HomeMy WebLinkAbout19970118 Ver 1_Complete File_19970220.?h
9 7 01 1 g
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
JAMES B. HUNT JR. DIVISION OF HIGHWAYS
GOVERNOR P.O. BOX 25201, RALEIGH, N.C. 27611-5201
February 14, 1997
U. S. Army Corps of Engineers
Regulatory Field Office
P. O. Box 1890
Wilmington, North Carolina 28402-1890
ATTN: Mr. Cliff Winefordner
Chief, Southern Section
Dear Sir:
GARLAND B. GARRETT JR.
SECRETARY
SUBJECT: Catawba County, Replacement of Bridge No. 82 over Clark Creek
on SR 1165; Federal Aid Project No. BRZ-1 165(5), State Project
No. 8.2791501, TIP No. B-2940.
Attached for your information is a copy of the project planning document for the
subject project prepared by the North Carolina Department of Transportation (DOT) and
signed by the Federal Highway Administration (FHWA) on October 31, 1996. The
project involves replacing Bridge No. 82 over Clark Creek on SR 1165. The new bridge
will be placed on existing alignment. During project construction, traffic will be
maintained using an off site detour. No jurisdictional wetlands will be impacted by the
subject project.
The project is being processed by the FHWA as a "Categorical Exclusion" (CE) in
accordance with 23 CFR 771.115(b). Therefore, the DOT does not anticipate requesting
an individual permit but proposes to proceed under a Nationwide Permit 23 in accordance
with 33 CFR 330 Appendix A (B-23) issued December 13, 1996, by the Corps of
Engineers (COE). The provisions of Section 330.4 and Appendix A (C) of these
regulations will be followed in the construction of the project.
The DOT anticipates that 401 Gene I ter Quality Certification for an approved
CE will apply to this project. A copy of a CE d cument has also been provided to the
North Carolina Department of Environme t, Hea h and Natural Resources, Division of
Water Quality, for their review.
A-41
r, 01
2
If you have any questions or need any additional information, please contact
Mr. Phillip Todd at (919) 733-7844 extension 314.
Sincerel ,
H. Franklin Vick, PE, Manager
Planning and Environmental Branch
HFV/pct
cc: w/ attachments
Mr. Bob Johnson, COE, Asheville
Mr. John Dorney, NCDEHNR, Division of Water Quality
Mr. William Rogers, P.E., Structure Design
w/o attachments
Mr. Kelly Barger, P.E., Program Development
Mr. Don Morton, P.E., Highway Design
Mr. A. L. Hankins, P.E., Hydraulics Unit
Mr. Tom Shearin, P.E., Roadway Design
Mr. R. W. Spangler, P.E., Division 12 Engineer
Mr. Jim Buck, P.E., Planning & Environmental
Catawba County
SR 1165
Bridge No. 82 Over Clark Creek
Federal-Aid Project No. BRZ-1165(5)
State Project No. 8.2791501
T.I.P. No. B-2940
CATEGORICAL EXCLUSION
U.S. DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
AND
N.C. DEPARTMENT OF TRANSPORTATION
DIVISION OF HIGHWAYS
APPROVED:
/? 3 b
DATE H. ranklin Vick, P.E., Manager
Planning and Environmental Branch, NCDOT
/ey
DATE J;or Nicholas L. Graf, P.E.
Division Administrator, FHWA
A
Catawba County
SR 1165
Bridge No. 82 Over Clark Creek
Federal-Aid Project No. BRZ-1165(5)
State Project No. 8.2791501
T.I.P. No. B-2940
CATEGORICAL EXCLUSION
OCTOBER 1996
Document Prepared by Wang Engineering Company, Inc.
Cy"Y?? (;1 • ?J? J tMMMMNNj//
Pamela R. Williams ?ZN cp0
Project Engineer g O,
SEAL
r r,,2,
9 '• ?'GINEE`? ? '
mes Wang, Ph.D., P.E. .,?? •..,..,.. ?,
resident
For North Carolina Department of Transportation
L. Gail rimes, P.E , U it Head
Cons nt Engine rin Unit
ames A. Buck, P. E.
Project Planning Engineer
Catawba County
SR 1165
Bridge No. 82 Over Clark Creek
Federal-Aid Project No. BRZ-1165(5)
State Project No. 8.791501
T.I.P. No. B-2940
Bridge No. 82 is included in the North Carolina Department of Transportation (NCDOT) 1997-
2003 Transportation Improvement Program. The location is shown in Figure 1. No substantial
impacts are anticipated as a result of this action. The project is classed as a Federal
"Categorical Exclusion."
1. SUMMARY OF ENVIRONMENTAL COMMITMENTS
1. All Standard procedures and measures, including NCDOT's Best Management Practices for
Protection of Surface Waters, will be implemented, as applicable, to avoid or minimize
environmental impacts.
2. Construction will be scheduled to include the summer months to minimize impacts on school
bus traffic.
3. Location and installation of any required deck drains will be determined during final design
phase.
II. SUMMARY OF RECOMMENDATIONS
Bridge No. 82 will be replaced on the existing alignment as shown in Figure 2. It will be replaced
with a new bridge having a clear roadway width of 9.2 meters (30 ft) and a length of 46 meters
(151 ft).
The grade of the new structure will be approximately the same as the existing bridge grade at
this location. A vertical design exception will be required.
The proposed approach roadway will have a 7.2 meter (24 ft) travelway with 2.4 meters (8 ft)
shoulders, including 0.6 meter (2 ft) paved, for approximately 110 meters (360 ft) east and west
of the bridge.
During construction, traffic will be detoured off-site as shown in Figure 1.
The estimated cost, based on current prices, is $961,000 including $61,000 for right-of-way and
$900,000 for construction. The estimated cost of the project, as shown in the NCDOT 1997-
2003 Transportation Improvement Program, is $450,000 including $30,000 for right-of-way and
$420,000 for construction.
III. EXISTING CONDITIONS
SR 1165 is classified as a rural collector route in the Statewide Functional Classification System.
Land use is primarily residential, forest land and agricultural in the immediate vicinity of the
bridge. Bridge No. 82 is located approximately 215 meters (700 ft) downstream from the
confluence of Cline Creek and Clark Creek.
The existing bridge is located in a vertical sag with an approximate 9 percent grade on the west
approach and an approximate 4 percent grade on the east approach. A design exception for
the vertical alignment will be required.
Near the bridge SR 1165 is tangent and has a 5.9 meter (19.2 ft) pavement width and 1.8 meter
(6 ft) shoulders. Both approaches are constructed on 7.0 meter (23 ft) embankments. The
surface of the bridge is approximately 9.0 meters (29.5 ft) above the creek bed.
The speed limit is posted 70 km/h (45 mph) at the project site and the existing northwest
approach curve has an advisory speed of 55 km/h (35 mph).
SR 1165 is a connector between SR 1005 and SR 1149, minor arterials for Hickory and
Conover, respectively. These minor arterials serve area which are beginning to undergo
suburbanization. The thoroughfare plan for the Cities of Hickory, Newton and Conover show
the proposed Newton-Conover Southern Loop (T.I.P. No. U-2532) will use the existing SR 1165
alignment. Construction of the Southern Outer Loop is scheduled to begin between 2015 and
2025. When the Southern Loop is completed and open to traffic, the section which includes this
bridge is expected to carry 15,800 vehicles per day (vpd). Prior to construction of the Southern
Loop, the projected traffic volume are 2,700 vpd for 1997 and 6,200 vpd for the design year
2017. The proposed bridge replacement project is based on design traffic volumes prior to the
construction of the Southern Loop. The volumes include one percent truck-tractor semi-trailer
(TTST) and two percent dual-tired vehicles (DT), twelve percent design hourly volume and fifty-
five percent directional.
The existing bridge was built in 1960 (Figure 3). The superstructure consists of timber deck on
steel 1-beams with an asphalt wearing surface. The substructure consists of timber caps and
piles with cross bracing and vertical timber bulkheads at the abutments.
The overall length of the bridge is 46.0 meters (151 ft). The clear roadway width is 5.9 meters
(19.2 ft). The posted weight limit is 12,712 kilograms (14 tons) for single vehicles and 16,344
kilograms (18 tons) for truck-tractor semi-trailers.
Bridge No. 82 has a sufficiency rating of 42.2, compared to a rating of 100 for a new structure.
Four accidents were reported on the bridge during the period from April 1, 1992 to March 31,
1995. Two accidents were double vehicle with icy conditions. Two accidents were single
vehicle accidents, one in icy conditions, the other exceeding the speed limit. All accidents
involved loss control of the vehicle
According to Catawba County Planning Department, there is a 24-inch sewer line on the east
side of the bridge. An overhead electric power line is on the north side of the bridge. An
overhead telephone line crosses SR 1165 to the west of the bridge. Utility impacts are
anticipated to be low.
Three Catawba County school buses cross the bridge twice daily.
IV. ALTERNATIVES
Several preliminary alternatives were studied for replacing Bridge No. 82 including replacement
with a bridge or a culvert. Economical analysis eliminated the option of replacing the bridge with
a culvert due to fill heights and size of the culvert. The bridge alternatives studied for replacing
Bridge No. 82 include a new bridge 46.0 meters (151 ft) in length, that will accommodate a 7.2
meter (24 ft) travelway with 1.0 meter (3 ft) shoulders on each side. The approach roadway
consists of a 7.2 meter (24 ft) travelway with 2.4 meter (8 ft) shoulders, including 0.6 meter (2
ft) paved shoulders.
