20151179 Ver 1_Scoping Comments_20091001

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RCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
October 1, 2009
MEMORANDUM
TO: Breanna Poole, NCDOT
Dee Freeman
Secretary
FROM: Amy Euliss, NCDWQ, Winston Salem Regional Office
SUBJECT: Scoping Review of NCDOT's Proposed Bridge Replacement Projects: B-4962, B-5162,
B-4756, B-4961, B-4623, B-5163, B-5154
In reply to your correspondences dated September 1 and 8 in which you requested comments for the
above referenced projects, the NCDWQ offers the following comments:
Project-Specific Comments
B-4962, Bridge No. 46 over Eno River on US 70, Orange County
1. This project is within the Neuse River Basin. Riparian buffer impacts shall be avoided and
minimized to the greatest extent possible pursuant to 15A NCAC 2B .0233 for Neuse.
2. The Eno River is class C; NSW waters of the State. NCDWQ is very concerned with sediment
and erosion impacts that could result from this project. NCDWQ recommends that highly
protective sediment and erosion control BMPs be implemented to reduce the risk of nutrient
runoff to the Eno River. NCDWQ requests that road design plans provide treatment of the storm
water runoff through best management practices as detailed in the most recent version of
NCDWQ's Stormwater Best Management Practices.
B-5154, Bridge No. 56 over US 29B/US 158 on SR 2670, Rockingham County
*There are no visible streams in the area. The area should still be assessed on the ground. Please see
general comments below.
B-5163, Bridge No. 160 over Buffalo Creek on SR 1354, Rockingham County
*No project specific conditions. Please see general comments below.
B-4623, Bridge No. 47 over Hogan's Creek on SR 1128, Rockingham County
*No project specific conditions. Please see general comments below.
B-5162, Bridge No. 35 over Rattlesnake Creek on SR 1523, Caswell County
1. The project site is less than 1 mile and draining to the Dan River. The Dan River is class C;
303(d) waters of the State. The Dan River is on the 303(d) list for impaired use for aquatic life
due to turbidity. NCDWQ is very concerned with sediment and erosion impacts that could result
from this project. NCDWQ recommends that the most protective sediment and erosion control
BMPs be implemented in accordance with Design Standards in Sensitive Watersheds to reduce
the risk of nutrient runoff to the Dan River. NCDWQ requests that road design plans provide
treatment of the storm water runoff through best management practices as detailed in the most
recent version of NCDWQ's Stormwater Best Management Practices.
Transportation Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
Location: 2321 Crabtree Blvd., Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: http://h2o.enr.state.nc.us/ncwegandsJ
One
rthCarolina
No
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An Equal opportunity 1 Affirmative Action Employer
B-4961, Bridge No. 208 over Little Alamance Creek on SR 3051, Guilford County
1. This project is within the Cape Fear River Basin and within the watershed for Jordan Lake.
Riparian buffer impacts shall be avoided and minimized to the greatest extent possible pursuant to
15A NCAC 2B .0267.
2. Little Alamance Creek are class WS IV; NSW waters of the State. NCDWQ is very concerned
with sediment and erosion impacts that could result from this project. NCDWQ recommends that
highly protective sediment and erosion control BMPs be implemented to reduce the risk of
nutrient runoff to Little Alamance Creek. NCDWQ requests that road design plans provide
treatment of the storm water runoff through best management practices as detailed in the most
recent version of NCDWQ's Stormwater Best Management Practices.
B-4756, Bridge No. 120 over Reedy Fork Creek on SR 2128, Guilford County
1. This project is within the Cape Fear River Basin and within the watershed for Jordan Lake.
Riparian buffer impacts shall be avoided and minimized to the greatest extent possible pursuant to
15A NCAC 213.0267.
2. Reedy Fork Creek are class WS III; NSW; 303 (d) waters of the State. NCDWQ is very
concerned with sediment and erosion impacts that could result from this project. NCDWQ
recommends that highly protective sediment and erosion control BMPs be implemented to reduce
the risk of nutrient runoff to Little Alamance Creek. NCDWQ requests that road design plans
provide treatment of the storm water runoff through best management practices as detailed in the
most recent version of NCDWQ's Stormwater Best Management Practices.
