20100747 Ver 1_US 29 Widening_20070702

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Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
August 8, 2007
MEMORANDUM
To: Melba McGee
From: ,0Sue Homewood, Division of Water Quality, Winston-Salem Regional Office
Subject: Comments on the Finding of No Significant Impact related to proposed widening of US 29
Business (Freeway Drive) from existing SR 2670 (South Scales Street) to Existing NC 14,
Rockingham County, Federal Aid Project No. STP-29B(1), State Project No. 8.1511901, TIP U-
3326.
This office has reviewed the referenced document dated July 11, 2007. The Division of Water Quality (DWQ) is
responsible for the issuance of the Section 401 Water Quality Certification for activities that impact Waters of the
U.S., including wetlands. It is our understanding that the project as presented will result in impacts to jurisdictional
wetlands, streams, and other surface waters. The DWQ offers the following comments based on review of the
aforementioned document:
Project Specific Comments:
1. This project is being planned as part of the 404/NEPA Merger Process. As a participating team member, the
NCDWQ will continue to work with the team.
2. Little Troublesome Creek and Troublesome Creek are class C; NSW waters of the State. DWQ is very
concerned with sediment and erosion impacts that could result from this project. DWQ recommends that
highly protective sediment and erosion control BMPs be implemented to reduce the risk of nutrient runoff to
both creeks and their tributaries. DWQ requests that road design plans provide treatment of the storm water
runoff through best management practices as detailed in the most recent version of NC DWQ Stormwater Best
Management Practices.
3. Little Troublesome Creek is identified as a 303(d) waters of the State for impared use for aquatic life due to
impervious surface runoff sources. DWQ is very concerned with sediment and erosion impacts that could
result from this project. DWQ recommends that the most protective sediment and erosion control BMPs be
implemented to reduce the risk of nutrient runoff to Little Troublemsome Creek. DWQ requests that road
design plans provide treatment of the storm water runoff through best management practices as detailed in the
most recent version of NC DWQ Stormwater Best Management Practices.
4. Review of the project reveals the presence of surface waters classified as Water Supply Critical Area in the
project study area. Given the potential for impacts to these resources during the project implementation, the
DWQ requests that DOT strictly adhere to North Carolina regulations entitled "Design Standards in Sensitive
Watersheds" (15A NCAC 04B .0124) throughout design and construction of the project. This would apply
for any area that drains to streams having WS CA(Water Supply Critical Area) classifications.
The NCDOT will be required to design, construct, and maintain hazardous spill catch basins in the project
area. The number of catch basins installed shall be determined by the design of the bridge, so that runoff
would enter said basin(s) rather than flowing directly into the stream, and in consultation with the DWQ.
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Transportation Permitting Unit tuCQ??lf
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone: [phone] / FAX [phone] Internet: http://h2o enr.state.nc.us/ncwetlands
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General Comments:
5. The environmental document shall 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
211.0506(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.
6. Environmental assessment 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
Stormwater Best Management Practices, 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 NCDOT 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.
In accordance with the Environmental Management Commission's Rules {15A NCAC 2H.0506(h)),
mitigation will be required for impacts of greater than 150 linear feet to any single perennial stream. In the
event that mitigation is required, the mitigation plan shall be designed to replace appropriate lost functions
and values. The NC Ecosystem Enhancement Program may be available for use as stream mitigation.
9. 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.
10. NC DOT is respectfully reminded that all impacts, including but not limited to, bridging, fill, excavation and
clearing, 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 Quality Certification Application.
11. Where streams must be crossed, the DWQ 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 shall be
countersunk to allow unimpeded passage by fish and other aquatic organisms. Moreover, in areas where high
quality wetlands or streams are impacted, a bridge may prove preferable. When applicable, DOT should not
install the bridge bents in the creek, to the maximum extent practicable.
12. Sediment and erosion control measures shall not be placed in wetlands or streams.
13. Borrow/waste areas shall 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.
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15. Based on the information presented in the document, the magnitude of impacts to wetlands and streams may
require an Individual Permit (IP) 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 NCDOT and written concurrence
from the 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. Bridge supports (bents) shall not be placed in the stream when possible.
17. Whenever possible, the DWQ prefers spanning structures. Spanning structures usually do not require work
within the stream or grubbing of the streambanks and do not require stream channel realignment. The
horizontal and vertical clearances provided by bridges allow for human and wildlife passage beneath the
structure, do not block fish passage and do not block navigation by canoeists and boaters.
18. 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 NC DWQ ,Stormwater Best
Management Practices.
19. 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.
20. 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.
21. Placement of culverts and other structures in waters, streams, and wetlands shall 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 inches, to allow low flow passage of water and
aquatic life. Design and placement of culverts and other structures including temporary erosion control
measures shall not be conducted in a manner that may result in dis-equilibrium of wetlands or streambeds or
banks, adjacent to or upstream and down stream of the above structures. The applicant is required to provide
evidence that the equilibrium is being maintained if requested in writing by DWQ. If this condition is unable
to be met due to bedrock or other limiting features encountered during construction, please contact the NC
DWQ for guidance on how to proceed and to determine whether or not a permit modification will be required.
22. 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 and/or sills 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.
23. If foundation test borings are necessary; it shall be noted in the document. Geotechnical work is approved
under General 401 Certification Number 3494/Nationwide Permit No. 6 for Survey Activities.
24. 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. .
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25. 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.
26. 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.
27. Heavy equipment shall 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.
28. 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 shall be properly designed, sized and installed.
29. 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.
The NCDWQ appreciates the opportunity to provide comments on your project. Should you have any questions or
require any additional information, please contact Sue Homewood at 336-771-4964 or at
[e-mail].
cc: Andy Williams, US Army Corps of Engineers, Raleigh Field Office
Felix Davila, Federal Highway Administration
Chris Militscher, Environmental Protection Agency
Travis Wilson, NC Wildlife Resources Commission
Gary Jordan, US Fish and Wildlife Service
DWQ 401 Wetlands Transportation Permitting Unit