Alternate A: Replace the bridge on existing alignment with a temporary on-site detour bridge
on the south side. The roadway grade of the new structure will be approximately the same as
the grade on the existing bridge. The approach work will extend approximately 110 meters (360
ft) east and west of the proposed bridge. A vertical design exception will be required. The
detour bridge will require a length of 30 meters (99 ft).
Alternate B (Recommended): Replace Bridge No. 82 will be replaced on existing alignment at
approximately the same elevation. Traffic will be detoured off-site along existing roads during
construction. The approach work will extend approximately 110 meters (360 ft) east and west of
the proposed bridge. A vertical design exception will be required.
Other Alternates:
The "do-nothing" alternative would eventually necessitate closure of the bridge. This is not
desirable due to the traffic service provided by SR 1165.
Investigation of the existing structure by the Bridge Maintenance Unit indicates the rehabilitation
of the old bridge is not feasible due to its age and deteriorated condition.
3
V. ESTIMATED COST
The estimated costs of the alternate studied, based on current prices, are as follow:
Alternate A
Structure Removal (existing) $ 18,240
Structure (proposed) 296,240
Temp. Detour Structure and Approaches 338,800
Roadway Approaches 275,020
Miscellaneous and Mobilization 296,700
Engineering and Contingencies 175,000
ROW/Const. Easements/Utilities 68,000
TOTAL $ 1,468,000
VI. TRAFFIC DETOUR
(Recommended)
Alternate B
$ 18,240
296,240
N/A
275,020
185,500
125,000
61,000
$ 961,000
An eight month road closure period is anticipated. Traffic will be detoured along SR 1149 and
SR 1005, an approximate distance of 5.0 kilometers (3.1 miles). The detour roadway and
bridges are adequate to accommodate the detoured traffic during the construction period.
Provision of an on-site detour is not justifiable due to added cost incurred by the extensive fill
heights and length of detour structure.
Construction will be scheduled to include the summer months to minimize impacts on school
bus traffic.
VII. RECOMMENDED IMPROVEMENTS
Alternate B is recommended because it is the most economical.
Bridge No. 82 will be replaced on the existing alignment at approximately the same elevation
with a length of 46 meters (151 ft). A vertical design exception will be required.
A 9.2 meter (30 ft) clear roadway width is recommended on the replacement structure in
accordance with the current NCDOT Bridge Policy. This will provide a 7.2 meter (24 ft)
travelway with 1 meter (3 ft) shoulders across the structure.
A 7.2 meter (24 ft) travelway with 2.4 meter (8 ft) shoulders, including 0.6 meter (2 ft) paved, will
be provided on the proposed approaches.
The Division Engineer concurs in the recommendation that the structure be replaced on the
existing alignment with SR 1165 closed during construction and traffic detoured along other
existing roads.
4
Based on a preliminary hydraulic analysis utilizing the 25 year design storm, the new structure is
recommended to have a length of approximately 46 meters (151 ft). The elevation of the new
structure will be approximately the same as the existing bridge. The replacement structure will
maintain a minimum 0.3% grade to facilitate deck drainage. The length and height may be
increased or decreased as necessary to accommodate peak flows as determined by further
hydrologic studies.
VIII. ANTICIPATED DESIGN EXCEPTION
A vertical design exception for the design speed will be required due to the existing vertical
alignment. The existing vertical design speed is approximately 60 km/h (35 mph), which is
within the character of SR 1165. The speed limit is posted 70 km/h (45 mph) at the project site.
Improving the vertical alignment to a design speed of 80 km/h (50 mph) will require raising the
grade approximately 1.8 meters (6 ft). This was not considered reasonable due to the
additional environmental impacts, right-of-way and construction costs, and major changes to
the vertical alignment.
IX. NATURAL RESOURCES
The proposed project is located within rural Catawba County (Figure 1) in the Piedmont
Physiographic Province of North Carolina. Catawba County is primarily agricultural but is rapidly
becoming an industrial and urban county.
Methodology
Informational sources used to prepare this report include: United States Geological Survey
(USGS) quadrangle map (Hickory, 1970); NCDOT aerial photographs of project area (1:1200);
Soil Conservation Service (SCS) soil maps (1975); Fish and Wildlife Service (FWS) National
Wetlands Inventory Map (Hickory, 1994); FWS list of protected and candidate species; and
North Carolina Natural Heritage Program (NCNHP) database of uncommon species and unique
habitats. Research using these resources was conducted prior to the field investigation.
A general field survey was conducted along the proposed project corridor on March 20, 1996.
Plant communities and their associated wildlife were identified using a variety of observation
techniques, including active searching, visual observations with binoculars, and identifying
characteristic signs of wildlife (sounds, tracks, scat, and burrows).
Quantitative impact calculations were based on the worst case scenario using the full 24.4 m
(80.0 ft) wide right-of-way limits and the width of the replacement structure, the width of the
stream for aquatic impacts, and the length of the project approaches. The actual construction
impacts should be less, but without specific replacement structure design information (culvert,
pier intrusions, etc.) the worst case was assumed for the impact calculations.
Definitions for area descriptions used in this report are as follows: "project study area," "project
area," and "project corridor" denote the specific area being directly impacted by each
alternative. "Project vicinity" denotes the area within a 1.6 km (1.0 mi.) radius of the project
area.
5
Topography and Soils
The topography of the project vicinity is characterized as rolling hills with steeper slopes along
the major streams. Project area elevation is approximately 268.2 meters (880.0 feet).
This portion of Catawba County contains soils from the Hiwassee-Cecil association, which are
characterized as being gently sloping to moderately steep soils that have a subsoil that is
dominantly dark-red or red, firm clay found on broad ridgetops and short side slopes. The field
investigation confirms the soils as they are mapped.
WATER RESOURCES
This section describes each water resource and its relationship to major water systems. The
proposed project lies within the Catawba River drainage basin.
Water Resource Characteristics
Clark Creek is a perennial tributary within the Catawba River basin. The stream banks are well
defined, approximately 3.0 meters (10.0 feet) high, and vegetated with river birch, ironwood
(carpinus caroliniana), greenbrier and blackberry. The stream flows north to south through the
proposed project area with a width at the bridge of 10.1 meters (33.0 feet). On the day of
investigation the stream was turbid and the bottom was only visible in a few shallow areas. The
bottom consists of medium to coarse gravel covered with silt. The depth of the stream could
not be accurately determined due to the turbidity and the swift flow. Clark Creek has a Class C
rating and a stream index no. of 11-129-5-(4.5) from the NCDEM, indicating the creek's
suitability for aquatic life propagation and survival, fishing, wildlife, secondary recreation,
agriculture, and other uses. The Federal Emergency Management Agency (FEMA) Flood
Boundary and Floodway Map for Catawba County (1980) indicates the project area lies in Zone
AE where base flood elevations have been determined. The base flood elevation at Bridge No.
82 is 262.4 meters (861.0 feet).
The NCDEM does maintain a benthic macroinvertebrate sampling station on Clark Creek
downstream of the project area. Benthic macroinvertebrates, or benthos, are organisms that
live in and on the bottom substrates of rivers and streams. The use of benthos data has proven
to be a reliable tool as some benthic macroinvertebrates are sensitive to subtle changes in
water quality. Criteria have been developed to assign bioclassifications ranging from "Poor" to
"Excellent" to each benthic sample based on the number of taxa present in the intolerant groups
Ephemeroptera, Plecoptera and Tdchoptera (EPT). Different criteria have been developed for
different ecoregions (mountains, piedmont, coastal) within North Carolina. Data from Clark
Creek at SR 1149 in August 1992 indicated an EPT taxa richness value of 16, which has a
bioclassification of "Good-Fair".
The NCDEM also uses the North Carolina Index of Biotic Integrity (NCIBI) as another method to
determine general water quality. The method was developed for assessing a stream's
biological integrity by examining the structure and health of its fish communities. The scores
derived from the index are a measure of the ecological health of the waterbody and may not
necessarily directly correlate to water quality. There is no NCIBI data for Clark Creek.
The Catawba County Watershed Protection District Ordinance (1993) provides regulations to
limit the exposure of watersheds in Catawba County to pollution. The Critical Area is defined as
being one-half mile from a lake or where water is taken from a river. The critical area is the area
closest to the drinking water source. Regulations restrict development in this area. The
Protected Area is the remainder of the watershed where the regulations apply. The Watershed
Protection District Map indicates that the project area is not within a Critical Area.
No waters classified by NCDEM as High Quality Waters (HQW), Outstanding Resource Waters
(ORW), or waters designated as WS-1 or WS-II are located within 1.6 km (1.0 mile) of the
project study area. No impacts to sensitive water resources of any kind will take place as a
result of the project construction.
Anticipated Impacts to Water Resources
Short-term impacts to water quality can be anticipated from construction-related activities, which
may increase sedimentation and turbidity. Short-term impacts will be minimized by the
implementation of NCDOT's Best Management Practices for Protection of Surface Waters, as
applicable. Long-term impacts to water resources are not expected as a result of proposed
improvements.
BIOTIC RESOURCES
Living systems described in the following sections include communities of associated plants and
animals. These descriptions refer to the dominant flora and fauna in each community and the
relationship of these biotic components. Scientific nomenclature and common names (when
applicable) are used for the plant and animal species described. Subsequent references to the
same species include the common name only.
