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HomeMy WebLinkAbout20041764 Ver 3_More Info Received_20100218aC- o4116h 82 4 Ian From: Karoly, Cyndi Sent: Thursday, February 18, 2010 11:54 AM To: Mcmillan, Ian Subject: FW: Shiloh Crossing - Morrisville, NC Attachments: Shiloh-BMP-As-Built-Punchlist-12-17-09.pdf; Shiloh-Crossing-SLOPE-EXHIBIT-2.pdf; Shiloh- Crossing-SLOPE-EXHIBIT-1.pdf; Shiloh-BMP-Issues-2-12-10.pdf fyi for the file From: Bradley Bowling [mailto:bbowling@priestcraven.com] Sent: Friday, February 12, 2010 4:35 PM To: Landry, Natalie Cc: jimspeake@gmail.com; 'Tommy Craven'; Kevin Martin; tgrady@g2designpa.com; Austin.Watts@kimley-horn.com; todd.stjohn@kimley-horn.com; Moltz, Phillip; 'Fredrick Lutz'; Karoly, Cyndi; Smith, Danny Subject: Shiloh Crossing - Morrisville, NC Natalie, Please find attached information we are providing based on our meeting of January 27th regarding the Shiloh Crossing Development in Morrisville, NC. I will follow up with a hard copy of this information that will be delivered to your office early next week. If you have any questions or require any additional information, please let me know. Thanks, Bradley Bowling, PE Priest, Craven and Associates, Inc. Phone: (919) 781-0300 Fax: (919) 782-1288 PRIEST, CRAVEN, & ASSOCIATES, INC. LAND USE CONSULTANTS December 17, 2009 Reference: Shiloh Crossing - Morrisville, NC Permanent BMP's and Temporary Sediment Basin As-Builts and Punchlist Items We performed a cursory visual observation of the Permanent BMP's and Temporary Sediment Basin at Shiloh Crossing on the morning of December 17, 2009. All disturbed areas in and around Wetland "A" had been sodded, the silt fence had been removed from the interior of the wetland, no construction equipment was present, and no construction activity was ongoing at the sites of the Permanent BMP's and Temporary Sediment Basins. This seems to indicate that no additional remedial actions are planned by Wal-mart. If construction is in fact complete and Wal- mart does not intend to do anything further, we have several outstanding concerns that need to be addressed. Multiple items are not in compliance with the approved construction plans. We have outlined our comments and concerns below: Permanent BMP Devices Extended Detention Wetland "A" (a.k.a. Basin #4) Grading Based on a field topographic survey by our office, the forebays do not have the appropriate depth or volume per the approved construction plans. Forebays should be graded in accordance with the approved construction plans to a bottom elevation of 351.0 providing a minimum 3 feet of depth. In accordance with the Wetland Worksheet on file with the NCDWQ and the Town of Morrisville; the required volumes for Forebay #1 and #2 are 20,491 c.f. and 21,209 c.f. respectively. According to our field surveys, the volumes are only 15,394 c.f. and 18,183 c.f. respectively. Based on our field topographic survey of the current as-built condition of the wetland, some of the re-graded slopes on the interior of the wetland as well as some of the slopes on the exterior and downstream face of the dam are much steeper than the 3:1 slopes shown in the approved construction plans. According to the approved construction plans and current NCDWQ design guidelines, all slopes from the top of dam elevation down to the bottom of the wetland should be a maximum of 3:1 for the entire wetland. The existing slopes in the pond range from 1.8:1 to 3:1 with slopes in many areas being in the 2:1 to 2.5:1 range. This is not in accordance with the approved plans. The NCDWQ and Town of Morrisville should review and approve any revisions to the approved plans. 3. Based on our field topographic survey, the slope adjacent to Level Spreader #2 on the downstream face of the daui is 1.6:1. The approved c011sUuc6011 plans call for a 3:1 slope. This is not in accordance with the approved plans and should be re-graded to a maximum 3:1 slope. 4. No topsoil has been placed on the re-graded slopes, dam, or high marsh areas. The Grading and Drainage Notes on Sheet C-2 of the approved construction plans calls for a minimum of 4"of topsoil to be incorporated into "all unsurfaced areas disturbed by grading operation". 5. No topsoil was observed being placed prior to installation of the sod. This is not in accordance with the approved plans. Per the approved construction plans, a minimum of 4" of topsoil is to be incorporated into all areas disturbed by construction prior to establishing permanent ground cover. PLANNERS / LANDSCAPE DESIGNERS / ENGINEERS / SURVEYORS 3803-B Computer Drive, Suite 104, Raleigh NC 27609, Phone: (919) 781-0300 Fax (919) 782-1288 The sod installed on the top of dam is very uneven and appeared to have been installed over the considerable rutting that had occurred outside the fence due to construction activity associated with the placement of the sod. The top of dam does not appear to have been properly repaired, graded, or compacted prior to placement of the sod. Several other areas where sod has been installed in the wetland are uneven and also did not appear to have been properly fine graded, prepared, or amended prior to sod installation. There are significant ruts and low spots on the dam that are poorly graded, have poor drainage, and are holding water. 7. Due to steep slopes, poor subgrade soils, and improper pinning some areas of sod are slumping, sliding, and separating. This should be remedied. 8. Several rutted, uneven, muddy, areas of clay like material remain at the base of the sodded slopes. These areas should be fine graded and the proper topsoil with amendments should be installed in all of these areas in accordance with the approved construction plans. 9. The area where shrubs are planted just outside the fence between the newly sodded areas is holding water in several locations. This area should be addressed to provide adequate drainage and prevent ponding of water around the shrubs. 10. There appears to be significant sediment build-up along the toe of the existing slopes within the wetland that were not re-graded. Sediment should be removed and grades established per the approved construction plans. Soils Soils used within the wetland must adhere to the requirements in the Stormwater Wetland Notes on Sheet C11-07 of the approved construction plans. The in-situ soils used in the entire wetland should have been tested by a soil scientist or other qualified individual and amended per their recommendations in accordance with the instructions on Sheet C11-07. Please have the contractor provide copies of the soil analysis, recommendations from the soil scientists or other qualified individual based on the soil analysis, and a list of all soil amendments, application rates, and techniques used by the contractor to properly prepare the soils for the wetland in accordance with the approved construction plans. 