figure 2 – Project Location Map (Aerial) Figure 3 – Site Plan Figure 4 – NRCS Soils Map Figure 5 – USFWS National Wetlands Inventory Map Figure 6 – FEMA Floodplain Map Figure 7 – Utility Map

APPENDICES

Appendix A – Agency Coordination Letters Appendix B – Wetland Delineation Report Appendix C – Photograph Log Appendix D – Finding of No Significant Impact iv

Glossary of Acronyms and Abbreviations Used in this EA

APE Area of Potential Effect ARS Agricultural Research Service BMP Best Management Practices CEQ Council on Environmental Quality CFR Code of Federal Regulations CO Carbon Monoxide DCNR Department of Conservation and Natural Resources DHS Department of Homeland Security EA Environmental Assessment EBSC Eastern Business Service Center EIS Environmental Impact Statement EO Executive Order ERRC Eastern Regional Research Center FEMA Federal Emergency Management Agency FIRM Flood Insurance Rate Map FONSI Finding of No Significant Impact GHG Greenhouse Gas MCCD Montgomery County Conservation District NHPA National Historic Preservation Act NPDES National Pollutant Discharge Elimination System NRHP National Register of Historic Places NEPA National Environmental Policy Act NOI Notice of Intent NRCS Natural Resource Conservation Service NWI National Wetlands Inventory PADEP Pennsylvania Department of Environmental Protection PGC Pennsylvania Game Commission PFBC Pennsylvania Fish and Boat Commission PHMC Pennsylvania Historical and Museum Commission PNDI Pennsylvania Natural Diversity Inventory SHPO State Historic Preservation Office STV STV Incorporated T&E Threatened and Endangered TSF Trout Stocked Fishery USACE United Stated Army Corps of Engineers USDA United States Department of Agriculture USEPA United States Environmental Protection Agency USFWS United States Fish and Wildlife Service USGS United States Geological Survey

COVER SHEET

Proposed Action: Creek Bed and Lower Road Repairs United States Department of Agriculture, Agricultural Research Service Eastern Regional Research Center Wyndmoor, Pennsylvania

Type of Statement: NEPA Environmental Assessment

Lead Agency: United States Department of Agriculture

Consulting Agencies: Federal:

Department of the Interior, U.S. Fish and Wildlife Service

Non-Federal:

Pennsylvania Historical and Museum Commission Pennsylvania Fish and Boat Commission Pennsylvania Game Commission

Pennsylvania Department of Conservation and Natural Resources

Abstract:

The United States Department of Agriculture (USDA), Agricultural Research Service (ARS), Eastern Business Service Center (EBSC) is proposing to conduct road repairs and creek stabilization at their Eastern Regional Research Center (ERRC) in Wyndmoor, Pennsylvania. The ERRC is a laboratory research center tasked with developing new knowledge and technology to improve agricultural commodities.

This National Environmental Policy Act (NEPA) Environmental Assessment (EA) has been prepared for the USDA to document the proposed actions at the ERRC. The end result of this project will not adversely affect physical, environmental, social, or economical resources. Road renovation and creek stabilization activities are expected to have a positive impact to the environment of the project area and that of the surrounding lands.

The proposed actions and the potential impacts associated are fully assessed in this EA which is prepared pursuant to NEPA standards. Based on the absence of significant impacts to the project area and to the surrounding lands, a recommendation will be made to the USDA Area Director that a Finding of No Significant Impact (FONSI) be rendered for this project. Further, implementation of the mitigation measures previously identified will reduce the potential impacts resulting in no significant impacts to the environment.

SECTION 1.0

INTRODUCTION

1.1 GENERAL

The United States Department of Agriculture (USDA), Agricultural Research Service (ARS), Eastern Business Service Center (EBSC) is proposing to conduct road repairs and creek stabilization at their Eastern Regional Research Center (ERRC) in Wyndmoor, Springfield Township, Montgomery County, Pennsylvania (see Figures 1 and 2). The ERRC is a laboratory research center, established by an Act of Congress in 1938. The ERRC is home to the Nation’s leading scientists and engineers in agriculture, solving problems facing the U.S. today and tomorrow with fundamental, applied, and developmental research on agricultural commodities including milk, meat, poultry, hides, leather, wool, fats, oils, rendered protein, grains, fruits, vegetables, energy crops, and juices.

The ERRC is tasked with developing new knowledge and technology that will ensure an abundance of high quality agricultural commodities and products at reasonable prices to meet the increasing needs and to provide a continued improvement in the standard of living of all Americans through the following research objectives:

Development of rapid methods to detect human pathogens and harmful chemicals in foods.

Development of novel methods to characterize human pathogens in foods.

Development of microbial predictive modeling for food safety risk assessment and management.

Development of effective and innovative intervention technologies to reduce or eliminate human pathogens in foods.

Sustainable production of biofuels and co-products from grains and biomass.

Sustainable agricultural practices.

Development of new crop-derived food ingredients and nutraceuticals with health-promoting ability.

Development of new food and dairy products with improved functionality and health benefits.

Development of valuable biobased products from agricultural byproducts for biomedical, industrial, and commercial applications.

