19970093 Ver 1_Scoping Comments_20080812

F wArF Michael F. Easley, Governor
Q R William G. Ross Jr., Secretary
A pG North Carolina Department of Environment and Natural Resources
fq r Coleen Sullins, Director
Division of Water Quality

August 12, 2008

MEMORANDUM

To: Mr. Marc Hamel, Rail Environmental Planning Engineer
NCDOT Rail Division, Environmental and Planning Branch
1553 Mail Service Center
Raleigh, NC. 27699-1553
From: David Wainwright, NC Division of Water Quality-F)

Subject: Scoping comments on the proposed rail connector to the Global TransPark near Kinston in
Lenoir County, State WBS No. 41739, TIP U-2928.

Reference your correspondence dated July 31, 2008 in which you requested comments for the referenced
project. "Preliminary analysis of the project reveals the potential for multiple impacts to perennial streams
and jurisdictional wetlands in the project area. More specifically, impacts to:
Stream Name River Basin Stream Classifications Stream Index Number
Ston on Creek Neuse C;Sw;NSW 27-81
Several UTs to Ston on Creek Neuse C;Sw;NSW 27-81
Brie Run Neuse C;Sw;NSW 27-81-1
Several UT to Briery Run Neuse C;Sw;NSW 27-81-1
Taylors Branch Neuse C;Sw;NSW 27-81-1-1
Two UTs to Taylors Branch Neuse C;Sw;NSW 27-81-1-1
Several UTs to the Neuse River Neuse C;NSW 27-(56)

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 any jurisdictional areas are identified, the
Division of Water Quality requests the NCDOT consider the following environmental issues for the
proposed project:
Project Specific Comments:

1. All creeks are at least 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 these
creeks. DWQ requests that the 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.

2. This project is within the Neuse River Basin. Riparian buffer impacts should be avoided and
minimized to the greatest extent possible pursuant to 15A NCAC 2B .0233.

Noe Carolin
Transportation Permitting Unit Naturally
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone: [phone] / FAX [phone] / Internet: htto://h2o.enr.state.nc.us/ncwetlands
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper

General Project Comments:

1. Any environmental documents should 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.
2. 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 should be designed to replace appropriate
lost functions and values. The NC Ecosystem Enhancement Program may be available for use as
wetland mitigation.

3. 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
NC Ecosystem Enhancement P ogramgma
funtilonn and values. required,
to replace appropriate to
be available for use as stream mitigation.
4. DWQ is very concerned with sediment and erosion impacts that could result from this project.
NC DOT should address these concerns by describing the potential impacts that may occur to the
aquatic environments and any mitigating factors that would reduce the impacts.
5. Bridge supports (bents) should not be placed in the stream when possible.
6. 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.
7. If concrete is used during construction, a dry work aWat r°hat inadvertentlydCOto prevent direct
ntacts uncured
contact between curing concrete and stream water.
concrete should not be discharged to surface waters due to the potential for elevated pH and
possible aquatic life and fish kills.
8. If temporary access roads or detours are constructed, the site should be graded to its
preconstruction contours and elevations. Disturbed areas should be seeded or mulched to
stabilize the soil and appropriate native woody species should be planted. When using temporary
structures the area should 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.

9. Placement of culverts and other structures in waters, streams, and wetlands should 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 should 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.
10. If multiple pipes or barrels are required, they should 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.
11. If foundation test borings are necessary; it should be noted in the document. Geotechnical work
is approved under General 401 Certification Number 3494/Nationwide Permit No. 6 for Survey
Activities.

12. 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.
13. All work in or adjacent to stream waters should be conducted in a dry work area unless otherwise
approved by NC DWQ. 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.

14. Sediment and erosion control measures should not be placed in wetlands and streams.

15. Borrow/waste areas should avoid wetlands to the maximum extent practical. Impacts to wetlands
in borrow/waste areas could precipitate compensatory mitigation.

16. 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.
17. 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.
This equipment should be inspected daily and maintained to prevent contamination of surface
waters from leaking fuels, lubricants, hydraulic fluids, or other toxic materials.

orplaced rucin the tures should bedprope many ner
laced in the active thalweg channel or
18. Riprap should not be P Bioengineering boulder
that precludes aquatic life passage
designed, sized and installed.
l
our input at this time. The DOT is reminded that issuance of a 401 Water
Thank you for requesting ro riate measures be instituted to ensure thaquestions r require
Ot degraded or lost. If you have an
Quality Certification requires that app P
dards are met and designated uses are not
Wainwright at [phone].
stan lease contact David
additional information, p
cc: William Wescott, US Army Corps of Engineers, Washington Field Office
ion Agency
Chris Wilson, NC Environmental
tCommission
e Resources
Travis Garcy Ward, DWQ Washington Regional Office
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