20081327_More Info Letter_20080418

OF WAT~9 Michael F. Easley, Governor
O~ pG William G. Ross Jr., Secretary
y North Carolina Department of Environment and Natural Resources
j r Coleen H. Sullins, Director
Division of Water Quality

April 18, 2008

MEMORANDUM

TO: Colin Mellor, NEU, NCDOT

FROM: Brian Wrenn, Transportation Permitting Unit, NC Division of Water Quality
SUBJECT: Requested Comments for the Draft Qualitative Indirect and Cumulative Effects
Assessment for the Proposed Widening of SR 1793 (Upward Road), TIP Project No.
R-4430.

NCDWQ has reviewed the referenced document. We offer the following comments:

1. Previous comments made by NCDWQ regarding this project referenced the potential presence of
acid-forming rock in the project corridor. It is unclear if any geotechnical determinations have been
made regarding this issue. Subsequently, NCDWQ has concerns about acid-forming rock for
secondary development stimulated by the proposed project. Please provide geotechnical data
regarding the presence of acid-forming rock in the proposed road corridor and in the Growth Impact
Study Area. (GISA). The determination of the potential presence of acid-forming rock in the GISA
can be conducted through a mapping exercise in accordance with NCDWQ's Assessing and
Controlling Acid Rock Drainage on Projects Requiring Section 401 Water Quality Certification (see
attached). Geotechnical investigations should be made for the proposed road corridor.
2. Bat Fork Creek (6-55-8-1), Class C waters of the State, is listed on the 2008 Draft 303(d) list for
impaired waters for Biological Criteria Exceeded. NCDWQ has serious concerns regarding impacts
to this stream from construction and operation of the proposed road as well from indirect and
cumulative development. Often, NCDWQ requires a quantitative analysis of indirect and cumulative
impacts for projects draining to 303(d) listed streams. However, considering that this project is a
widening project with minor impacts to indirect and cumulative development, NCDWQ will accept a
qualitative analysis if NCDOT will implement enhanced sedimentation and erosion control and
stormwater control measures. We request that NCDOT implement Design Standards in Sensitive
Watersheds [I 5A NCAC 4B .0124(a)-(e)] for the portions of the construction corridor draining to Bat
Fork Creek. In addition, we request that NCDOT implement stormwater BMPs that route stormwater
runoff from the road project through vegetated conveyances with outlet velocities at non-erosive
velocities.
Thank you for the opportunity to comment on this document. We look forward to working with you in
the future on this project. If you have any questions regarding these comments, please contact me at 919-
733-5715.

Nw
One
hCarolin
Transportation Permitting Unit ? A(rQ«Y
1650 Mail Servioe Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone: [phone] /FAX [phone] / Intemet: http://h2o.enr.state.nc.us/ncwetlands
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cc: Dave Baker, US Army Corps of Engineers, Asheville Field Office
Clarence Coleman, Federal Highway Administration
Roger Bryan, Division 13 Environmental Officer
Chris Militscher, Environmental Protection Agency
Marla Chambers, NC Wildlife Resources Commission
Mike Parker, DWQ Asheville Regional Office
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