Utilize by-products, particularly potential pollutants.

Open new and expand existing domestic and foreign markets.

This National Environmental Policy Act (NEPA) Environmental Assessment (EA) has been prepared for the USDA to document proposed actions to ensure consideration of the environmental aspects of the proposed actions in the Federal decision making processes;

determine whether or not the proposed actions have the potential for creating significant impacts on the human and/or natural environment; and to make environmental information available to the public before decisions are made and actions taken.

1.2 DESCRIPTION OF THE PROJECT AREA

The ERRC campus was established in 1938, with the construction of the facility being completed in the early 1940s. There are currently between 175-200 employees working at the ERRC. The campus consists of the main laboratory building, and several out buildings, including a vehicle storage building, hazardous operations building, leather research building, meat processing laboratory, service building, mechanical service building and the transformer/meter house (see Figure 3). Parking lots 1, 2, and 3 are located east of the main laboratory building, and parking lot 5 is located to the south. Internal connector roads connect the parking lots to the main laboratory and out buildings. Cresheim Creek, located at the northeast corner of the intersection of East Lane and Mermaid Lane, runs through and along the southeast edge of the ERRC property.

1.3 PURPOSE OF AND NEED FOR PROPOSED ACTION

In 2013, STV performed a preliminary investigation on behalf of the ERRC of a section of Cresheim Creek running from the culvert at Mermaid Lane to East Lane. At the time of the preliminary investigations performed by STV, the team found evidence of accelerated stream bank erosion occurring along the banks of the creek. Other observations noted were debris/large obstructions located within the creek bed, including tires, fallen trees and large rock boulders, steep slopes along the creek bank with no vegetation, exposed tree roots along the banks, lack of outfall protective measures for storm sewer pipes discharging to the creek, lack of riparian buffers along sections of the creek, toe erosion, undercutting and vertical banks. Stream surveys conducted in November 2018 indicated that conditions of the creek have continued to deteriorate due to further urbanization and more intense storms and runoff events.

In addition to restoration of the creek, sections of the Lower Road driveways and paved surfaces, located along the southeastern border of the property also require repairs. Also, based on informal discussions USDA has had with the Philadelphia Water Department and Friends of the Wissahickon, a non-profit organization, it is desired by USDA to incorporate a walkable path for public use along the outside of the ERRC fence line.

1.4 PROCEDURAL REQUIREMENTS

This EA was prepared in accordance with NEPA, Section 102(2)(C) and the Council on Environmental Quality (CEQ) Regulations for Implementing the Procedural Provisions of NEPA; 40 Code of Federal Regulation (CFR), Parts 1500 through 1508. The objective of this EA is to determine whether the proposed actions have the potential for creating significant impacts on the human and/or natural environment, which would thereby warrant a more detailed study of possible impacts, mitigation, and alternate courses of action. If no potentially significant impacts are identified from the Proposed Actions, a Finding of No Significant Impact (FONSI) can be issued. If significant impacts are deemed probable (in accordance with CEQ criteria (40 CFR 1508.27)), even after mitigation measures are incorporated into the design, a Notice of Intent (NOI) to prepare a NEPA Environmental Impact Statement (EIS) is required, followed by the completion of the EIS itself.

Background data review and on-site investigations conducted as part of this EA included the following activities:

Review of United States Geological Service (USGS) Topographic Map; Germantown, PA Quadrangles (2015) to identify general area setting;

Review of Natural Resource Conservation Service (NRCS), Montgomery County, PA Soil Survey Maps for the project area to identify soils characteristics;

Review of Federal Emergency Management Agency (FEMA) maps for the project area to determine the extent of flood boundaries;

Review of U.S. Fish and Wildlife Service (USFWS) National Wetlands Inventory (NWI) online mappers for the project area to assist in the identification of jurisdictional wetland areas;

Completion of an on-line Pennsylvania Natural Diversity Inventory (PNDI) to ascertain the presence or absence of Rare, Threatened, or Endangered Species (Appendix A);

Completion of field inspections of the project area to document the presence or absence of environmentally sensitive features, wetlands, threatened and endangered plant and wildlife species;

Review of the Wetland Delineation Report prepared by Cedarville Engineering Group, LLC (Appendix B).

1.5 POTENTIALLY SIGNIFICANT ISSUES

Scoping covers the range and detail of issues covered in this EA document. Scoping was conducted as part of the original NEPA process to ensure that identification of issues of concern (i.e., potentially significant impacts) occurred as early in the assessment process as possible.

The following activities were conducted to define and refine the scope of this EA:

Evaluation of existing/current site conditions and natural resources and the human environment within and adjacent to the subject property area.

Correspondence and request for agency review from state, and federal regulatory agencies to obtain information pertaining to critical resources (e.g, threatened and endangered species) and environmental permits required for land development activities within the project area.

In accordance with CEQ regulations (specifically sections 1500.4 and 1501.7), this EA includes detailed discussions of only those issues deemed to be potentially significant. Potential issues involved with the project are as follows:

1.5.1 Surface Waters

Direct impacts to surface waters would be avoided with the use of Best Management Practices (BMPs) and an Erosion & Sedimentation (E&S) Control plan to avoid sedimentation from entering Cresheim Creek during construction activities. Additionally, the Build Alternative would result in a positive impact to the portion of Cresheim Creek being stabilized, as well as downstream surface waters.

