20110023_Staff Comments_20081015

W A T Michael F Easley, Governor
?F
?9
?? pG William G Ross Jr, Secretary
North Carolina Department of Environment and Natural Resources
(3\ r Coleen Sullins, Director
5: r- Division of Water Quality
o ?
October 15, 2008
MEMORANDUM
To Melba McGee, Environmental Coordinator, Office of Legislative and Intergovernmental
Affairs 1
Through Brian Wrenn, Transportation Permitting Unit, NC DWQ p3
From David Wainwright, Transportation Permitting Unit, NC DWQ,2d
Subject Comments on the Final Environmental Impact Statement related to the proposed
replacement of the Bonner Bridge and upgrades to NC 12, Dare County, Federal Aid
Project No BRS-2358(15), State Project No 8 1051205 TIP B-2500
State Clearinghouse Project No 09-0078
This office has reviewed the referenced document dated September 11, 2008 The Division of Water
Quality (DWQ) is responsible for the issuance of the Section 401 Water Quality Certification for
activities that impact Waters of the U S , including wetlands It is our understanding that the project as
presented will result in impacts to jurisdictional wetlands, streams, and other surface waters The DWQ
offers the following comments based on review of the aforementioned document
Project Specific Comments:
This project is being planned as part of the 404/NEPA Merger Process As a participating team
member, the NCDWQ will continue to work with the team
2 According to the Green Sheet and, as discussed in the text, the NCDOT and the contractor are
planning on jetting the piles in place before being seated to their final elevation The DWQ
understands the necessity for completing this project as quickly as possible and betting is quicker
than some other methods It is also understood that the velocity through Oregon Inlet is high and
may negate some potential turbidity and noise problems, which during tourist season may be
undesirable However, the DWQ does not generally prefer this method Other methods allow for
better control of turbidity If the NCDOT and its contractor(s) plan on pursuing this method, then
the NCDOT will need to provide a plan in the 401 Water Quality Certification application that
adequately addresses turbidity concerns to the best extent practicable
3 There is mention on the document of dragging barges into position for use as a temporary work
bridge The DWQ does not approve of dragging barges along the bottom It is preferred to float the
barge into position, and then sink it The dragging of barges is very destructive to the bottom and
subsequently to aquatic life
4 The DWQ would prefer that temporary dredging during construction be kept to a minimum The
use of temporary work bridges, when possible, is preferred At the very least, dredging should be
kept to a minimum during the spring in order to reduce potential impacts to fisheries resources
NorthCarolma
Transportation Permitting Unit )Vatmrally
1650 Mad Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone [phone] FAX [phone] / Internet httg //h2o enr state nc us/ncvvetlands
An Equal Opportunity/Affirmative Action Employer- 50% Recycled/10% Post Consumer Paper
S.
The document indicates that not all stormwater on the bridge may be able to be collected and
treated The DWQ does not allow stormwater to be discharged from bridges directly into stream or
wetlands without proper treatment and velocity dissipation The NCDOT will be required to find a
way to properly collect and treat all stormwater from the bridge
General Comments:
NC DOT is respectfully reminded that all impacts, including but not limited to, bridging, fill,
excavation and clearing, 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
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
Bridge deck drains should 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 Please refer to the most current version of
NC DWQ Stormwater Best Management Practices
The NCDWQ appreciates the opportunity to provide comments on your project Should you have any
questions or require any additional information, please contact David Wainwright at [phone]
cc Bill Biddlecome, US Army Corps of Engineers, Washington Field Office
Clarence Coleman, Federal Highway Administration
Chris Mihtscher, Environmental Protection Agency (electronic)
Travis Wilson, NC Wildlife Resources Commission (electronic)
Gary Jordan, US Fish and Wildlife Service (electronic)
Cathy Brittmgham, Division of Coastal Management
Garcy Ward, DWQ Washington Regional Office
File Copy
Department of Environment and Natural Resources
Office of Legislative and Intergovernmental Affairs
Project Review Form
Project Number
oci -Go 1-6 County
D f) R c Date Received
to IQio`b Date Response Due (firm deadline)
101 PS 10

This project is being reviewed as indicated below
Regional Office Regional Office Area In-House Review
Asheville I Air - Soil & Water X Marine Fisheries
Fayetteville _)L Water X Coastal Management
Mooresville ?t Aquifer Protection x Wildlife bo-r
Raleigh X Land Quality Engineer - Forest Resources
y Washington - Water Resources - Environmental Health
Wilmington Parks & Recreation - Solid Waste Mgmt
Winston-Salem L Water Quality -'DoT v- Radiation Protection
-
- Air Quality - Other
Manager Sign-off/Region Date In-House Reviewer/Agency
Response (check all applicable)
- No objection to project as proposed
No comment
- Insufficient information to complete review ?•?, 4
08
®l
Other (specify or attach comments)
lA A
RETURN TO:
Melba McGee
Environmental Coordinator
Office of Legislative & Intergovernmental Affairs