20160571_Scoping Comments_20101119

ALA
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor - Director
November 19, 2010
MEMORANDUM
To: Paul Koch, Stantec Consulting, 801 Jones Franklin Road, Suite 300
From: Amy Euliss, NC Division of Water Quality, Office
Dee Freeman
Secretary
Subject: Scoping comments on proposed extension of the Deep River Greenway in High Point, Guilford
County. Project No. EL-5104.
Reference your correspondence dated October 25, 2010 in which you requested comments for the
referenced project. Preliminary analysis of the project reveals the potential for multiple impacts to
streams and jurisdictional wetlands in the project area. More specifically, impacts to:
Stream Name River Basin Stream Stream Index 303(d) Listing
Classifications Number
Deep River and Cape Fear WSIV; CA* 17-(3.3) Yes; chlorophyll A
unnamed
tributaries
Further investigations at a higher resolution should be undertaken to verify the presence of other streams
and/or jurisdictional wetlands in the area. In the event that anyjurisdictional areas are identified, the
Division of Water Quality requests that Stantec Consulting and The City of High Point consider the
following environmental issues for the proposed project:
Project Specific Comments:
Deep River and its unnamed tributaries are class WSIV; CA; 303(d) waters of the State. Deep River
and its unnamed tributaries are on the 303(d) list for impaired use for aquatic life due to chlorophyll
A. NCDWQ is very concerned with sediment and erosion impacts that could result from this project.
NCDWQ recommends that the most protective sediment and erosion control BMPs be implemented
in accordance with Design Standards in Sensitive Watersheds to reduce the risk of nutrient runoff to
Deep River and its unnamed tributaries. NCDWQ requests that road design plans provide treatment
of the storm water runoff through best management practices as detailed in the most recent version
of NCDWQ's Stormwater Best Management Practices.
2. 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, NCDWQ requests that Stantec Consulting and The City of High Point 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.
North Carolina Division of Water Quality, Winston-Salem Regional Office
Location: 585 Waughtown St. Winston-Salem, North Carolina 27107
Phone: [phone] FAX: 336-77I A6301 Customer Service: 1-877-623-6748
Internet: w".nmaterquality.org
NorthCarolina
Natmallty .
An Equal Opportunity 1 Affirmative Action Employer
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3. This project is within Randleman Lake Basin. Riparian buffer impacts shall be avoided and
minimized to the greatest extent possible pursuant to 15A NCAC 213 .0259. Please reference the
"Greenway and Hiking Trails " buffer clarification memorandum on our website at:
http:I/portal.ncdenr.or<.,/c/document_library/get _file?uuid=7ec f c732-3dfb-42d5-9010-
Oc5658ae8217&groupld=38364
General Project Comments:
4. 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 2H.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.
5. After the selection of the preferred alternative and prior to an issuance of the 401 Water Quality
Certification, Stantee Consulting and The City of High Point 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 115A NCAC 214.0506(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.
6_ 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. 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.
7. NCDWQ is very concerned with sediment and erosion impacts that could result from this project.
Stantec Consulting and The City of High Point shall address these concerns by describing the
potential impacts that may occur to the aquatic environments and any mitigating factors that would
reduce the impacts.
8. 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.
9. 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 should 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.
10. Placement of culverts and other structures in waters, streams, and wetlands shall be 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 NCDWQ. If this condition is unable to be met due to bedrock

or other limiting features encountered during construction, please contact NCDWQ for guidance on
how to proceed and to determine whether or not a permit modification will be required.
11. 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, floodplain benches, and/or
sills may be required where appropriate. Widening the stream channel shall 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.
12. If foundation test borings are necessary; it should be noted in the document. Geotechnical work is
approved under General 401 Certification Number 3624/Nationwide Permit No. 6 for Survey
Activities.
13. 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 NCGO1000.
14. All work in or adjacent to stream waters shall be conducted in a dry work area unless otherwise
approved by NCDWQ. 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 should be used to prevent excavation in flowing water.
15. Sediment and erosion control measures shall not be placed in wetlands and streams.
16. Borrow/waste areas shall avoid wetlands to the maximum extent practical. Impacts to wetlands in
borrow/waste areas could precipitate compensatory mitigation.
17. 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.
18. 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.
19. 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 should be properly designed,
sized and installed.
Thank you for requesting our input at this time. Stantec Consulting and The City of High Point is
reminded that issuance of a 401 Water Quality Certification requires that appropriate measures be
instituted to ensure that water quality standards are met and designated uses are not degraded or lost. If
you have any questions or require additional information, please contact Amy Euliss at [phone].
cc: Andy Williams, US Army Corps of Engineers, Raleigh Field Office
Wetlands/40;L-P.ermitting:Unit::!,
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