1.5.2 Soils

Earthwork and other related construction activities would involve temporary impacts to site soils.

During site construction activities, stormwater management and E&S control measures would be implemented and adhered to in accordance with Pennsylvania Department of Environmental Protection (PADEP) and Montgomery County Conservation District (MCCD) requirements.

Through appropriate measures and the installation of Best Management Practices BMPs, off site wetlands and streams would be protected from inadvertent sediment runoff during construction activities.

1.5.3 Utilities

Underground utilities are located throughout the ERRC facility. During excavation activities, contact with other subsurface utilities (e.g, electrical, natural gas, sewer, etc.) that are found in the facility must be avoided. The contractor should take great care to avoid inadvertent contact with any other subsurface utilities during construction.

1.6 POTENTIAL PERMITS AND APPROVALS

In the development of this EA, potential environmental permits and approvals applicable to the Proposed Action were identified. Summarized below are those permits required for the construction of the proposed project.

1.6.1 Stormwater Management Permits

Federal Requirements

Section 438 of the Energy Independence and Security Act requires any development or redevelopment project involving a Federal facility with a footprint that exceeds 5,000 square feet shall use site planning, design, construction, and maintenance strategies for the property to maintain or restore, to the maximum extent technically feasible, the predevelopment hydrology of the property with regard to temperature, rate, volume, and duration of flow.

State Requirements

Pursuant to the federal Clean Water Act, a National Pollution Discharge Elimination System (NPDES), permit is required from the PADEP for projects causing a ground disturbance of an acre or more of land, in order to limit the negative impacts of construction projects on Pennsylvania waters. It is anticipated that project impacts will be greater than one acre, and therefore, PADEP would require an Individual NPDES permit for this project.

1.6.2 Water Obstruction Permit

The project will require a Chapter 105/Section 404 Joint Permit from PADEP and the U.S. Army Corps of Engineers (USACE) for impacts to Cresheim Creek and the associated floodway.

1.7 OTHER CHAPTERS OF THIS ENVIRONMENTAL ASSESSMENT

The following table identifies the organization of this EA:

TABLE 1

DOCUMENT SUMMARY

CHAPTER TOPIC

2 Alternatives Considered, Including the Proposed Action 3 Existing Environmental Conditions 4 Environmental Consequences 5 Unavoidable Adverse Impacts 6 Irreversible and Irretrievable Commitments of Resources 7 Cumulative Effects 8 List of Preparers 9 References Appendices

Chapter 2 presents the two practical alternatives including the Preferred Alternative. Chapter 3 describes the existing environmental conditions potentially affected by the proposed construction.

Chapter 4 details the impacts on each specific environmental condition or media for the build and no build alternatives. Chapters 5 and 6 present unavoidable adverse impacts and weigh the short and long-term impacts. Chapter 7 evaluates the summation of impacts from this and other current and future projects in the vicinity that have an additive impact effect on environmental conditions. The Appendices contain pertinent informational maps, correspondence with regulatory agencies, photographs (Appendix C), and technical reports prepared as part of the assessment process. This study concluded that a FONSI was justified which can be reviewed in Appendix D.

SECTION 2.0

ALTERNATIVES CONSIDERED INCLUDING

THE PROPOSED ACTION

NEPA allows the evaluation of only one build alternative for projects that are not complex or controversial. Therefore, this EA evaluates only the Proposed Actions (Build Alternatives) for the stream restoration, the road improvements and the walking path, and the No Build Alternative for each project.

2.1 STREAM RESTORATION

2.1.1 Build Alternative

Under the Build Alternative, the USDA will restore approximately 1,450 LF of streambank along Cresheim Creek. The restoration would involve stabilization of the streambanks, habitat enhancement structures, and other instream structures. Additionally, a native riparian corridor would be established on the banks.

To accomplish this work, the following tasks would be conducted:

Evaluation of existing conditions, including soils, vegetation, hydrology and stream morphology;

Preparation of a clearing and grading plan to depict how the project area will be prepared for the stream restoration, and establishment of proper soil media for vegetation planting;

Preparation of a planting plan to identify species of native vegetation and location of plantings;

Preparation of a site plan to include stream grading, pattern/profile, in-stream grade control structures and deer/wildlife protection;

Preparation of a report to identify project goals, success criteria and a contingency plan.

2.1.2 No Build Alternative

Under the No Build Alternative, restoration of Cresheim Creek would not occur, allowing continued degradation of the stream. Streambank erosion and undercutting would continue, obstructions would not be removed, outfall protection would not be installed, and the creek would continue to lack riparian buffers.

2.2 ROAD IMPROVEMENTS

2.2.1 Build Alternative

Under the Build Alternative, the USDA would repair sections of the Lower Road, driveways and paved surfaces that are deteriorated. Due to funding limitations, a phased construction approach will be developed.

