Scope comments.pdf

Water Resources
ENVIRONMENTAL OUALITV
PAT MCCRORY
Gavemm�
DONALD R. VAN DER VAART
set�re�a.y
S. JAY ZIMMERMAN
Direclor
June 14, 2016
MEMORANDUM
To: Al Blanton, NCDOT Division 9 Design Construct Engineer
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From: Dave Wanucha, NC Division of Water Resources, Winston Salem Regional Office
Subject: Scoping comments on proposed improvements/widening to NC 66 in Forsyth County, TIP U-5824
Reference your electronic correspondence dated June l, 2016 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
Old Field Creek
Lowery Mill
Creek
Martin Mill
Creek
Notes: *Annrovec
River Basin Stream
Classificatic
Roanoke B
Yadkin Pee Dee WS-111
Yadkin Pee Dee WS-Ill
TMDL for Mercury
Stream Index
Number
22-25-11
12-94-12-3-(0.5)
12-94-12-3-1
303(d) Listing*
No
No
No
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
Resources requests that NCDOT consider the following environmental issues for the proposed project.
General Project Comments:
Prior to an issuance of the 401 Water Quality Certification, the NCDOT is respectfully reminded that they will
need to demonstrate the avoidance and minimization of impacts to wetlands (and streams) to the maximum
extent practicaL In accordance with the Environmental Management Commission's Rules (15A NCAC
2H.0506[h]), mitigation will be required for impacts of greater than 1 acre to wetlands. In the event that
mitigation is required, the mitigation plan shall be designed to replace appropriate lost functions and values.
North Carolina Division of Mitigation Services may be available for assistance with wetland mitigation.
2. In accordance with the Environmental Management Commission's Rules (15A NCAC 2H.0506[h]),
mitigation will be required for impacts of greater than I50 linear feet to any perennial stream. In the event
that mitigation is required, the mitigation plan shall be designed to replace appropriate lost functions and
values. The North Carolina Division of Mitigation Services may be available for assistance with stream
mitigation.
Future documentation, including the 401 Water Quality Certification Application, shall continue to include an
itemized listing of the proposed wetland and stream impacts with corresponding mapping.
State of North Carolina IEmironmental Quality I Water Resowces
1617 Mail Service Center. Raleigh, NoRh Carolina 27699-1617
Phone�.919-807-0300

4. The NCDWR is very concerned with sediment and erosion impacts that could result from this project. The
NCDOT 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.
5. An analysis of cumulative and secondary impacts anticipated as a result of this project is requ'ved. The type
and detail of analysis shall conform to the NC Division of Water Resource Policy on the assessment of
secondary and cumulative impacts dated April 10, 2004.
6. The NCDOT is respectfully reminded that all impacts, including but not limited to, bridging, fill, excavation
and clearing, and rip rap to jurisdictional wetlands, streams, and riparian buffers need to be included in the
final impact calculations. These impacts, in addition to any construction impacts, temporary or otherwise,
also need to be included as part of the 401 Water Qualiry Certification Application.
7. Where streams must be crossed, the NCDWR prefers bridges be used in lieu of culverts. However, we realize
that economic considerations often require the use of culverts. Please be advised that culverts should be
countersunk to allow unimpeded passage by fish and other aquatic organisms. Moreover, in azeas where high
quality wetlands or streams are impacted, a bridge may prove preferable. When applicable, the NCDOT
should not install the bridge bents in the creek, to the maximum elctent practicable.
8. Whenever possible, the NCDWR prefers spanning siructures. 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 shall allow for human and wildlife passage beneath the
structure. Fish passage and navigation by canoeists and boaters shali not be blocked. Bridge supports (benu)
should not be placed in the stream when possible.
9. Bridge deck drains shall not discharge directly into the stream. Stormwater shall be directed across the bridge
and pre-treated through site-appropriate means (grassed swales, pre-formed scour holes, vegetated bufFers, etc.)
before entering the stream. To meet the requirements of NCDOT's NPDES permit NCS0000250, please refer
to the most recent version of the North Carolina Department of Transportation Stormwater Best Management
Practices Toolbox manual for approved measures.
10. Sediment and erosion control measures should not be placed in wetlands or streams.
11. Borrow/waste azeas should avoid wetlands to the maacimum extent practicaL Impacts to wetlands in
bonow/waste azeas will need to be presented in the 401 Water Quality Certification and could precipitate
compensatory mitigation.
12. 'fhe 401 Water Quality Certification application will need to specifically address the proposed methods for
stormwater management. More specifically, stormwater shall not be permitted to dischazge directly into
streams or surface waters.
13. Based on the information presented in the document, the magnitude of impacts to wetlands and streams may
require a Nationwide (NV� application to the Corps of Engineers and corresponding 401 Water Quality
Certification. Please be advised that a 401 Water Qualiry Certification requires satisfactory protection of
water quality to ensure that water quality standards are met and no wetland or stream uses aze lost. Final
permit authorization will require the submittal of a formal application by the NCDOT and written concurrence
from the NCDWR. Please be aware that any approval will be contingent on appropriate avoidance and
minimization of wetland and stream impacts to the maximum extent practical, the development of an
acceptable stormwater management plan, and the inclusion of appropriate mitigation plans where appropriate.
14. If concrete is used during construction, a dry work azea shall be maintained to prevent direct contact between
curing concrete and stream water. Water that inadvertently contacts uncured concrete shall not be dischazged
to surface waters due to the potential for elevated pH and possible aquatic life and fish kills.
15. If temporary access roads or detours aze constructed, the site shall be graded to its preconstruction contours
and elevations. Disturbed areas shall be seeded or mulched to stabilize the soil and appropriate native woody
species shall be planted. When using temporary structures the area shall be cleared but not grubbed. Cleazing
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.

