20190201 Ver 1_U-5747-scoping_20170511

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ROY COOPER
Gnrernw�
MICHAEL S. REGAN
Sc•crrtui�r
Environmental S. JAY ZIMMERMAN
Quality n�,������»�
May 11, 2017
MEMORANDUM
To
From:
Zal�id Balocl�, PE, NCDOT Project Developn�ent
Rob Ridings, NC Division of Water Resources, Transportation P�i7nitting Branch
Subject: Scoping comments onproposed improvements to SR 1635 in Walce County, State ProjectNo. SOl67.l.1,
TIP No. U-5747
Reference your correspondence received May 1, 2017 in which you requested conm�ents for tl�e referenced project.
Preliminary analysis of the �roject reveals tl�e potential for impacts to strean�s/tributar�ies, riparian buffers, andlor
jurisdictional wetlands in tl�e project area. More specifically, impacts to:
Stream Name River Basin & Subbasin Stream Classifications Stream Index Number 303(d) Listing?
Kit Creek CPF OS WS-V; NSW 16-41-]-17-2-(0.3) No
UT Crabtree Creek NEU 02 C; NSW 27-33-(l ) Yes
Further investigations at a higher resolutioi� should be undertaken to verify the �resence of otller streams and/or
jurisdictional wetlands in the area. In the event that any jurisdictional a�-eas are identified, the Division of Water
Resotu-ces requests that NCDOT consider the following environmental issues for the proposed project:
Project Spetific Comments:
Kit Creelc and its tributaries are class WS-V; NSW waters of the State. The NCDWR is veiy concerned
with sediment and erosion im�pacts that could result fi-om this project. The NCDWR recommends tl�at
highly protective sedin�ent and erosion conh�ol BMPs be implemented to reduce the risk of nutrient runoff
to these streams. Additionally, to meet the requirements of NCDOT's NPDES permit NCS0000250 the
NCDWR reqliests that road design plans provide treatment of the storm water runoff tlu•ough best
management practices as detailed 'u1 the most recent version of the Noy�tlz C'ar•olirza Depar•tmer�t of'
Trarasportatior� Stormtivatei- Best Mnnagen�zent Practices Toolbo_r manttal.
Crabtree Creek and its tributaries are class C;NSW; 303(d) iinpaired waters of the State. The NCDWR is
very conceri�ed with sedimei�t and erosion i���pacts that could resiilt fi-om this project. The NCDWR
recoi��mends that the most protecrive� sediment and erosion control BMPs be i��lplemented in accordance
with Desigrz Stczndarcls in Sensitive Wntersheds (15A NCAC 04B .0124) to reduce the risk of further
impainl�ent to these waters. Additionally, to �neet the rec�uiren�ents of NCDOT's NPDES pei-mit
NCS0000250, the NCDWR rec�uests that road design plans provide treah»ent of the storm water nmoff
through best management practices as detailed in the imost recent ver-sion of the Nortla Cczr-olirza
De�artment of Tr•ansportatio�a Storrr�waxer Best Manngen�re��t Practices Toolhox manual.
3. This project is within the Neuse River and Jordan Lake bains. Riparian buffer impacts shall be avoided aild
minimized to the greatest extent possible pursuant to 15A NCAC 2B.0233 and 15A NCAC 2B.0267. New
development activities located ii1 the protected 50-foot wide riparian areas within the basin shall be limited
to "uses" idei7tified within and constructed in accordance with 15A NCAC 2B.0295. Buffer mitigarion
�."T^Jntf�i��� C:i,�����.are�s _
State of No�tl� Caroli��a I E�vironmental Quality
I(17 Mail Service Center I Raleigh, North Carolina 27699-1617

may be required for buffer impacts resulting from activities classified as "allowable with mitigation" within
the "Table of Uses" section of the Buffer Rules or require a variance under the Buffer Rules. A buffer
mitigation plan, including use of the North Carolina Division of Mitigation Services, must be provided to
the NCDWR prior to approval of the Water Quality Certification. Buffer mitigation may be required for
buffer impacts resulting from activities classified as "allowable with mitigation" within the "Table of Uses"
section of the Buffer Rules or require a variance under the Buffer Rules. A buffer mitigation plan,
coordinated with the North Carolina Division of Mitigation Services, must be provided to the NCDWR
prior to approval of the Water Quality Certification.
General Project Comments:
The environmental document 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. Environmental impact statement alternatives shall consider design criteria that reduce the impacts to streams
and wetlands from storm water runoff. These alternatives shall include road designs that allow for treatment
of the storm water runoff through best management practices as detailed in the most recent version of the
North Carolina Department of Transportation Stormwater Best Management Practices Tool box manual,
such as grassed swales, buffer areas, preformed scour holes, retention basins, etc.
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 shall be designed
to replace appropriate lost functions and values. North Carolina Division of Mitigation Services may be
available for assistance with wetland mitigation.
4. In accordance with the Environmental Management Commission's Rules (15A NCAC 2H.0506[h]),
mitigation will be required for impacts of greater than 1501inear 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.
5. 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.
6. 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.
7. An analysis of cumulative and secondary impacts anticipated as a result of this project is required. 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.
8. 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 Quality Certification Application.
9. 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 areas 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 extent practicable.
10. Whenever possible, the NCDWR 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 shall allow for human and wildlife passage beneath the
structure. Fish passage and navigation by canoeists and boaters shall not be blocked. Bridge supports (bents)
should not be placed in the stream when possible.
11. 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.
12. Sediment and erosion control measures should not be placed in wetlands or streams.
13. Borrow/waste areas should avoid wetlands to the maximum extent practicaL Impacts to wetlands in
borrow/waste areas will need to be presented in the 401 Water Quality Certification and could precipitate
compensatory mitigation.
14. The 401 Water Quality Certification application will need to specifically address the proposed methods for
stormwater management. More specifically, stormwater shall not be permitted to discharge directly into
streams or surface waters.
15. Based on the information presented in the document, the magnitude of impacts to wetlands and streams may
require a Nationwide Pernut application to the Corps of Engineers and corresponding 401 Water Quality
Certification. Please be advised that a 401 Water Quality Certification requires satisfactory protection of
water quality to ensure that water quality standards are met and no wetland or stream uses are lost. Final
pernut 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.
16. If concrete is used during construction, a dry work area shall be maintained to prevent direct contact between
curing concrete and stream water. Water that inadvertently contacts uncured concrete shall not be discharged
to surface waters due to the potential for elevated pH and possible aquatic life and fish kills.
17. If temporary access roads or detours are 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. 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.
18. Unless otherwise autharized, 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, adj acent 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 deternune whether or not a permit
modification will be required.

19. If multiple pipes or barrels are required, they shall be designed to mimic natural stream cross section as
closely as possible including pipes or barrels 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.
20. 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.
21. 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.
22. 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 Activities manual such as
sandbags, rock berms, cofferdams and other diversion structures shall be used to prevent excavation in
flowing water.
23. 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 pernut approval.
24. 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 shall be
inspected daily and maintained to prevent contamination of surface waters from leaking fuels, lubricants,
hydraulic fluids, or other toxic materials.
25. 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.
26. Riparian vegetation (native trees and sl�rubs) shall be preserved to the maximum extent 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 are not degraded or lost. If you have any questions or require additional information, please contact
Rob Ridings at [e-mail] or 919-707-8786.
Electronic copy only distribution:
Teresa Gresham, Kimley-Horn
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