2.2.2 No Build Alternative

Under the No Build Alternative, no road improvements would occur, resulting in the conditioned use of deteriorated roadways.

2.3 WALKING PATH

2.3.1 Build Alternative

The USDA is seeking to partner with the Philadelphia Water Department and the Friends of the Wissahickon for full remediation of Cresheim Creek. Additionally, according to the feasibility study for the Cresheim Trail (Campbell Thomas & Co. Architects, 2008), there are long term plans to connect Mermaid Park to the Cresheim Trail system. Therefore, USDA is proposing to incorporate a walkable path for public use along the outside of the ERRC fence line.

2.3.2 No Build Alternative

Under the No Build Alternative, no walking path would be constructed along Cresheim Creek.

SECTION 3.0

EXISTING ENVIRONMENTAL CONDITIONS

3.1 LAND RESOURCES

3.1.1 Geology

The project area lies in the Piedmont Upland Section of the Piedmont Province. The Piedmont Upland Section consists of broad, gently rolling hills and valleys. This upland area is developed mainly on metamorphic rocks called schists. These rocks usually have a very well-developed plane (schistocity) that was formed during metamorphism. This plane dips at moderately steep angles to the south and stream erosion is often either parallel to or normal to the plane of schistocity. In some places the drainage pattern has a very pronounced rectangular orientation, but for the most part the drainage pattern is dendritic. Local relief is generally less than 300 feet, but it can be as much as 600 feet. Elevations in the section range from 100 to 1,220 feet, but are generally between 400 and 600 feet.

Site specific geotechnical studies will be performed prior to construction activities.

3.1.2 Soils

A review of the existing soils was performed based on available information from the NRCS Web Soil Survey data for Montgomery County, PA. Based on this review, two types of soils exist within the facility. One of the soil types in the facility are hydric. Refer to Figure 4 and Table 2 for a map and description of the existing soil types.

TABLE 2

PROJECT AREA SOILS

SYMBOL DESCRIPTION HYDRIC

RATING

UugB Urban land-Udorthents, schist and gneiss complex, 0 to 8 percent slopes Yes

UgB Urban land, 0 to 8 percent slopes No

Construction suitability for project area soils, based on the NRCS soil survey, is listed in Table 3.

TABLE 3

CONSTRUCTION SUITABILITY CHART

SYMBOL

Bldgs. (3 stories or less with basements)

Lawns, landscaping, golf fairways

Impoundments, Embankments Road Fill

UugB Somewhat Limited

Somewhat Limited

Somewhat Limited Poor

UgB Not Rated Not Rated Not Rated Not Rated

3.1.3 Topography

As shown in Figure 1, the ERRC site is located in a very gently rolling topography. Elevations range from EL 350 to EL 400 feet. The USGS quadrangle map of the facility and vicinity is shown on the Project Location Map (Figure 1).

3.2 WATER RESOURCES

3.2.1 Surface Waters

The ERRC site is bordered on the southwest Cresheim Creek, and a small lake is adjacent the western edge of the property. Cresheim Creek drains the lake and is part of the Wissahickon tributary system that feeds to the Philadelphia water system. Cresheim Creek is listed as a Trout Stocked Fishery (TSF) under Chapter 93 of the PA Code, Water Quality Standards. The ERRC is not within a sole source aquifer.

3.2.2 Wetlands

The National Wetland Inventory (NWI) map for the ERRC facility identifies one wetland, a small lake identified as a palustrine, unconsolidated bottom, semi permanently flooded, diked impoundment (PUBFh), located adjacent to its western property boundary (Figure 5). This lake feeds into Cresheim Creek.

A site visit was conducted within the ERRC site on October 25, 2018 by Cedarville Engineering Group, LLC to determine if wetlands were present within the project area. No wetlands were identified. A copy of the wetland delineation report can be found in Appendix B.

3.2.3 Floodplains

A review of FEMA FIRMs (Figure 6) revealed that no portion of the ERRC site lies within a flood hazard zone and that the entirety of the Facility lies in Zone X, which is located outside of the 500-year floodplain.

3.2.4 Groundwater

According to the USDA NRCS Web Soil Survey, depth to groundwater in the vicinity of the project location is generally at 6.5 feet. Site specific geotechnical studies will be performed prior to construction activities, and depth to groundwater observations will be recorded at that time.

Fluctuations in groundwater levels can be expected due to precipitation, evaporation, surface run-off, construction activities, and other similar project-related activities.

3.3 BIOLOGICAL RESOURCES

This section describes the local biological resources found within the ERRC site. Biological resources within the project area were characterized based on reviews of available database inventories, resource agency correspondence, and direct field observations during which the characterization of vegetative communities, identification of dominant plant species, and documentation of wildlife were conducted. Habitats in which species were observed were evaluated and compared to their individual preferred habitats.

3.3.1 Vegetation

The ERRC site is situated in a residential area. The site consists primarily of paved surfaces and maintained grass, with a riparian corridor adjacent to Cresheim Creek. Vegetation within the riparian corridor consists of a mixture of upland forest and understory scrub/shrub vegetation.