Terrestrial Communities
The predominant terrestrial communities found in the project study area are man-dominated
and mixed hardwood forest. Dominant faunal components associated with these terrestrial
areas are discussed under the community description. Many species are adapted to the entire
range of habitats found along the project alignment, but may not be mentioned separately in
each community description.
Man-Dominated Community
This highly disturbed community includes the road shoulders, the powerline easement, the
pastures to the southeast and southwest of the bridge, and the open grassy field to the
northeast of the bridge (Figure 2). These regularly maintained areas are dominated by fescue
(Festuca sp.), ryegrass (Lolium sp.), white clover (Trifolium repens), thistle (Cirsium sp.),
broomsedge (Andropogen virginicus), wild onion (Allium canadense), violet (Viola sp.), and
dandelion (Taraxacum offrcinale).
The animal species present in these disturbed habitats are opportunistic and capable of
surviving on a variety of resources, ranging from vegetation (flowers, leaves, fruits, and seeds)
to living and dead faunal components. Virginia opossum (Didelphis virginiana), American crow
(Corvus brachyrhynchos), and Northern cardinal (Cardinalis cardinalis) were observed during
the site visit. Other animals such as mice (Peromyscus sp.), the Northern mockingbird (Mimus
polyglottos), and the American robin (Turdus migratodus) are also often attracted to these
roadside habitats.
Mixed Hardwood Community
This forested community occurs on the moderate slopes along Clark Creek as well as in narrow
strips in the pastures and field. The dominant canopy trees in this area include river birch
(Betula nigra), loblolly pine (Pinus taeda), southern red oak (Quercus falcata), red maple (Acer
rubrum), white oak (Quercus albs), Eastern red cedar (Juniperus virginiana), post oak (Quercus
stellata), and sweetgum (Liquidambar styraciflua). The herbaceous layer consists mainly of
Japanese honeysuckle (Lonicera japonica), common greenbder (Smilax rotundifolia),
blackberry (Rubus sp.), and giant cane (Arundinaria gigantea). Gray squirrel (Sciurus
carolinensis), raccoon (Procyon lotor), and mourning dove (Zenaida macroura) were observed
during the site visit.
Although not observed during the site visit, the animals previously listed may be found in this
community along with whitetail deer (Odocoileus virginianus), Eastern cottontail (Sylvilagus
floridanus), downy woodpecker (Picoides pubescens), Carolina wren (Thryothorus
ludovicianus), and Eastern box turtle (Terrapene carolina carolina).
Aquatic Communities
The aquatic community in the project area exists within Clark Creek.
Animals such as the Northern water snake (Nerodia sipedon sipedon), the bullfrog (Rana
catesbeiana), and the Southern leopard frog (Rana utricularia) may reside along the waters
edge. The macroinvertebrate community of this stream would include mayfly (Ephemeroptera),
stonefly (Plecoptera), caddisfly (Trichoptera) and dragonfly (Odonata) larvae under stones and
within the leaf debris as well as chironomid (midges) larvae and oligochaetes (segmented
worms) within the substrate. No macroinvertebrates were observed during the site visit.
According to the North Carolina Wildlife Resources Commission (Memorandum dated April 10,
1996), the following fish species were collected in Clark Creek in 1993: bluehead chub
(Nocomis leptocephalus), white sucker (Catostomus commersoni), flat bullhead (Ameiurus
platycephalus), redbreast sunfish (Lepomis auritus), pumkinseed (Lepomis gibbosus), bluegill
(Lepomis macrochirus), and large mouth bass (Micropte?us salmoides).
Anticipated Impacts to Biotic Communities
Biotic community impacts resulting from project construction are addressed separately as
terrestrial impacts and aquatic impacts. Table 1 details the anticipated impacts to terrestrial and
aquatic communities by habitat type. However, impacts to terrestrial communities, particularly in
locations exhibiting steep slopes, can result in the aquatic community receiving heavy sediment
loads as a consequence of erosion. The NCDOTs Best Management Practices for Protection
of Surface Waters, will be implemented, as applicable, to ensure sediment does not leave the
construction site.
8
TABLE 1
ANTICIPATED IMPACTS TO
TERRESTRIAL and AQUATIC COMMUNITIES
HECTARES(ACRES)
Bridge #82 Man- Mixed Aquatic Combined Total
Replacement Dominated Hardwood Community
Impacts Community Community
Alternative A 0.25 (0.62) 0.06 (0.16) 0.02 (0.05) 0.33 (0.83)
Temporary 0.40 (1.0) 0.04 (0.10) 0.02 (0.05) 0.46(l.16)
Detour
Alternative B 0.25 (0.62) 0.06 (0.16) 0.02 (0.05) 0.33 (0.83)
Recommended
Impacts to Terrestrial Communities
Of the two communities in the project area,
greatest impact from construction, resulting in
and mortality of faunal species in residence.
the man-dominated community will receive the
the loss of existing habitats and displacement
Impacts to Aquatic Communities
The aquatic community in the study area exists within Clark Creek. The proposed bridge
replacement may result in the disturbance of up to 0.02 hectare (0.05 acre) of stream bottom.
The new replacement structure construction and approach work will likely increase sediment
loads in the stream in the short term. Construction related sedimentation can be harmful to
local populations of invertebrates which are an important part of the aquatic food chain. The
impacts to the stream community will not be confined to the 0.02 hectare (0.05 acre) impact
zone. Potential adverse effects will be minimized through the implementation of NCDOT's Best
Management Practices for Protection of Surface Waters, as applicable, and the use of erosion
and sediment control measures as specified in NCDOT Erosion and Sedimentation Control
Guidelines for Contract Construction (January 1995)".
SPECIAL TOPICS
Jurisdictional Issues
Waters of the United States
Wetlands and surface waters fall under the broad category of "Waters of the United States" as
defined in 33 CFR 328.3 and in accordance with provisions of Section 404 of the Clean Water
Act (33 U.S.C. 1344) and are regulated by the U.S. Army Corps of Engineers (USACOE).
Impacts to Wetlands and Surface Waters
9
No wetlands will be impacted by the subject project as Clark Creek has well defined banks
within the bridge replacement corridor. Investigation into wetland occurrence in the project area
was conducted using methods of the 1987 Wetland Delineation Manual. Project construction
cannot be accomplished without infringing on jurisdictional surface waters. Up to 0.02 hectare
(0.05 acre) of jurisdictional surface water impacts may occur due to the proposed replacement
of Bridge No. 82.
Permits
Nationwide Permit No. 23 CFR 330.5(a)(23) is likely to be applicable for all impacts to Waters of
the United States from the proposed project. This permit authorizes activities undertaken,
assisted, authorized, regulated, funded or financed in whole, or part, by another Federal agency
or department where:
1) that agency or department has determined the pursuant to the council on environmental
quality regulation for implementing the procedural provisions of the national
Environmental Policy Act;
2) that the activity, work, or discharge is categorically excluded from environmental
documentation because it is included within a category of actions which neither
individually nor cumulatively have a significant effect on the human environment, and;
3) that the office of the Chief of Engineers has been furnished notice to the agency's or
department's application for the categorical exclusion and concurs with that
determination.
The NCWRC made several potential recommendations pertaining to the permit application for
this project in a April 10, 1996, memorandum (Appendix). The recommendations as applicable,
will be implemented in accordance with NCDOT's Best Management Practices for Protection of
Surface Waters.
Mitigation
Since this project will not impact jurisdictional wetlands, compensatory mitigation will not be
required. Mitigation requirements on projects covered by Nationwide permits are left up to the
discretion of the USACOE.
Rare and Protected Species
Some populations of plants and animals have been in or are in the process of decline either due
to natural forces or due to their inability to coexist with man. Rare and protected species listed
for Catawba County, and any likely impacts to these species as a result of the proposed project
construction, are discussed in the following sections.
Federally Protected Species
Plants and animals with federal classification of Endangered (E), Threatened (T), Proposed
Endangered (PE) and Proposed Threatened (PT) are protected under provisions of Section 7
10
and Section 9 of the Endangered Species Act of 1973, as amended. The USFWS lists one
federally protected species for Catawba County as of August 23, 1996, (see Table 2).
TABLE 2
FEDERALLY-PROTECTED SPECIES
FOR CATAWBA COUNTY
Scientific Name Status
(Common Name)
Hexastylis naniflora T
(Dwarf-flowered heartleaf)
NOTE:
T Denotes Threatened (a species that is likely to become an endangered species within the
foreseeable future throughout all or a significant portion of its range).
The dwarf-flowered heartleaf is a perennial, evergreen herbaceous plant having the aroma of
ginger. The leaves of the dwarf-flowered heartleaf are variegated, cordate to orbicular-cordate
and approximately 4.0 to 6.0 cm (1.6 to 2.4 inches) long and wide. The flowers have a
cylindrical calyx tube with an apical flare which is wider than the calyx tube is long. The flowers
are present between late March and June.
The dwarf-flowered heartleaf is often found in mature, deciduous forests on acidic, sandy loam
soils of north facing bluffs and ravines. It is frequently associated with mountain laurel, and with
Pacolet sandy loam soil of the Piedmont physiographic province.
No habitat exists in the project area as the project area does not contain acidic, sandy
loam soil or north facing slopes. It can be concluded that the proposed project will not
impact this Threatened species.