3. Reedy Fork Creek is class WS III; NSW; 303(d) waters of the State. The Dan River is on the
303(d) list for impaired use for aquatic life due to impaired biological criteria. NCDWQ is very
concerned with sediment and erosion impacts that could result from this project. NCDWQ
recommends that the most protective sediment and erosion control BMPs be implemented in
accordance with Design Standards in Sensitive Watersheds to reduce the risk of nutrient runoff to
the Reedy Fork Creek. NCDWQ requests that road design plans provide treatment of the storm
water runoff through best management practices as detailed in the most recent version of
NCD WQ's Stormwater Best Management Practices.
General Comments Regarding All of the Above Bridge Replacement Projects
1. The environmental document shall 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 21-1.0506(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 assessment 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 NCDWQ Stormwater Best Management Practices, 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, 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. The NC Ecosystem
Enhancement Program may be available for use as wetland mitigation.
4. In accordance with the Environmental Management Commission's Rules 115A NCAC 2H.0506(h)},
mitigation will be required for impacts of greater than 150 linear feet to any single perennial stream.
In the event that mitigation is required, the mitigation plan shall be designed to replace appropriate
lost functions and values. The NC Ecosystem Enhancement Program may be available for use as
stream mitigation.
5. NCDWQ is very concerned with sediment and erosion impacts that could result from this project.
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.
6. If a bridge is being replaced with a hydraulic conveyance other than another bridge, NCDWQ
believes the use of a Nationwide Permit may be required. Please contact the US Army Corp of
Engineers to determine the required permit(s).
7. If the old bridge is removed, no discharge of bridge material into surface waters is allowed unless
otherwise authorized by the US ACOE. Strict adherence to the Corps of Engineers guidelines for
bridge demolition will be a condition of the 401 Water Quality Certification.
8. Whenever possible, NCDWQ 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) shall 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. Please refer to the most current version of
NCDWQ's Stormwater Best Management Practices.
10. 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.
11. 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 should 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.
12. Placement of culverts and other structures in waters, streams, and wetlands shall be 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 down stream of the
above structures. The applicant is required to provide evidence that the equilibrium is being
maintained if requested in writing by NCD WQ. If this condition is unable to be met due to bedrock
or other limiting features encountered during construction, please contact NCDWQ for guidance on
how to proceed and to determine whether or not a permit modification will be required.
13. 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 shall 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.
14. If foundation test borings are necessary; it should be noted in the document. Geotechnical work is
approved under General 401 Certification Number 3624/Nationwide Permit No. 6 for Survey
Activities.
15. 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.
16. All work in or adjacent to stream waters shall be conducted in a dry work area unless otherwise
approved by NCDWQ. Approved BMP measures from the most current version ofNCDOT
Construction and Maintenance Activities manual such as sandbags, rock berms, cofferdams and other
diversion structures should be used to prevent excavation in flowing water.
17. Sediment and erosion control measures shall not be placed in wetlands and streams.
18. Borrow/waste areas shall avoid wetlands to the maximum extent practical. Impacts to wetlands in
borrow/waste areas could precipitate compensatory mitigation.
19. 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 permit approval.
20. Heavy equipment shall 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.
21. Inmost cases, NCDWQ prefers 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, minimize the need for clearing and to avoid destabilizing stream banks. If the
structure will be on a new alignment, the old structure shall be removed and the approach fills
removed from the 100-year floodplain. Approach fills should be removed and restored to the natural
ground elevation. The area shall be stabilized with grass and planted with native tree species. Tall
fescue shall not be used in riparian areas.
22. 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.
Thank you for requesting our input at this time. 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 Amy Euliss at [phone].
cc: Andy Williams, US Army Corps of Engineers, Raleigh Field Office
Federal Highway Administration
Jerry Parker, Division 7 Environmental Officer
Kathy Matthews, Environmental Protection Agency (electronic copy only)
Travis Wilson, NC Wildlife Resources Commission
Wetlands/401 Transportation Permitting Unit
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