The understory vegetation consisted primarily of invasive or weedy species, including Japanese knotweed (Fallopia japonica), pokeweed (Phytolacca americana), and wineberry (Rubus phoenicolasius). The upland forest species included bitternut hickory (Carya cordifomis), black cherry (Prunus serotine), black locust (Robinia pseudoacacia), red maple (Acer rubrum), and dogwood (Cornus florida).

3.3.2 Wildlife

The land use at and surrounding ERRC does not provide habitat for a diverse assemblage of wildlife species. The habitat is suitable for species common to human habitations.

Table 4 presents the wildlife species that were either observed during the site visits or could occur within the ERRC based on the habitats identified.

Table 4 – Representative Wildlife Commonly Found at the ERRC Common Name Scientific Name Common Name Scientific Name

American toad Bufo americanus Opossum Marmota Monax Eastern box turtle Terrepene carolina White-tailed deer Odocoileus virginianus Gray Squirrel Sciurus carolinensis Red-tailed hawk Buteo jamaicensis Blackbird Euphagus carolinus White-footed mouse Peromyscus leudopus American robin Turdus migratorius Raccoon Procyon lotor Mockingbird Mimus gundlachii Garter snake Thamnophis sirtalis American Crow Corvus brachyrhynchos Eastern cottontail rabbit

Sylvilagus floridanus

Groundhog Marmota monax Gray tree frog Hyla versicolor Red eft Notophthalmus viridencens Chipmunk Tamias striatus

Striped Skunk Mephitis mephitis Eastern mole Scalopus aquaticus Blue jay Cyanocitta cristata Mourning dove Zenaida macroura

3.3.3 Rare, Threatened and Endangered Species

In Pennsylvania, state and federal endangered species fall under the jurisdiction of four agencies, including the Pennsylvania Department of Conservation and Natural Resources (DCNR), the PA Fish and Boat Commission (PFBC), the PA Game Commission (PGC) and the USFWS. An on-line PNDI was conducted on October 31, 2018 to determine if there was a potential for the project to impact threatened and/or endangered species. The PNDI resulted in no known impacts, and no further review required with the PGC, DCNR, PFBC and the USFWS.

3.4 CULTURAL RESOURCES

Implementation of proposed Federal actions must comply with the National Historic Preservation Act (NHPA) of 1966 (16 U.S.C. § 470 et seq., as amended). Under the NHPA, consideration of historic and archeological preservation issues must be integrated into the early stages of project planning by Federal agencies.

Under Section 106 of the NHPA, a Federal agency is required to account for the effects of proposed actions on any district, site, building, structure, or object that is included or eligible for inclusion in the National Register of Historic Places (NRHP), prior to the expenditure of funds on the action. Section 110 of the NHPA requires the identification and evaluation of any cultural resources on Federal property that meet the eligibility criteria of the NRHP. The Pennsylvania State Historic Preservation Office (SHPO), is part of the Pennsylvania Historical and Museum Commission (PHMC). It is the responsibility of PHMC to consult with Federal agencies in accordance with Section 106.

A SHPO Project Review Form was submitted to the PHMC on November 15, 2018. According to the Project Review Form, the project site does not contain any resources listed on or eligible for the National Register of Historic Places. PHMC responded on November 30, 2018 that they concurred with the assessment that there are no historic properties within the Area of Potential Effect (APE).

3.5 AIR QUALITY

The ERRC maintains a General Air Permit which was renewed in 2018. Ongoing and future construction activities within the facility must comply with all local and regional air quality regulations.

The proposed projects would not threaten the attainment status of the region, would not produce substantial greenhouse gas (GHG) emissions, or would not lead to a violation of any Federal, state, or local air regulation. In compliance with CEQ and U.S Environmental Protection Agency (USEPA) guidance, a detailed qualitative and quantitative analysis of carbon dioxide (CO2) equivalents is not required for the proposed actions.

3.6 NOISE

Existing noise generating sources at ERRC would be limited primarily to general vehicular and traffic, which is common in the project vicinity. In Springfield Township, the noise ordinance prohibits construction activities between 6 p.m. and 7:30 a.m.

3.7 INFRASTRUCTURE

3.7.1 Utilities

To assess the existing utility system, STV conducted the following;

Reviewed existing as-built drawing information and project construction drawings.

Interviewed USDA personnel.

Conducted a field verification and investigation of existing conditions.

A plan illustrating the location of utilities is found in Figure 7.

3.7.2 Transportation and Parking

Major public roads that provide access to the ERRC site include Mermaid Lane, Stenton Avenue, Ivy Hill Road, and Queen Street. Access for employees to facility grounds is off Mermaid Lane.

Mermaid Lane forms the northern boundary of the ERRC site. All parking spaces at the ERRC site are paved. In addition to the 175-200 employees that access the ERRC, there are 10-15 contractor trucks at the ERRC each week, and 10-15 delivery trucks per day. The majority of the delivery trucks go to the pilot wing door of the main building.

3.8 HAZARDOUS MATERIALS/WASTE AND SOLID WASTE

3.8.1 Hazardous Materials/Waste

The Hazardous Operations Building, located in the southern portion of the facility (see Figure 3), houses an irradiator. The irradiator is a sealed source of radiation, and as such, does not pose a threat to the environment. As required by the Department of Homeland Security (DHS), protective bollards surround the vehicle entrance to this building (see Photo 12 in Appendix C) for added safety. Historically, this building contained nitrate and nitrite for bomb studies, which is where the name originated from.