BIOLOGICAL CONCLUSION: NO EFFECT
Federal Species of Concern
Federal Species of Concern (FSC) are not legally protected under the Endangered Species Act
and are not subject to any of its provisions, including Section 7, until they are formally proposed
or listed as Threatened of Endangered. Species designated as FSC are defined as taxa which
may or may not be listed in the future. These species are formerly Candidate 2 (C2) species, or
species under consideration for listing for which there is insufficient information to support listing.
NCNHP database showed no recorded occurrences of state protected species within the
project vicinity. Table 3 includes FSC species listed for Catawba County and their state
classifications.
11
TABLE 3
FEDERAL SPECIES OF CONCERN
CATAWBA COUNTY
Scientific Name North Carolina Habitat Present
(Common Name) Status
Dactyloctythere isabelae N/L No
(Catawba crayfish ostracod)
Monotropsis odorata C Yes
(Sweet pinesap)
NOTES:
C Denotes Candidate species are considered by the State as being rare and needing population
monitoring.
N/L Denotes species for which the state status is not listed at this time.
State Protected Species
Plant and animals which are listed as Endangered (E), Threatened (T), or Special Concern
(SC) by the NCNHP list of Rare Plant and Animal species are afforded limited state protection
under the State Endangered Species Act and the North Carolina Plant Protection and
Conservation Act of 1979.
The NCNHP records indicated two state-listed Special Concern species, highfin carpsucker
(Carpiodes velifer) and loggerhead shrike (Lanius ludovicianus ludovicianus). A search of the
NCNHP database showed no recorded occurrences of state protected species within the
project vicinity and no individuals were observed during the investigation.
X. CULTURAL EFFECTS
This project is subject to compliance with Section 106 of the National Historical Preservation
Act of 1966, as amended, implemented by the Advisory Council on Historic Preservation's
Regulations for Compliance with Section 106, codified at 36 CFR Part 800. Section 106
requires that for federally funded, licensed, or permitted projects having an effect on properties
listed in or eligible for the National Register of Historic Places, the Advisory Council on Historic
Preservation be given the opportunity to comment.
In a Concurrence Form, dated April 11, 1996, the State Historic Preservation Officer (SHPO)
concurred that there are no historic architectural resources either listed in or eligible for listing in
the National Register of Historic Places located in the project's area of potential effect. A copy
of the SHPO letter is included in the Appendix.
The SHPO, in a memorandum dated April 4, 1996, stated there are no known archaeological
sites within the proposed project area and therefore, SHPO recommended that no
archaeological investigation be conducted in connection with this project. A copy of the SHPO
memorandum is included in the Appendix.
12
XI. ENVIRONMENTAL EFFECTS
The project is expected to have an overall positive impact. Replacement of an inadequate
bridge will result in safer traffic operations.
The bridge replacement will not have an adverse effect on the quality of the human or natural
environment with the use of current NCDOT standards and specifications.
The project is not in conflict with any plan, existing land use, or zoning regulation. No significant
change in land use is expected to result from construction of the project.
No adverse impact on families or communities is anticipated. No relocatees are expected with
implementation of the proposed alternatives.
No adverse effect on public facilities or services is anticipated. The project is not expected to
adversely affect social, economic, or religious opportunities in the area.
There are no publicly owned parks, recreational facilities, or wildlife and waterfowl refuges of
national, state, or local significance in the vicinity of the project.
No geodetic survey markers will be impacted.
The Farmland Protection Policy Act requires all federal agencies or their representatives to
consider the potential impacts to prime and important farmland soils by all land acquisition and
construction projects. Prime and important farmland soils are defined by the U.S. Soil
Conservation Service (SCS). Since the bridge will be replaced at the existing location, the
Farmland Protection Policy Act does not apply.
This project is an air quality "neutral" project, so it is not required to be included the regional
emission analysis (if applicable) and a project level CO analysis is not required.
The project is located in Catawba County, which has been determined to be in compliance with
the National Ambient Air Quality Standards. 40 CFR Part 51 is not applicable because the
proposed project is located in an attainment area. This project is not anticipated to create any
adverse effects on the air quality of this attainment area.
The traffic volumes will not increase or decrease because of this project. There are no
receptors located in the immediate project area. The projects impact on noise and air quality
will not be significant.
Noise levels could increase during construction but will be temporary. If vegetation is disposed
of by burning, all burning shall be done in accordance with applicable local laws and regulations
of the North Carolina SIP air quality in compliance with 15 NCAC 2D.0520. This evaluation
completes the assessment requirements for highway traffic noise (23 CFR Part 772) and for air
quality (1990 CAAA and NEPA) and no additional reports are required.
An examination of records at the North Carolina Department of Environment, Health and
Natural Resources, Division of Environmental Management, Groundwater Section and the
13
North Carolina Department of Human Resources, Solid Waste Management Section revealed
no underground storage tanks or hazardous waste sites in the project area.
Catawba County is a participant in the National Flood Insurance Program. The approximate 100
year floodplain in the project area is shown in Figure 4. The amount of floodplain area to be
affected is not considered to be significant.
On the basis of the above discussion, it is concluded that no significant adverse environmental
effects will result from implementation of the project. The project is a Federal "Categorical
Exclusion" due to its limited scope and lack of significant environmental consequences.
14
REFERENCES
Burt, W.H. and R.P. Grossenheider. 1952. A Field Guide to Mammals. Houghton Mifflin
Publishing, Boston, Massachusetts.
Catawba County Watershed Protection District Ordinance. 1993.
Conant, R., and J.T. Collins. 1958. A Field Guide to Reptiles and Amphibians of Eastern and
Central North America. Houghton Mifflin Publishing, Boston, Massachusetts.
Cowardin, L.M., V. Carter, F.C. Golet and E.T. LaRoe. 1979. Classification of Wetlands and
Deepwater Habitats of the United States. Prepared for the U.S. Fish and Wildlife Service,
United States Department of the Interior, Washington DC.
Delorit, R.J. 1970. An Illustrated Taxonomy Manual of Weed Seeds. Agronomy Publications,
River Falls, Wisconsin.
Environmental Laboratory. 1987. U.S. Army Corps of Engineers Wetlands Delineation Manual,
Technical Report Y-87-1. United States Army Engineer Waterways Experiment Station,
Vicksburg, Mississippi.
Farrand, J., Jr. 1993. Audubon Society Guide to Animal Tracks of North America. Chanticleer
Press, New York, New York.
Natural Heritage Program. February, 1996. List of Rare Animal Species of North Carolina.
North Carolina Natural Heritage Program, Raleigh, North Carolina.
Newcomb, L. 1977. Newcomb's Wildflower Guide. Little, Brown and Company, Boston,
Massachusetts.
North Carolina Department of Environment, Health, and Natural Resources. 1993.
Classifications and Water Quality Standards Assigned to The Waters of the Catawba River
Basin. Division of Environmental Management, Raleigh, North Carolina.
Preston, R.J. and V.G. Wright. Identification of Southeastern Trees in Winter. North Carolina
Cooperative Extension Service, Raleigh, North Carolina.
Radford, A.E., H.E. Ahles and G.R. Bell. 1968. Manual of the Vascular Flora of the Carolinas.
The University of North Carolina Press, Chapel Hill, North Carolina.
Robbins, C.S., B. Bruun and H.S. Zim. 1966. A Guide to Field Identification of Birds of North
America. Western Publishing, Racine, Wisconsin.
Schafale, M.P. and A.S. Weakley. 1990. Classification of the Natural Communities of North
Carolina Third Approximation. North Carolina Natural Heritage Program, Raleigh, North
Carolina.
Sutton, A. and M. Sutton. 1985. Eastern Forests. Alfred Knopf Publishing, New York, New
York.
15
United States Department of Agriculture, Soil Conservation Service. 1975 Soil Survey of
Catawba County, North Carolina.
United States Fish and Wildlife Service. 1992 (updated 1996). Endangered and Threatened
Species of the Southeastern United States (The Red Book). United States Fish and Wildlife
Service Southeastern Region, Atlanta, Georgia.
United State Fish and Wildlife Service. August 23, 1996. List of Threatened and Endangered
Species.
United States Fish and Wildlife Service National Wetlands Inventory Map of Hickory. 1994.
United States Geological Survey Topographic map of Hickory quadrangle. 1970.
Whitaker, J.O., Jr. 1980. The Audubon Society Field Guide to North American Mammals.
Alfred Knopf Publishing, New York, New York.
16
Z ,??
D
O
m
U
w
F-
D
O
DC
O
O
w
0
F-
U)
o.
0
o0
c
0
^ L
LYi
O
co
E
F- v oC W O
o m w CO W
U
N ZD LO
Y?
c Cr q CV
cd E p_UON
aai ? ??Urb CV
mw< -
=W OD?z
c=-0 Z?da
.O? ? wrU r
0 g
U c r W cl)
'y .c g z r
if - o.> a0
Z 4. w
Ul)
0
L
U
C C
_o v
-F- m
v
o m
vai E
`oo
C p P li
2 p
p C 4,.. C
U E p,
?CpC
+-vcn? Cl- .{ p a).?: 0
znoa
N
OO
W w
CO W
L7
z Y >-
?I-O ?