16. Unless otherwise authorized, placement of culverts and other structures in waters and streams shall be placed
below the elevation of the streambed by one foot for all culverts with a diameter greater than 48 inches, and
20 percent of the culvert diameter for culverts having a diameter less than 48 inches, to allow low flow
passage of water and aquatic life. Design and placement of culverts and other structures including temporary
erosion control measures shall not be conducted in a manner that may result in dis-equilibrium of wetlands or
streambeds or banks, adjacent to or upstream and downstream of the above structures. The applicant is
required to provide evidence that the equilibrium is being maintained if requested in writing by the NCDWR.
If this condition is unable to be met due to bedrock or other limiting features encountered during construction,
please contact the NCDWR for guidance on how to proceed and to determine whether or not a permit
modification will be required.
17. If mulriple pipes or barrels aze required, they shall be designed to mimic natural stream cross section as
closely as possible including pipes or ba�rels at flood plain elevation, floodplain benches, and/or sills may be
required 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.
18. If foundation test borings are necessary; it shall be noted in the document. Geotechnical work is approved
under Genera1401 Certification Number 3883/Nationwide Permit No. 6 for Survey Activities.
19. Sediment and erosion control measures sufficient to protect water resources must be implemented and
maintained in accordance with the most recent version of North Cazolina Sediment and Erosion Control
Planning and Design Manual and the most recent version of NCS000250.
20. All work in or adjacent to stream waters shall be conducted in a dry work area. Approved BMP measures
from the most current version of the NCDOT Construction and Maintenance Activiries manual such as
sandbags, rock berms, cofferdams and other diversion structures shall be used to prevent excavation in
flowing water.
21. While the use ofNational Wetland Inventory (NWI) maps, NC Coastal Region Evaluation of Wetland
Significance (NGCREWS) maps and soil survey maps are useful tools, their inherent inaccuracies requ've
that qualified personnel perform onsite wetland delineations prior to permit approval.
22. Heary 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 shall be
inspected daily and maintained to prevent contaminarion of surface waters from leaking fuels, lubricants,
hydraulic fluids, or other toxic materials.
23. 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.
24. Riparian vegetation (native trees and shrubs) shall be preserved to the maa�imum wctent possible. Riparian
vegetation must be reestablished within the construction limits of the project by the end of the growing season
following completion of construction.
Thank you for requesting our input at this time. The NCDOT 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 aze not degraded or lost. If you have any questions or require additional information, please contact
Dave Wanucha at [phone] or [e-mail].
Electronic copy only distribution:
John Thomas, US Army Corps of Engineers, Raleigh Field Office
Kristi Lynn Carpenter, NCDWR
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