A Solvent Storage Building is located near the boiler house. Hazardous materials from the Solvent Storage Building are disposed of every six month by Clean Harbors, a waste management company specializing in hazardous material management. The majority of hazardous wastes generated at ERRC are recycled. Additional hazardous materials are stored in a waste hazard/solvent storage building labeled (see Photo 11). This building is used for additional capacity, augmenting the capacity of the Solvent Storage Building. This building has not been used for several years. An eye wash station is located outside the chemical storage facility.

The majority of hazardous materials used at ERRC are bio-level 2 bacterial materials, solvents, and low quantity lithium. All drains within the laboratory are plugged; nothing is released into Cresheim Creek.

There was a past spill of No. 6 fuel oil from a tank overflow around 1997/1998. This spill was subsequently cleaned.

Fill material of unknown origins was identified along a portion of the banks of Cresheim Creek in the westernmost portion of the creek.

3.8.2 Solid Waste

Dumpsters are located throughout the ERRC facility to contain yard debris, construction debris and other facility wastes (see Photo 10). There are two dumpsters near the main building that are used for general and recyclable trash. There is a smaller dumpster at the back of the property that is used for landscaping waste. There is a large dumpster behind Mechanical Services Building that is for metal recyclables. The trash dumpsters are emptied once a week. The landscaping and metal waste dumpsters are on call - typically not picked up more than once or twice a month.

3.9 RECREATION

While there are no public recreational facilities within the ERRC, Mermaid Park, owned by Springfield Township, is located immediately northeast of the ERRC. Mermaid Park is a seven acre passive recreation facility, consisting of a pond and a portion of Cresheim Creek, park benches and shade trees.

3.10 ENVIRONMENTAL JUSTICE

Executive Order (EO) 12898 of February 11, 1994 addresses environmental justice in minority populations and low-income populations that may be affected by federal projects. This program requires federal agencies such as the USDA to ensure its projects do not discriminate against persons on the basis of race, color, or national origin. Federal projects must be accomplished such that minority and low-income populations are not subject to disproportionately high and adverse environmental effects. The proposed project will essentially have no environmental impacts, and will have a net positive impact on the surrounding community by stabilizing the banks of Cresheim Creek and providing a public walking trail. Additionally, all persons will have access to the path, regardless of race, religion, or national origin. Therefore, this project demonstrates compliance with the EO.

SECTION 4.0

ENVIRONMENTAL CONSEQUENCES

This section describes potential impacts or effects, if any, of the Proposed Actions (Build Alternatives) and the No Build Alternatives, as identified in Section 2. Environmental effects are described as changes to the biophysical and socioeconomic environment, either positive or negative, from a desirability standpoint. In accordance with CEQ regulations (specifically sections 1500.4 and 1501.7), this EA includes detailed discussions of only those resources deemed to be potentially impacted by this project.

As discussed in Section 3.2, there are no wetlands or mapped 100-year floodplains within the ERRC. Therefore, no further evaluation of these resources is included in this section.

As discussed in Section 3.3, the project site does not contain suitable habitat for any T&E species; no additional coordination will be needed with the PFBC, PGC, DCNR or USFWS for activities that require federal or state permits. Therefore, no further evaluation of T&E species is included in this section.

As discussed in Section 3.4, impacts to cultural and archeological resources will be updated upon completion of coordination with PHMC.

Where potential environmental impacts are identified, specific mitigation measures are described. The purpose of mitigation is to reduce the undesirable effects of an action on the environment. Five means of mitigation are available for consideration, including avoidance of the impact, limitation of action, restoration of the resource, reduction over time by preservation/maintenance, and replacement of the resource.

4.1 STREAM RESTORATION

4.1.1 Build Alternative

Under the Build Alternative, the USDA would restore and stabilize a portion of the banks of Cresheim Creek, where the creek is located adjacent to ERRC property.

Potential adverse impacts that warrant further discussion include impacts associated with soils, surface waters, wildlife, noise, utilities and hazardous waste.

Soils

Earthwork and other related construction activities would involve temporary impacts to site soils by the construction equipment used to conduct stream restoration activities. During site construction activities, stormwater management and E&S control measures would be implemented and adhered to in accordance with PADEP and MCCD requirements. Through appropriate measures and the installation of BMPs, off site wetlands and streams would be protected from inadvertent sediment runoff during construction activities.

Surface Waters

Under the Build Alternative, the banks of Cresheim Creek adjacent to ERRC would be restored and stabilized. As a result, erosion of the streambanks would be reduced, improving the water quality of downstream waterways including Cresheim Creek and the Wissahickon Creek. The Build Alternative would result in a positive impact to water quality in the portion of Cresheim Creek being stabilized and downstream surface waters, as well as improving the aesthetic properties of the creek.