Wazv 4-
0JOa7 N
O N E
Um O
L.L m > pap O
O O ?::z
LO a CL
H H-
zsea?-
W - U
V I O
a
J z
Q- O
W
w
O
CATAWBA COUNTY
BRIDGE NO. 82
B-2940
LOOKING EAST
LOOKING WEST
LOOKING SOUTH
FIGURE 3
SCALE 1:12000
0 500 1000
meters
j Fl(
4
. STArf
^`fn
North Carolina Department of Cultural Resources
James B. Hunt Jr., Governor
Betty Ray McCain, Secretary
April 4, 1996
MEMORANDUM
TO: H. Franklin Vick, P.E., Manager
Planning and Environmental Branch
Division of Highways
Department of Trans rtation
FROM: David Brook
Deputy State ?j
Historic Preservation Officer
SUBJECT: Group IX Bridge Replacement Projects
Bridge 82 on SR 1 165 over Clark Creek, B-2940,
Catawba County, ER 96-8518
Division of Archives and History
Jeffrey J. Crow, Director
El?
APR 1 1 1996
DIVISIGN OF
HIGHW?;YS
Thank you for your letter of March 11, 1996, concerning the above project.
We are aware of no structures of historic or architectural importance within the
general area of the project.
We recommend that an architectural historian on your staff identify and evaluate
any structures over fifty years of age within the project area, and report the
findings to us.
There are no known archaeological sites within the proposed project area. Based
on our present knowledge of the area, it is unlikely that any archaeological
resources which may be eligible for inclusion in the National Register of Historic
Places will be affected by the project construction. We, therefore, recommend that
no archaeological investigation be conducted in connection with this project.
The above comments are made pursuant to Section 106 of the National Historic
Preservation Act and the Advisory Council on Historic Preservation's Regulations
for Compliance with Section 106 codified at 36 CFR Part 800.
Thank you for your cooperation and consideration. If you have questions
concerning the above comment, please contact Renee Gledhill-Earley, environmental
review coordinator, at 919/733-4763.
DB:slw
cc: N. Graf
B. Church
T. Padgett
109 East Jones Street • Raleigh, North Carolina 27601-2807 g??
Federal Aid # I'27- - I14'45 (ri TIP # 6'- VI4-0 County G?Ti?JF'?A
CONCURRENCE FORM FOR PROPERTIES NOT ELIGIBLE FOR
THE NATIONAL REGISTER OF HISTORIC PLACES
Brief Project Description VWLA4,E e*404t: QV- 10-L 614 eL. RGC7 adt;,g- C4#41t - cper e-
( FiW04rc G72eur tX
On AML. ?t x'11(. , representatives of the
? North Carolina Department of Transportation (NCDOT)
Federal Highway Administration (FHwA)
? North Carolina State Historic Preservation Office (SHPO)
Other
reviewed the subject project at
All parties present agreed
? there arc no properties over fifty years old within the project's area of potential cffccts.
? there are no properties less than fifty years old which are considered to meet Criterion
Consideration G within the project's area of potential cffccts.
there are properties over fifty years old (list attached) within the project's area of potential effects,
but based on the historical information available and the photographs of each property, properties
identified as arc considered not eligible.
for National Register and no further evaluation of them is necessary.
? there are no National Register-listed properties within the project's area of potential effects.
Signed:
ef "l
Repress
4/11/%
Date
C
FHwA, for the Division Administrator, or other Federal Agency
4111Ig0
Representative, SIVO 'Date
r?
State Historic Preservation Officer atc
A scoping meeting
Historic architectural resources photograph review session/consultation
Other
If a survey report is prepared, a final copy of this form and die attached list will be included.
APR 1 5 1996
i
Z? DIVISIC
V op
HIGHtj,4
North Carolina Wildlife Resources Commission
512 N. Salisbury Street, Raleigh, North Carolina 27604-1188, 919-733-3391
Charles R. Fullwood, Executive Director
MEMORANDUM
TO: H. Franklin Vick, P.E., Manager
Planning and Environmental Branch, NCDOT
FROM: Stephanie E. Goudreau, Mt. Region Coordinator
Habitat Conservation Program
DATE: April 10, 1996
SUBJECT: Comments on Group IX Bridge Replacements, Alleghany, Cleveland, McDowell,
Buncombe, and Catawba Counties.
This correspondence responds to a request by you for our review and comments regarding eleven
proposed bridge replacements in western North Carolina. Biological field staff of the North Carolina
Wildlife Resources Commission (WRC) have reviewed the information in your letter dated 11 March 1996
and have examined our records fish sampling data.
Our comments on these projects are listed below. All species and common names follow
"Common and Scientific Names of Fishes from the United States and Canada" by Robins et al. 1991
(American Fisheries Society Special Publication 20). Species listed in bold print are considered to be
intolerant to stream degradation under the North Carolina Index of Biotic Integrity used by the North
Carolina Division of Environmental Management to assess the biological integrity of streams.
B-2803 - Alleghany County, Bridge No. 52 over Little River, Bridge No. 56 over Pine Swamp Creek
Both the Little River and Pine Swamp Creek are designated Hatchery Supported Public Mountain
Trout Waters (PMTW) in the project area. We recently provided you with a memorandum dated
12 July 1995 with our scoping comments on this project (see attached).
B-2815 - Cleveland County, Bridge No. 35 on SR 1001 over Persimmon Creek
No fish data are available for Persimmon Creek, nor have we identified any special concerns
associated with this project.
B-2816 - Cleveland County, Bridge No. 230 on SR 1908 over Buffalo Creek
We have not identified any special concerns associated with this project. According to WRC
district files, the following fish species were collected in Buffalo Creek in 1980:
Group IX Page 2 April 10, 1996
Common Name
rosyside dace
bluehead chub
greenfin shiner
spottail shiner
yellowfin shiner
swallowtail shiner
sandbar shiner
creek chub
striped jumprock
redbreast sunfish
bluegill
Scientific Name
Canostomus funduloides
Nocomis leptocephalus
Cyprinella chloristius
Notropis hudsonius
Notropis lutipinnis
Notropis procne
Notropis scepticus
Semotilus atromaculatus
Moxostoma rupiscartes
Lepomis auritus
Lepomis macrochirus
Other species collected by Messer et al. of the WRC in 1964:
gizzard shad Dorosoma cepe&anum
rainbow trout Oncorhynchus mykiss
fieryblack shiner Cyprinella pyrrhomelas
highback chub Notropis hypsinotus
white sucker Catostomus commersoni
redhorse Moxostoma sp.
bullhead Ameiurus sp.
pumpkinseed Lepomis gibbosus
warmouth Lepomis gulosus
largemouth bass Micropterus salmoides
B-2847 - McDowell County, Bridge No. 65 on SR 1760 over Muddy Creek
We have not identified any special concerns associated with this project. No fish sampling
data is available for Muddy Creek, but we would expect the species assemblage to be
similar to that of South Muddy Creek (see B-3002 below).
B-2931 - Buncombe County, Bridge No. 512 on SR 2435 over Swannanoa River
The Swannanoa River is designated Hatchery Supported PMTW at the project site. The
river also supports some wild trout. We would prefer that the existing bridge be replaced
with another spanning structure.
B-2940 - Catawba County, Bridge No. 82 on SR 1165 over Clark Creek
We have not identified any special concerns associated with this project. Schneider of the
North Carolina Division of Environmental Management (DEM) collected the following
fish species in Clark Creek in 1993:
Common Name Scientific Name
bluehead chub Nocomis leptocephalus
white sucker Catostomus commersoni
flat bullhead Ameiurus platycephalus
Group IX
redbreast sunfish
pumpkinseed
bluegill
largemouth bass
B-2941 - Catawba Cou
Page 3 April 10, 1996
Lepomis auritus
Lepomis gibbosus
L Momis macrochirus
Micropterus salmoides
nty, Bridge No. 94 on SR 1722 over McLin Creek
We have not identified any special concerns associated with this project. Menhinick of the
University of North Carolina at Charlotte collected the following species in 1991:
Common Name
common carp
rosyside dace
bluehead chub
greenhead shiner
creek chub
white sucker
Scientific Name
Cyprinus carpio
Canostomus funduloides
Nocomis leptocephalus
Notropis chlorocephalus
Semotilus atromaculatus
Catostomus commersoni
silver (v-lip) redhorse Moxostoma anisurum
striped jumprock Moxostoma rupiscartes
channel catfish Ictalurus punctatus
redbreast sunfish Lepomis auritus
bluegill LMomis macrochirus
fantail darter Etheostoma flabellare
tessellated darter Etheostoma olmstedi
B-2998 - McDowell County, Bridge No. 41 on SR 1147 over Second Broad River
We have not identified any special concerns associated with this project. Schneider of the
DEM collected the following fish species in the Second Broad River in 1988:
Common Name Scientific Name
fieryblack shiner Cyprinella pyrrhomelas
Santee chub
bluehead chub
highback chub
greenfin shiner
yellowfin shiner
creek chub
white sucker
striped jumprock
silver (v-lip) redhe
flat bullhead
margined madtom
rock bass
redbreast sunfish
fantail darter
Cyprinella unnema
Nocomis leptocephalus
Notropis hypsinotus
Cyprinella chlorisdus
Notropis lutipinnis
Semotilus atromaculatus
Catostomus commersoni
Moxostoma rupiscartes
rse Moxostoma anisurum
Ameiurus platycephalus
Noturus insignis
Ambloplites rupestris
Lepomis auritus
Etheostomaflabellare
Group IX Page 4 April 10, 1996
B-2999 - McDowell County, Bridge No. 317 on SR 1267 over Cove Creek
We have not identified any special concerns associated with this project. The following
fish data were collected by Messer et al. of the WRC in 1964:
Common Name
thicklip chub
fieryblack shiner
bluehead chub
yellowfin shiner
creek chub
redhorse
margined madtom
redbreast sunfish
Scientific Name
Cyprinella labrosa
Cyprinella pyrrhomelas
Nocomis leptocephalus
Notropis lutipinnis
Semodlus atromaculatus
Moxostoma sp.
