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William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
August 29, 2005
MEMORANDUM
To: Chavonda Brown, Bridge Planning Unit, NC DOT
From: Brian L. Wrenn, NCDWQ, Transportation Permitting Unit ~,
Subject: Request for Comments for the Replacement of Bridge No. 195 on SR 1552 over Lake
James Creek in McDowell County, TIP Project No. B-3872
In reply to your correspondence dated June 15, 2005 (received June 27, 2005) in which you requested
comments for the referenced project, the NC Division of Water Quality has the following comments:
Project Specific Comments:
1. The request for comments cover letter references Lake James Creek as the surface water being
crossed by Bridge No. 195: However, the Categorical Exclusion document shows that the bridge
would be constructed over Bear Creek. It is unclear where Lake James Creek is located. Please
provide an explanation for the discrepancy between the stream names.
2. Bridge No. 195 would be relocated east of the existing bridge closer to Lake James. Lake James is in
the Catawba River Basin and is subject to Catawba River Buffer Rules.. Please indicate any potential
buffer impacts that may occur as a result of this project. NC DOT is respectfully reminded that any
buffer impacts greater than 1501f of stream length and/or greater than one-third of an acre in area will
required compensatory mitigation.
3. Once the existing bridge is removed the area should be returned to the natural elevation and contours
of the adjacent undisturbed areas. Native woody vegetation should be planted in all disturbed areas.
The native vegetation should be representative of the surrounding undisturbed areas.
General Comments:
1. If the old bridge is removed, no discharge of bridge material into surface waters is preferred. Strict
adherence the Corps of Engineers guidelines for bridge demolition will be a condition of the 401
Water Quality Certification.
2. DWQ prefers spanning structures. Spanning structures usually do not require work within the stream
and do not require stream channel realignment. The horizontal and vertical clearances provided by
bridges allows for human and wildlife passage beneath the structure, does not block fish passage, and
does not block navigation by canoeists and boaters.
3. Bridge deck drains should not discharge directly into the stream; stormwater should 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. Please refer to NCDOT Best Management
Practices for the Protection of Surface Waters
Q;thCarolina
Transportation Permitting Unit lltllCQ~~t,~
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone: 919-733-1786 /FAX 919-733.6893 / Internet: http://h2o.enr.state.nc.us/ncwetlands
An Equal Opportunity/Affirmative Action Employer-50% Recycled/10% Post Consumer Paper
August 29, 2005
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4. Live concrete should not be allowed to contact the water in or entering into the stream. Concrete is
mostly made up of lime (calcium carbonate) and when in a dry or wet state (not hardened) calcium
carbonate is very soluble in water and has a pH of approximately 12. IFi an unhardened state concrete
or cement will change the pH of fresh water to very basic and will cause fish and other
macroinvertebrate kills.
5. If possible, bridge supports (bents) should not be placed in the stream.
6. If temporary access roads or detours are constructed, they should be removed back to original ground
elevations immediately upon the completion of the project.' Disturbed areas should be seeded or
mulched to stabilize the soil and native tree species should be planted with a spacing of not more than
10'x10'. If possible, 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 disturbed soil.
7. A clear bank (rip rap-free) area of at least 10 feet should remain on each side of the steam underneath
the bridge.
8. Sedimentation and erosion control measures sufficient to protect water resources. must be
implemented prior to any ground disturbing activities. Structures should be maintained regularly,
especially following rainfall events.
9. Bare soil should be stabilized through vegetation or other means as quickly as feasible to prevent
sedimentation of water resources.
10. All work in or adjacent to stream waters should be conducted in a dry work area. Sandbags, rock
berms, cofferdams,. or other diversion structures should be used where possible to prevent excavation
in flowing water.
11. 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.
]:n most cases, we prefer the replacement of the existing structure at the same location with road closure.
If road closure is not feasible, a temporary detour should be designed and located to avoid wetland
impacts, to minimize the need for clearing, and to avoid destabilizing stream banks. ff the structure will
be on a new alignment, the old structure should be removed and the approach fills removed from the 100-
year floodplain. Approach fills should be removed down to the natural ground elevation. The area
should be stabilized with grass and planted with native tree species. Tall fescue should not be used in
riparian areas. If the area that is reclaimed was previously wetlands, NCDOT should restore the area to
wetlands. If successful, the site may be used as wetland mitigation for the subject project or other
projects in the watershed.
Thank you for requesting our input at this time. The DOT 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 Brian Wrenn 919-733-5715.
August "Ly, 2UU5
Page 3
pc: Steve Lund, USACE Asheville Field Office
Mike Parker, NCDWQ, Asheville Regional Office
Chris Militscher, USEPA
Marla Chambers, NCWRC
Marella Buncick, USFWS
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