Wildlife

Proposed construction activities will have a direct, but temporary impact on wildlife within the project area. However, little to no habitat will be lost by this project, and stream enhancements and planting of a native riparian corridor will ultimately improve habitat for fish and wildlife.

Noise

The project area is adjacent to residential areas; therefore, noise sensitive receptors are present in the vicinity of this project. However, construction activities related to this project would be minor and temporary in duration. The contractor would adhere to local noise ordinances regarding when construction can begin in the morning, and when it must conclude in the evening (i.e. no construction between 6 p.m. and 7:30 a.m.). Therefore, noise impacts during construction are anticipated to be insignificant.

Utilities

The stream restoration plan will incorporate the findings of the utility survey in order to avoid conflicts with utilities during construction. During excavation activities, contact with subsurface utilities (e.g, electrical, natural gas, sewer, etc.) that are found in the facility must be avoided.

The contractor should take great care to avoid inadvertent contact with any subsurface utilities during construction.

Hazardous Waste

Fill material of unknown origins was found along a portion of the banks of Cresheim Creek.

Further investigation of this material should be conducted prior to construction activities.

4.1.2 No Build Alternative

Under the No Build Alternative, the banks of Cresheim Creek would continue to erode, and downstream surface water quality would be negatively affected as a result.

4.2 ROAD IMPROVEMENTS

4.2.1 Build Alternative

Under the Build Alternative, the USDA would repair driveways and paved surfaces throughout the south side of the ERRC, resulting in minor disturbances to soils. Potential adverse impacts that warrant further discussion include impacts associated with soils, noise, utilities and traffic, and solid wastes.

Soils

Repaving of roads and parking lots involves temporary impacts to site soils. During site construction activities, stormwater management and E&S control measures would be implemented and adhered to in accordance with PADEP and the MCCD requirements. Through appropriate measures and the installation of BMPs, off site wetlands and streams would be protected from inadvertent sediment runoff during construction activities.

Noise

The project area is adjacent to residential areas; therefore, noise sensitive receptors are present in the vicinity of this project. However, construction activities related to this project would be minor and temporary in duration. The contractor would adhere to local noise ordinances regarding when construction can begin in the morning, and when it must conclude in the evening (i.e. no construction between 6 p.m. and 7:30 a.m.). Therefore, noise impacts during construction are anticipated to be insignificant.

Utilities

The road improvement plans will incorporate the findings of the utility survey in order to avoid conflicts with utilities during construction. During excavation activities, contact with subsurface utilities (e.g, electrical, natural gas, sewer, etc.) that are found in the facility must be avoided.

The contractor should take great care to avoid inadvertent contact with any subsurface utilities during construction.

Traffic

Traffic patterns within the ERRC will be temporarily impacted during repaving activities.

However, construction will be conducted in phases to minimize impacts.

Solid Waste

Demolition waste (e.g., construction debris) will be managed and transported to a solid waste landfill.

4.2.2 No Build Alternative

Implementation of the No-Build Alternative would have no significant short or long-term effects on the biophysical or socioeconomic environment. However, pavement existing pavement in the lower roadways would continue to deteriorate.

4.3 WALKING PATH

4.3.1 Build Alternative

Under the Build Alternative, the USDA, in partnership with the Philadelphia Water Department and the Friends of the Wissahickon, would construct a walking path adjacent to Cresheim Creek, resulting in minor disturbances to soils and vegetation. Potential adverse impacts that warrant further discussion include impacts associated with soils, surface waters, vegetation, noise, utilities and recreation.

Soils

Earthwork and other related construction activities would involve temporary impacts to site soils by the construction equipment used to construct a walking path. During site construction activities, stormwater management and E&S control measures would be implemented and adhered to in accordance with PADEP and MCCD requirements. Through appropriate measures and the installation of BMPs, off site wetlands and streams would be protected from inadvertent sediment runoff during construction activities.

Surface Waters

Direct impacts to surface waters would be avoided with the use of BMPs and an E&S plan to avoid sedimentation from entering Cresheim Creek during construction of the walking path.

Additionally, consideration will be given to use porous paving or other pervious options for path materials to reduce the amount of runoff from the path entering into Cresheim Creek.

Vegetation

Vegetation along the riparian corridor will need to be removed in order to construct the walking path. Efforts will be made to avoid mature tree removal. Understory vegetation consists of predominantly weedy or invasive species, so removal of these species, and replanting of native species, would enhance the riparian corridor.

Noise

The project area is adjacent to residential areas; therefore, noise sensitive receptors are present in the vicinity of this project. However, construction activities related to this project would be minor and temporary in duration. The contractor would adhere to local noise ordinances regarding when construction can begin in the morning, and when it must conclude in the evening (i.e. no construction between 6 p.m. and 7:30 a.m.). Therefore, noise impacts during construction are anticipated to be insignificant.

Utilities

The walking path design will incorporate the findings of the utility survey in order to avoid conflicts with utilities during construction. During excavation activities, contact with subsurface utilities (e.g, electrical, natural gas, sewer, etc.) that are found in the facility must be avoided.

The contractor should take great care to avoid inadvertent contact with any subsurface utilities during construction.