Noturus insignis
Lepomis auritus
bluegill Lepomis macrochirus
smallmouth bass Micropterus dolomieu
largemouth bass Micropterus salmoides
Piedmont darter Percina crassa
seagreen darter Etheostoma thalassinum
B-3002 - McDowell County, Bridge No. 60 on SR 1764 over South Muddy Creek
We have not identified any special concerns associated with this project. Schneider of the
DEM collected the following fish species in South Muddy Creek in 1993:
ommon Name Scientific Name
rosyside dace Chnostomus funduloides
bluehead chub Nocomis leptocephalus
greenhead shiner Notropis chlorocephalus
striped jumprock Moxostoma rupiscartes
margined madtom Noturus insignis
redbreast sunfish Lepomis auritus
bluegill Lepomis macrochirus
fantail darter Etheostoma flabellare
tessellated darter Etheostoma olmstedi
Piedmont darter Percina crassa
Other species collected by Louder (1963) include:
central stoneroller Campostoma anomalum
creek chub Semotilus atromaculatus
yellow perch Perca flavescens
B-3140 - Cleveland County, Bridge No. 13 on NC 198 over Buffalo Creek
We have not identified any special concerns associated with this project. Fish sampling
data for Buffalo Creek are listed above under B-2816.
Group IX Page 5 April 10, 1996
Although we do not have any special concerns regarding several of these bridge
replacements, we recommend that the NCDOT incorporate the following measures into all bridge
replacement projects to minimize impacts to aquatic organisms:
1) Erosion controls should be installed where soil is disturbed and maintained until project
completion.
2) If concrete will be used, work must be accomplished so that wet concrete does not contact
stream water. This will lessen the chance of altering water chemistry and causing a fish
kill.
3) 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.
4) Multi-celled reinforced concrete box culverts should be designed so that all water flows
through a single cell (or two if necessary) during low flow conditions. This could be
accomplished by constructing a low sill on the upstream end of the other cells that will
divert low flows to another cell. This will facilitate fish passage at low flows.
5) Temporary or permanent herbaceous vegetation should be planted on all bare soil within
15 days of ground disturbing activities to provide long-term erosion control.
Thank you for the opportunity to review and comment during the early stages of these projects. If
you have any questions regarding these comments, please contact me at 704/652-4257.
cc: Ms. Katie Cirilis, Resource Southeast
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Asheville Field Office
160 Zillicoa Street
Asheville, North Carolina 28801
March 26, 1996
Mr. H. Franklin Vick, P.E., Manager
Planning and Environmental Branch
North Carolina Department of Transportation
P.O. Box 25201
Raleigh, North Carolina 27611-5201
Dear Mr. Vick:
?GEI V?
n G
1,196
Subject: Proposed replacement of several bridges in Alleghany, Buncombe,
Catawba. Cleveland, and McDowell Counties, North Carolina
A copy of your letter of March 11, 1996, to the U.S. Fish and Wildlife
Service's (Service) Raleigh Field Office was forwarded to our office (we
received it on March 18. 1996). Our office handles project reviews and
requests of this nature for the western part of the state, including the
above-mentioned counties. The following comments are provided in
accordance with the provisions of the Fish and Wildlife Coordination Act,
as amended (16 U.S.C. 661-667e), and Section 7 of the Endangered Species
Act of 1973, as amended (16 U.S.C. 1531-1543) (Act).
According to the information provided in your letter, the following
bridges will be replaced: Bridge Numbers 52 and 56 on SR 1172 over the
Little River (Alleghany County): Bridge Number 512 on SR 2435 over the
Swannanoa River (Buncombe County): Bridge Number 82 on SR 1165 over Clark
Creek (Catawba County): Bridge Number 94 on SR 1722 over McLin Creek
(Catawba County); Bridge Number 35 on SR 1001 over Persimmon Creek
(Cleveland County): Bridge Number 230 on SR 1908 over Buffalo Creek
(Cleveland County); Bridge Number 13 on NC 198 over Buffalo Creek
(Cleveland County); Bridge Number 65 on SR 1760 over Muddy Creek
(McDowell County); Bridge Number 41 on SR 1147 over the Second Broad
River (McDowell County); Bridge Number 317 on SR 1267 over Cove Creek:
and Bridge Number 60 on SR 1764 over South Muddy Creek.
The Service is particularly concerned about: (1) the potential impacts
the proposed bridge replacement projects could have on federally listed
species and on Federal species of concern and (2) the potential impacts
to stream and wetland ecosystems within the project areas.
We have reviewed our files and believe the environmental document should
evaluate possible impacts to the following federally listed species
and/or Federal species of concern (these include aquatic animal species
2
known from a particular stream system for one of the proposed bridge
projects and plant species that may occur along the banks of
streams/rivers):
Alleghany County
Hellbender (Crvptobranchus alleganiensis) - Federal species of concern.
This species generally is found beneath large flat stones or logs in
shallow clear-running streams and rivers. It is presently known
from at least one location in the Little River, 7 miles east of
Sparta.
Kanawha minnow (Phenocobius teretulus) - Federal species of concern.
This species is endemic to large clear streams within the New River
drainage of North Carolina, Virginia, and West Virginia. It is
presently known from at least one location in the Little River,
0.5 mile downstream of the NC 18 bridge.
Buncombe County
Hellbender (Crvptobranchus alleganiensis) - Federal species of concern.
There is a record of this species in the Swannanoa River near Black
Mountain.
Spotfin chub (Hybopsis monacha) - Federally threatened. A species
endemic to the Tennessee River drainage. The Little Tennessee River
presently supports the only extant population in North Carolina;
however, there is a historical record from the Swannanoa River in
Asheville.
Appalachian elktoe (Alasmidonta raveneliana) - Federally endangered.
This species is endemic to the upper Tennessee River. It generally
occurs in the riffle areas of large rivers that have cobble and
gravel substrates. There are only a few extant populations left in
the Little Tennessee River. Toe River, Cane River, and Nolichucky
River systems. There is a historical record from the Swannanoa
River.
French Broad crayfish (Cambarus reburrus) - Federal species of concern.
This species is endemic to North Carolina and is known from the
headwater portions of the French Broad River and one stream in the
Savannah River drainage. It was once found in the Swannanoa River
near Black Mountain.
French Broad heartleaf (Hexastvlis rhombiformis) - Federal species of
concern. This species is generally found in association with other
acidophiles, such as ericaceacous shrubs, hemlock, rhododendron, and
mountain Laurel.
3
Butternut (Juglans cinerea) - Federal species of concern. This species
is generally found in cove forests and rich woods, including
floodplain forests.
Sweet pinesap (Monotropsis odorata) - Federal species of concern. This
species is generally found in dry forests and on river bluffs.
Virginia spiraea (Spiraea virginiana) - Federally threatened. This
species occurs within the scour zone on the banks of high-gradient
streams or on braided features such as point bars, natural levees,
or meander scrolls of the lower reaches of streams. It may occur
within the floodplain, but it is most often found at the water's
edge. There is a historical record of this species along Hominy
Creek near Asheville.
Catawba County
Dwarf-flowered heartleaf (Hexastvlis naniflora) - Federally threatened.
This species has been found along several creeks in the county,
including Brushy Creek, Sandy Run, and Poundingmill Creek.
Cleveland County
Dwarf-flowered heartleaf (Hexastvlis naniflora) - Federally threatened.
This species has been found along several tributaries to the Henry
Fork River.
McDowell County
Bennett's Mill Cave water slater (Caecidotea carolinensis) - Federal
species of concern. This species is presently known from one
locality in North Carolina at a cave located on the banks of Muddy
Creek east of Marion.
Butternut (Juglans cinerea) - Federal species of concern. This species
is generally found in cove forests and rich woods, including
floodplain forests.
Sweet pinesap (Monotropsis odorata) - Federal species of concern. This
species is generally found in dry forests and on river bluffs.
There is one known population located along the banks of South Muddy
Creek in the headwaters area.
Northern oconee-bells (Shortia galacifolia var. brevistyla) - Federal
species of concern. This species grows in various habitats, from
rocks near water falls, in sand at the edge of running water, in
shady deep moist loam soils, and on dry hillsides. It favors cool,
damp, shady stream banks with fertile, moderately acid, soils.
4
The presence or absence of the above-mentioned species in the project
impact areas should be addressed in any environmental document prepared
for these projects. Please note that the legal responsibilities of a
Federal agency or their designated non-Federal representative with regard
to federally listed endangered and threatened species under Section 7 of
the Act are on file with the Federal Highway Administration. Also,
please note that Federal species of concern are not legally protected
under the Act and are not subject to any of its provisions, including
Section 7, unless they are formally proposed or listed as endangered or
threatened. We are including these species in our response in order to
give you advance notification and to request your assistance in
protecting them.
Additionally, the Service believes the environmental document(s) for the
proposed projects should address the following issues: (1) an evaluation
of the various bridge replacement alternatives and structures (e.g.,
replacement at the existing location versus upstream or downstream of the
existing structure), (2) any special measures proposed to minimize
sedimentation during construction; and (3) any measures that will be
implemented to minimize impacts to fish and wildlife habitat (e.g.,
protecting riparian vegetation whenever possible).
