20140341 Ver 1_Inspection_20140813

A
7*2
NCD _EN R
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
MEMORANDUM
To: Mr. Art King, Environmental Officer, NCDOT Division 8
From: David Wainwright, NCDWR, Central Office, Raleigh, NC X
John E. Skvarla, III
Secretary
August 13, 2014
Randolph County
NCDWR Project No. 20140341
Bridge No. 29 on SR 1105
State Project No. 17.BP.8.R.57
Subject: Site Visit, Replacement of Bridge No. 29 over Uwharrie River, Randolph County
On July 31, 2014 1 visited the Bridge No. 29 in Randolph County project site with you and Ms.
Liz Hair, United States Army Corps of Engineer. Upon inspection of the site, it was found that
some construction activities were out of compliance with several conditions included in the
associated 401 Water Quality Certification (WQC) (issued April 24, 2014; DWR No. 20140341).
Listed below are some of the conditions from the 401 WQC and how, at the time of the site
visit, they were found to be deficient:
Condition 7: Geotextile or other suitable fabric will be placed under the proposed causeway in order to
facilitate the removal of rock. The NCDOT and its contractors shall remove all rock placed for the causeway
upon completion of construction. All reasonable efforts shall be employed to retain the rock on the
geotextile fabric. Should rock get washed from the geotextile fabric, it shall be retrieved as soon as
practicable with minimal disturbance of the stream bottom.
It was observed that approximately the last four feet of the rock pad on the downstream side was
NOT placed on geotextile fabric and had been laid directly on the stream bottom. By not placing the
rock on geotextile fabric, the stream bottom will have to be disturbed in order to retrieve this rock.
This is undesirable as it has the potential to disturb the stream bottom, which can disturb aquatic life,
and can cause significant turbidity plumes which may place the project in violation of State water
quality standards. If the rock cannot be completely removed from the stream bed, or damage to the
stream bottom occurs as a result of trying to remove the rock, additional mitigation may be required
as this could result in a permanent impact to the stream.
Upon inspection of the rock used to construct the causeway, the NCDWR does not believe that the
rock used was appropriate. First, the rock is too small in overall size; it contained too much fine
material; and was not pre - washed. The size of the material used lends itself to be washed off the
geotextile fabric quite easily and also makes it difficult to retrieve from the stream should it become
dislodged from the causeway. The finer material and dust from not being pre- washed will easily wash
out, causing a turbidity plume. As discussed below, this has already happened, and may have caused
a water quality violation. Additionally, the dust and fine material can clog the gills of fish and smother
aquatic organisms when it settles out in the stream.
Transportation and Permitting Unit
1617 Mail Service Center, Raleigh, North Carolina 27699 -1617
Location: 512N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] \ FAX: [phone]
Internet: www.ncwateraualitv.ora
An Equal Opportunity \ Afiirmafive Action Employer
NorthCarolina
Naha'ally

More recent communication with NCDOT staff have revealed that much of the rock contained in the
causeway washed out during a recent storm event, in which approximately two- inches of rain fell.
Ideally, this dislodged rock should be removed by hand, not by mechanical means which can further
disturb the stream bottom. However, due to the quantity and small size of the material, removal by
hand may not be practicable. Rock and other materials located outside of permitted areas are
considered fill and may require mitigation.
• Please contact me so that we may discuss how to proceed with addressing the rock that
was dislodged from the geotextile material and is now located in the stream bed. I
understand that a large amount of precipitation has fallen in the area which has raised the
water level in the stream and may in turn make it difficult to remove the rock. If the rock
cannot be removed, additional mitigation may be required to offset the impact.
Condition 13: The Permittee shall ensure that the final design drawings adhere to the permit and to the
permit drawings submitted for approval.
It was observed during the site visit that the rock work pad was NOT built as shown in the approved
permit application plans, dated received April 8, 2014. The plans submitted for approval included a
minimum ten foot opening on the right bank of the river as to provide the public a way to navigate
the stream in the construction area. The opening was to be spanned with a moveable timber crane
mat, which would be moved when necessary and when construction activities were not taking
place. The work pad was not constructed in this manner; rather the intended opening was filled with
rock, thereby not allowing navigation through the construction area and blocking nearly the entire
stream width. No request for modification was received or approved by the NCDWR to allow the
proposed navigation way to be filled.
• If the causeway cannot be modified or rebuilt to the plans submitted in the initial
application, please apply for a modification. Since the causeway will need to be rebuilt as a
result of the recent precipitation and loss of rock it would be prudent to do so using a more
suitable pre- washed material.
Condition 19: The permittee and its authorized agents shall conduct its activities in a manner consistent with
State water quality standards (including any requirements resulting from compliance with §303(d) of the
Clean Water Act) and any other appropriate requirements of State and Federal law. If the NCDWR
determines that such standards or laws are not being met (including the failure to sustain a designated or
achieved use) or that State or federal law is being violated, or that further conditions are necessary to
assure compliance, the NCDWR may reevaluate and modify this certification.
During the site visit, it was clearly observed that the stone used to construct the work pad was not
washed. While not directly observed by NCDWR staff, it has been reported that a plume was visible
during the installation of the work pad. With the amount of stone used to construct the work pad and
the amount of dust observed on the stone, it is quite possible that a turbidity related water quality
violation occurred as a result of using unwashed stone. Additionally, the stone dust will likely continue
to wash off during rain events causing additional turbidity plumes. The turbidity standard for Class C
waters, such as the Uwharrie River, is 50 NTU; exceeding this will result in a violation of water quality
standards.
Please contact me so we can discuss how future sediment releases will be managed to
prevent turbidity and other water quality violations. It should be noted that Condition 5 of
the Certification states "A turbidity curtain will be installed in the stream if driving or drilling
activities occur within the stream channel, on the stream bank, or within 5 feet of the top of
bank." While the Certification only requires turbidity curtains during pile installation, due to
turbidity concerns, the NCDWR feels it would be prudent to go ahead and install turbidity
curtains downstream of the work pad. Please be mindful that the turbidity curtain should not
be installed such that it impedes the ten -foot navigation way.

Condition 26: The Permittee shall report any violations of this certification to the Division of Water
Resources within 24 hours of discovery.
The NCDWR would like to remind the NCDOT and Lee Construction Company of the
Carolinas that any violation(s) of conditions to the 401 Water Quality Certification, issued
April 24, 2014, resulting from construction or associated activities shall be reported to the
NCDWR by phone, email, or letter within 24 hours of incident. The NCDWR will work
with the NCDOT, Lee Construction Company staff, and the USACE as necessary, on
how to best address the situation.
Moving forward, if conditions of the 401 WQC cannot be met, please contact the NCDWR to
discuss how best to proceed. If you have any questions, please contact David Wainwright at
(919)707 -8787 or David.Wainwright @ncdenr.gov.
cc: Liz Hair, Wilmington US Army Corp District Office (electronic copy only)
Mr. Ron Shaw, Lee construction Company of the Carolinas, PO Box 7667 Charlotte, NC 28241
File Copy