Recreation

Construction of a walking path along Cresheim Creek would provide direct access from residences along East Lane and points south, to Mermaid Park. Additionally, according to the feasibility study for The Cresheim Trail (Campbell Thomas & Co. Architects, 2008), there are long term plans to connect Mermaid Park to the Cresheim Trail system. Construction of the walking path would facilitate these efforts.

4.3.2 No Build Alternative

Implementation of the No-Build Alternative would have no significant short or long-term effects on the biophysical or socioeconomic environment.

SECTION 5.0

UNAVOIDABLE ADVERSE IMPACTS

Environmental impacts represent changes from the current situation and its environment that may be considered undesirable, but necessary to achieve the overall goals of the project. This project is proposed to occur entirely on a pre-existing research facility; site use and activities are projected to continue in its current form. Therefore, design plans will have limited impact on the project site and surrounding area. The intent of this chapter is to summarize environmental impacts that cannot be avoided, as required under 40 CFR, Part 1502.16. This section summarizes the potential unavoidable adverse impacts associated with implementing any of the alternatives.

Alternative 1 – Proposed Action

Unavoidable adverse impacts associated with implementing Alternative 1 (Proposed Action) would include:

Impacts to site soils and topography that would occur during construction activities.

These impacts are expected to be minor.

Small, but temporary additions of pollutants to the atmosphere as a result of operating heavy equipment during construction activities, and transportation of materials and wastes to and from the project area. Idling vehicles of any kind will be discouraged during construction activities.

Disposal of waste materials from the construction activities (primarily from the Road Improvements Project) will result the expenditure of landfill space at the receiving facility.

Short term noise impacts from the operation of heavy equipment, while temporary, are considered unavoidable. Contractors should be encouraged to maintain a regular maintenance program for heavy equipment to ensure that machinery is operating at peak efficiency relative to noise output.

Alternative 2 – No Action

This action would result in no unavoidable adverse impacts. No action would result in the facility continuing to operate under its current conditions. However, under the No Action Alternative for the Stream Restoration Project, the banks of Cresheim Creek would not be stabilized, and downstream erosion would not be reduced.

SECTION 6.0

IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF

RESOURCES

Irreversible commitments are those that are not reversible in the short term, and only potentially reversible or recoverable in the extreme long term. An example of this would be mining of coal or minerals, where once the material is removed from the earth, it cannot be replaced.

Implementation of the Preferred Alternative would involve the irreversible and irretrievable commitment of various natural, human, and fiscal resources. These resources would be permanently dedicated to the public use. Although utilization of the land can be considered an irreversible commitment of resources, it may be possible to convert the property to another use, should a greater need for the land be demonstrated. It is not anticipated, however, that this situation would occur.

Resources committed to this project that are not considered recoverable include fossil fuels, labor, construction materials, and financial resources. Electric power, gasoline, and diesel fuels would be consumed by worker vehicles, machinery, and tools during construction activities.

Upon completion of the project, fuel, power, and labor resources would largely remain at the current usage levels. Commitment of funds for design and implementation of the project reduces the availability of these resources for other projects. Construction materials used during the project would be considered an irreversible and irretrievable commitment of resources; however, most of these materials are not considered to be in short supply.

SECTION 7.0

CUMULATIVE EFFECTS

Cumulative effects include the total effect of an action, including direct and indirect effects, on the resources within the project area and the human environment surrounding the project area regardless of who has taken the action (e.g, federal, nonfederal, private). The purpose of reviewing cumulative effects is to address or evaluate the additive impacts of primary, secondary, and tertiary impacts within the project area. In order to avoid evaluating cumulative impacts on too grand a scale, this EA focused on only those effects that would be truly meaningful.

This project would occur within an existing research campus consisting of maintained lawns, paved roads/parking areas and existing buildings; land use and site activities are expected to remain unaffected into the future. Construction activities and the end result of the project are not expected to result in any adverse impacts to visual resources, traffic patterns, land use, or other environmental resources, and in fact, would have a positive cumulative impact to watercourses and the community as a whole.

SECTION 8.0

LIST OF PREPARERS & REVIEWERS

The following are primarily responsible for the preparation and review of this NEPA Environmental Assessment:

United States Department of Agriculture

Neil Goldberg Location Monitor Trisha Vigil Engineering Project Manager Sevim Erham Research Leader Joanne Sullivan Administrative Officer Bonnie Disalvo Safety, Health & Env. Branch Rep Phoebe Bordelon Real Property Man. Rep

STV Incorporated Contributions

Shamarukh Billah, PE Project Manager

Wendy Schellhamer, Sr. Env. Scientist Report Preparation, Coordination, Editor

Adam Wood, Environmental Scientist Report Preparation

Peter Gaskins, Sr. Env. Scientist QA/QC

SECTION 9.0

REFERENCES

Campbell Thomas & Co. Architects. A Feasibility Study for the Cresheim Trail. May 23, 2008.

Cedarville Engineering Group, LLC. Wetland Delineation Report, USDA Wyndmoor Creek Bed and Lower Road Repairs. November 15, 2018.

Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations.

“Fire Insurance Rate Map Nos. 42091C0383G and 42091C0379G for Springfield, PA”.