We appreciate the opportunity to provide these scoping comments and
request that you keep us informed of the progress of these projects. In
any future correspondence concerning this project, please reference our
Log Number 4-2-96-057.
Sin e ely,
Brian P. Cole
Field Supervisor
State of North Carolina
Department of Environment,
Health and Natural Resources 200?ff? •
Division of Environmental Management
? C
James B, Hunt, Jr., Governor
Jonathan B, Howes, Secretary
C
A, Preston Howard, Jr., P.E„ Director
April 19, 1996
MEMORANDUM
To: Jim Buck
From: Eric Galamb4
Subject: Water Quality Checklist for Group IX Bridge Replacement Projects
The Water Quality Section of the Division of Environmental Management requests that
DOT consider the following generic environmental commitments for bridge
replacements:
A. DEM requests that DOT strictly adhere to North Carolina regulations entitled,
"Design Standards in Sensitive Watersheds" (15A NCAC 04B .0024) throughout
design and construction for this project in the area that drains to streams having
WS (water supply), ORW (outstanding resource water), HQW (high quality
water), B (body contact), SA (shellfish water) or Tr (trout water) classifications
to protect existing uses.
B. DEM requests that bridges be replaced in existing location with road closure. If
an on-site detour or road realignment is necessary, the approach fills should be
removed to pre-construction contour and revegetated with native tree species at
320 stems per acre.
C. DEM requests that weep holes not be installed in the replacement bridges in
order to prevent sediment and other pollutants from entering the body of water.
If this is not completely possible, weep holes should not be installed directly
over water.
D. Wetland impacts should be avoided (including sediment and erosion control
structures/measures). If this is not possible, alternatives that minimize wetland
impacts should be chosen. Mitigation for unavoidable impacts may be required.
E. Borrow/waste areas should avoid wetlands. It is likely that compensatory
mitigation will be required if wetlands are impacted by waste or borrow.
Please be aware that 401 Certification may be denied if wetland or water impacts
have not been avoided and minimized to the maximum extent practicable.
cc: Monica Swihart
Melba McGee
bridges.sco
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-7015 FAX 919-733-2496
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
C??li?2 0
P.0 Box 1000 • Newton, North Carolina 28658. 704-464-8333
C E
`l
March 15, 1996
Mr. H. Franklin Vick, P. E., Manager
Planninq and Environmental Branch
Division of Highways
Department of Transportation
PO Box 25201
Raleigh, NC 27611-5201
1946
GHW
Dear Mr. Vick:
In reference to Bridges Nos. 82 and 94 on SR 1165 and 1722 for bus travel.
We have three buses crossing bridge no. 82 which will cause very little
mileage increase by detouring. Bridge no. 94 over Mclin Creek will cause
me an increase in mileage. The five buses will add 96 miles per day. The
large number of students at Catawba that we transport to Claremont is my
problem.
Sincerely,
Tony Eaglle
Tran8portation Director
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
P.O. BOX 1890
WILMINGTON, NORTH CAROLINA 28402-1890
REPLY TO
ATTENTION OF May 14, 1996
Special Studies and
Flood Plain Services Section
CE%
Mr. H. Franklin Vick, P.E., Manager
Planning and Environmental Branch
North Carolina Division of Highways
Post Office Box 25201
Raleigh, North Carolina 27611-5201
Dear Mr. Vick:
MA Y 1 7 1996
??
k DrVISIC
RnA,. A=V A a
H/GH
WA YS
i
11
This is in response to your letter of March 11, 1996 subject: "Request for
Comments for Group IX Bridge Replace Projects." The bridge replacement projects are
located in various Western North Carolina counties.
Our comments are enclosed. We appreciate the opportunity to comment on these
projects. If we can be of further assistance, please contact us.
Sincerely,
E. Shuford, Jr., P.E.
Acting Chief, Engineering
and Planning Division
Enclosure
Copies Furnished (with enclosure
and incoming correspondence):
Mr. Nicholas L. Graf
Federal Highway Administration
310 New Bern Avenue, Suite 410
Raleigh, North Carolina 27601-1442
Mr. David Cox
North Carolina Wildlife Resources Commission
Post Office Box 118
Northside, North Carolina 27564-0118
-2-
Copies Furnished (with enclosure
and incoming correspondence): continued
Ms. Barbara Miller
Chief, Flood Risk Reduction
Tennessee Valley Authority
400 West Summit Hill Drive
Knoxville, Tennessee 37902-1499
Mr. Jamie James (CEORN-EP-H-M)
U.S. Army Engineer District, Nashville
Post Office Box 1070
Nashville, Tennessee 37202-1070
Mr. Larry Workman (CEORH-PD-S)
U.S. Army Engineer District, Huntington
502 Eighth Street
Huntington, Vilest Virginia 25701-2070
May 13, 1996
Page 1 of 4
U.S. ARMY CORPS OF ENGINEERS, WILMINGTON DISTRICT, COMMENTS ON:
"Request for Comments for Group IX Bridge Replace Projects" in various Western
North Carolina counties
1. FLOOD PLAINS: POC - Bobby L. Willis, Special Studies and Flood Plain
Services Section, at (910) 251-4728
All of the bridges, except for Alleghany and Buncombe Counties, are within the
planning jurisdiction of the U.S. Army Corps of Engineers (USACE), Wilmington
District. With the exception of Allegheny and Cleveland Counties, these bridges are
located within counties which participate in the National Flood Insurance Program
(NFIP). Allegheny County has flood hazard areas identified on Flood Hazard Boundary
Maps, but has not had detailed mapping done and does not participate in the program.
Cleveland County has mapping done on Flood Insurance Rate Maps (FIRMs) in
anticipation of future participation in the NFIP, but does not currently participate in the
program. From the various FIRMs, it appears that both approximate study and detail
study streams are involved. (Detail study streams are those with 100-year flood
elevations determined and a floodway defined.) A summary of flood plain information
pertaining to these bridges is contained in the following table. The FIRMs are from the
county flood insurance study unless otherwise noted.
Bridge Route Study Date Of
No. No. County Stream Type Firm
52/56 SR 1172 Alleghany Little River Approx 7/77
35 SR 1001 Cleveland Persimmon Ck.** Detail 7/91 **"
230 SR 1908 Cleveland Buffalo Ck. Approx 7/91 ***
65 SR 1760 McDowell N. Muddy Ck. Approx 7/88
512 SR 2435 Buncombe Swannanoa R. Detail 8/80
82 SR 1165 Catawba Clarks Ck. Detail 8/94
94 SR 1722 Catawba McLin Ck. Detail 9/80
41 SR 1147 McDowell Second Broad R. Approx 7/88
317 SR 1267 McDowell Cove Ck. Approx 7/88
60 SR 1764 McDowell S. Muddy Ck. Approx 7/88
13 NC 198 Cleveland Buffalo Ck. Detail 7/91 ***
* County is not a participant in NFIP. Map is a Flood Hazard Boundary Map.
Stream is shown as Muddy Fork on the FIRM.
*** County is not a participant in NFIP.
May 13, 1996
Page 2 of 4
U.S. ARMY CORPS OF ENGINEERS, WILMINGTON DISTRICT, COMMENTS ON:
"Request for Comments for Group X Bridge Replace Projects" in various Western
North Carolina counties
1. FLOOD PLAINS: (Continued)
Enclosed, for your information on the detail study streams, is a copy of the Federal
Emergency Management Agency's "Procedures for 'No Rise' Certification for Proposed
Developments in Regulatory Floodways". In addition, we suggest coordination with the
respective counties or communities for compliance with their flood plain ordinances and
any changes, if required, to their flood insurance maps and reports.
Buncombe County is within the planning jurisdiction of the USACE, Nashville
District, and the Tennessee Valley Authority (TVA) with respect to any construction or
development involving the flood plains. The Nashville District does not currently have
projects that would be affected by this proposed project. Mr. Jamie James may be
contacted at (615) 736-5948 for further information and comments from the Nashville
District. Flood plain concerns are normally addressed within the TVA Section 26a
permitting process. A 26a permit is required for all constnaction or development
involving streams or flood plains in the Tennessee River drainage basin. Mr. Roger
Milstead at (615) 632-6115 should be contacted for information on the TVA 26a
permitting process. The project should be designed to meet the requirements of the
National Flood Insurance Program (NFIP), administered by the Federal Emergency
Management Agency (FEMA), and be in compliance with all local ordinances. The
engineering point of contact for the NFIP in this FEMA region is Ms. Bel Marquez, who
may be reached at (404) 853-4436. Specific questions pertaining to community flood
plain regulations or developments should be referred to the local building official.
Alleghany County is within the planning jurisdiction of the USACE,
Huntington District. The Huntington District does not currently have projects that would
be affected by the proposed project. Mr. Larry Workman may be contacted at
(304) 529-5644 for further information and comments from the Huntington District.
2. WATERS AND WETLANDS: POC - Raleigh and Asheville Field Offices,
Regulatory Branch (Individual POC's are listed following the comments.)
All work restricted to existing high ground will not require prior Federal permit
authorization. However, Department of the Army permit authorization pursuant to
Section 404 of the Clean Water Act of 1977, as amended, will be required for the
discharge of excavated or fill material in waters of the United States or any adjacent
and/or isolated wetlands in conjunction with your proposed bridge replacements,
including disposal of construction debris.
May 13, 1996
Page 3 of 4
U.S. ARMY CORPS OF ENGINEERS, WILMINGTON DISTRICT, COMMENTS ON:
"Request for Comments for Group IX Bridge Replace Projects" in various Western
North Carolina counties
2. WATERS AND WETLANDS: (Continued)
The replacement of these bridges may be eligible for nationwide permit
authorization [33 CFR 330.5(a)(23)] as a Categorical Exclusion, depending upon the
amount of jurisdictional wetlands to be impacted by a project and the construction
techniques utilized. Please be reminded that prior to utilization of nationwide permits
within any of the 25 designated mountain trout counties, you must obtain a letter with
recommendation(s) from the North Carolina Wildlife Resources Commission and a
letter of concurrence from the U.S. Army Corps of Engineers, Wilmington District
Engineer. The mountain trout designation carries discretionary authority for the
utilization of nationwide permits. In addition, any jurisdictional impacts associated with
temporary access roads or detours, cofferdams, or other dewatering structures should
be addressed in the Categorical Exclusion documentation in order to be authorized by
Nationwide Permit No. 23 (NWP 23). If such information is not contained within the
Categorical Exclusion documentation, then other DA permits may be required prior to
construction activities.
Although these projects may qualify for NWP 23 as a categorical exclusion, the
project planning report should contain sufficient information to document that the
proposed activity does not have more than a minimal individual or cumulative impact on
the aquatic environment. Accordingly, we offer the following comments and
recommendations to be addressed in the planning report:
a. The report should contain the amount of permanent and temporary impacts to
waters and wetlands as well as a description of the type of habitat that will be affected.
b. Off-site detours are always preferable to on-site (temporary) detours in
wetlands. If an on-site detour is the recommended action, justification should be
provided.
c. Project commitments should include the removal of all temporary fills from
waters and wetlands. In addition, if undercutting is necessary for temporary detours,
the undercut material should be stockpiled to be used to restore the site.
d. The report should address impacts to recreational navigation (if any) if a bridge
span will be replaced with a box culvert.
e. The report should address potential impacts to anadromous fish passage if a
bridge span will be replaced with culverts.
May 13, 1996
Page 4 of 4
U.S. ARMY CORPS OF ENGINEERS. WILMINGTON DISTRICT. COMMENTS ON:
"Request for Comments for Group IX Bridge Replace Projects" in various Western
North Carolina counties
2. WATERS AND WETLANDS: (Continued)
At this point in time, construction plans were not available for review. When final
plans are complete, including the extent and location of any work within waters of the
United States and wetlands, our Regulatory Branch would appreciate the opportunity to
review those plans for a project-specific determination of DA permit requirements.
For additional information, please contact the following individuals:
Raleigh Field Office -
John Thomas at (919) 876-8441, Extension 25, for Alleghany County
Asheville Field Office -
Steve Lund at (704) 271-4857 for Buncombe County
Steve Chapin at (704) 271-4014 for Cleveland, McDowell, and Catawba
Counties
???G?NGY M^N1cF3
O 2
a
R-4
Federal Emergency Management Agency
Region IV
1371 Peachtree Street, NE, Suite 700
Atlanta, GA 30309
LM
FOR "NO-RISE" CERTIFICA
Section 60.3 (d) (3)\ of the National Flood Insurance Program (NFIP)
regulations states that a community-shall "prohibit encroachments,
including fill, new construction, substantial improvements, and
other development within the adopted regulatory floodway unless it
has been demonstrated-through hydrologic and hydraulic analyses
performed in accordance with standard engineering practice that the
proposed encroachment would not result in any increase in flood
levels within the community during the occurrence of the base (100-
year) flood discharge."
Prior to issuing any building grading or, development permits
involving activities in a regulatory floodway, the community must
obtain a certification stating the proposed development will not
impact the pre-project base flood elevations, floodway elevations,
or floodway data widths. The certification should be obtained from
the permittee and be signed and sealed by a professional engineer.
The engineering or "no-rise" certification must be supported by
technical data. The supporting technical data should be based upon
the standard step-backwater computer model utilized to develop the
100-year floodway shown on. the community's effective Flood
Insurance Rate Map or Flood Boundary and Floodway Map (FBFM) and
the results tabulated in the community's Flood Insurance Study
(FIS).
Although communities are required to review and approve the "no-
rise" submittals, they may request technical assistance and review
from the FEMA regional office. However, if this alternative is
chosen, the community must review the technical submittal package
and verify that all supporting data, listed in the following
paragraphs, are included in the package before forwarding to FEMA.
-2-
To support a "no-rise" certification for proposed developments
encroaching into the regulatory floodway, a community will require
that the following procedures be followed:
Currently Effective Model
1. Furnish a written request for the step-
backwater computer model for the specified
stream and community, identifying the limits
of the requested data. A fee will be assessed
for providing the data. Send data requests
to:
Federal Emergency Management Agency
1371 Peachtree Street N.E., Suite 735
Atlanta, Georgia 30309
or to:
FIS Information Specialist
Dewberry & Davis
8401 Arlington Boulevard -
Fairfax, Virginia 22031-4666
Duplicate Effective Model
2. Upon receipt of the step-backwater computer
model, the engineer should run the original
step-backwater model-to duplicate the data in
the effective FIS.
Existing Conditions Model
3. Revise the original step-backwater model to
reflect site specific existing conditions by
adding new cross-sections (two or more)-in the
vicinity of the proposed development, without
the proposed development in place. Floodway
limits should be manually. set at the new
cross-section locations by measuring from the
effective FIRM or FBFM. The cumulative reach
lengths of the stream should also remain
unchanged. The results of these analyses will
indicate the 100-year floodway elevations for
revised existing conditions at the proposed
project site.
-3-
Proposed Conditions Model
4. Modify the revised existing conditions model
to reflect the proposed development at the new
cross-sections, while retaining the currently
adopted floodway widths. The overbank
roughness coefficients should remain the same
unless a reasonable explanation of how the
proposed development will impact Manning's "n"
values should be included with the supporting
data. The results of this floodway run will
indicate the 100-year floodway elevations for
proposed conditions at the project site.
These results must indicate NO impact on the
100-year flood elevations, floodway
elevations, or floodway widths shown in the
Duplicate`Effective Model or in the Existing
Conditions Model.
The original FIS model, the duplicate effective FIS model, the
revised existing conditions model, and the proposed conditions
model should all produce the same exact results.
The "no-rise" supporting data and 'a copy of the engineering
certification must be submitted to and reviewed by the appropriate
community official prior to issuing a permit:
The "no-rise" supporting data should include, but may not be
limited to:
a. Duplicate of the original PIS step-backwater model
printout or floppy disk.
b. ' Revised existing conditions.step-backwater model.
C. Proposed conditions step-backwater model.
d. FIRM and topographic map, showing floodplain and
floodway, the additional cross-sections, the
site location with the proposed topographic
modification superimposed onto the maps, and a
photocopy of the effective FIRM or FBFM showing the
current regulatory floodway.
e. Documentation clearly stating analysis procedures.
All modifications made to the original PIS model to
represent revised existing conditions, as well as
.
-4-
those made to the revised existing conditions model
to represent proposed conditions, should iwell
documented and submitted with all supporting data.
f. Copy of effective Floodway Data Table copied from
the FIS report.
g. Statement defining source of additional cross-
section topographic data and supporting information.
h. Cross-section plots, of the added cross sections,
for revised existing and proposed conditions.
i. Certified planimetric (boundary survey) information
indicating the location of structures on the
property.
j. Copy of the microfiche, or other applicable source,
from which input for original FIS HEC-2 model was
taken.
k. Floppy disk with all input files.
1. Printout of output files from EDIT runs for all
three floodway models.
The engineering "no-rise" certification and supporting technical
data must stipulate NO impact on the 100-year flood elevations,
floodway elevations, or floodway widths at the new cross-sections
and at all existing cross-sections anywhere in the model.
Therefore, the revised computer model should be run for a
sufficient distance (usually one mile, depending on hydraulic slope
of the stream) upstream and downstream of the development site to
insure proper "no-rise" certification.
Attached is a sample "no-rise" certification form that can be
completed by a registered professional engineer and supplied to the
community along with the supporting technical data when applying
for a development permit.
?F i??V'iT?'?iVC?? '?t"l .? ?+Y?i.?flCl!.y? iRN'?,/• ? fi :. 14?_ ???' .... - ..
T6/8
(ssasPPY)
: gx3S
(aTITS)
(asngvubTS)
(a?vQ)
•quawdoTanap posodoad agi
;p ATuToTn atM UT suoT4398-990so pausTTgndun 4v stnpTM APAPooT;
puv #suoTIvnaTa dvMPooT; 'suoT4v`naTa pooT; svad-OOT at;-4
IavdmT IOU TTTA, Puv
(A4TunwwoO ;o awvN)
PaIvP '
so; Apn';S aouvsnsul pooT3 at4 UT SUOT4389 Pat;sTTgnd qv
(mvaxIS ;o amvN) uo stPPTM AVMpooT;
puv SuoTgvnaTa dvMpooT; 'suoT4vnaTa poor; svad-OOT ate
(4usmdoTanaa ;o awvN)
govdmT '}ou TTTM
posodosd 4vu4 Iov; ate
sIsoddns vgvp TvoTtn;oa4 pat,;ovl4v atn lvgl A;TI.zao zat,;Isn; 04 ST II
;o 91VIS at;I UT aoTIovsd
04 pasuaoTT saauTbua paT;TTvnb ATnP Um I IvtP A;T4za3 04 ST sTtM
NOI VOIaLLE30 13SIH-ON.. ONIM33NION3
a