2. Per Note #5 on Sheet L-4.1 of the approved construction plans, infertile soils should be amended before installation and fertilized periodically. Please have the contractor provide a certification of all soil amendments, a list of rates and timing of fertilization, and a copy of all purchase receipts from the soil amendments added per the approved plans. 3. Please have the contractor provide us with the soil specifications from the approved project documents for the minimum 4" of topsoil to be placed in and around the wetland per the approved construction plans. 4. A large amount of debris including large sticks, stones, concrete pieces, construction debris, trash, etc. remain in the soils on the sides of the wetland, particularly along the edges of the wetland near the normal pool elevation. This is not in accordance with the approved construction plans and should be removed and remedied accordingly. Plants 1. Some existing plantings appear to have been removed and re-planted. Some of the plants that were re-planted appear to be diseased or dying. Per the Landscape Notes on Sheet L-2.0 of the approved construction plans: "All plants must be healthy, vigorous material, free of pests and disease". These plants should be replaced with healthy vegetation in accordance with the approved plans. 2. Dead and/or dying plants and shrubs remained in the existing high and low marsh areas within the wetland. These plants should be replaced with healthy vegetation. In accordance with the approved plans, "All plants must be healthy, vigorous material, free of pests and disease". The plants also did not appear to be installed per the approved construction plans. Plant installation should be per Sheets L-2.0, L-2.1, and Sheet L-4.1 of the approved construction plans. Sheet L-4.1 includes specific information for the required wetland plantings in the Wetlands Grading & Planting Notes and the plant installation details that should be followed. Per the details, shrubs and wetland plants should be installed in a hole much larger than the root ball and backfilled with a topsoil mix to promote healthy growth and establishment. 4. The entire wetland needs to be re-planted in accordance with the approved construction plans. Any proposed changes should be submitted to DWQ for approval. 5. Silt, mud, and clay material have accumulated over the base of most of the vegetation in the high marshes along the re-graded slopes. Most of the plants are dead or dying. Healthy living plants should be installed per the details in the approved construction plans and the proper topsoil with amendments should be installed in the high marsh areas as called for in the approved construction plans. In accordance with the approved plans, "All plants must be healthy, vigorous material, free of pests and disease". Permanent Grass Establishment 1. A good stand of permanent grass has still not established on the slope downstream of the emergency spillway or on the northern and northwestern interior slopes of the wetland where erosion control matting has been installed. It does not appear that the slopes were prepared in accordance with the Seedbed Preparation notes on Sheet L-2.0 of the approved construction plans and it does not appear that 4" of topsoil was incorporated into these areas prior to installing the erosion control matting. In order to establish a good stand of permanent grass in all disturbed areas from the Phase One construction, soil should be amended in accordance with Sheet L-2.0, four inches of topsoil should be incorporated in accordance with Sheet L-2.0, the seedbed should be prepared in accordance with Sheet L-2.0, the erosion control matting should be installed over the topsoil in accordance with the details on Sheet E-8, and all areas should be seeded in accordance with the Seeding Schedule on Sheet L-2.0 of the approved construction plans. The erosion control matting at the base of the northern and northwestern interior slopes of the wetland is not installed properly. A good stand of permanent grass has still not established on these slopes and the erosion control matting is exposed on top of the ground in many areas with little to no vegetation. Other areas of these slopes, along with the slope downstream of the concrete emergency spillway are poorly graded with many ruts, debris, and bunching of the plastic erosion control netting. In the current state, these slopes could not be properly maintained with mowing equipment. These slope should be re-graded to include a fine grading operation and the soil should be amended in accordance with Sheet L-2.0, four inches of topsoil should be incorporated in accordance with Sheet L-2.0, the seedbed should be prepared in accordance with Sheet L-2.0, the erosion control matting should be installed over the topsoil in accordance with the details on Sheet E-8, and all areas should be seeded in accordance with the Seeding Schedule on Sheet L-2.0 of the approved construction plans. 3. The access drive for the power easement remains in poor condition with little to no grass stand and significant bunching and rutting of the erosion control matting. The erosion control matting should be removed and reinstalled properly including making the appropriate soil amendments to provide for a healthy permanent stand of grass. 4. Several areas in and around the wetland do not have a healthy stand of grass or only have temporary grasses. All these areas should be addressed to provide a good healthy stand of permanent groundcover in accordance with the approved plans. 5. The slopes on which the matting was removed and sod installed is greater than 3:1. Morrisville requires permanent slope retention devices on slopes greater than 3:1. Contractor needs to verify sod is acceptable to the Town of Morrisville as installed in these locations. 6. Additional sod has been installed on portions of the northern and northeastern slopes of the wetland. No discing, tilling, soil amendments, or topsoil was observed under the additional areas of sod installation. This is not in accordance with the approved plans. 7. Several areas on the northern and northeastern slope that were not sodded do not have a healthy stand of permanent grass. In many areas the erosion control matting is bunched or laying on top of the ground with little to no vegetation growing. All areas should be addressed to provide proper installation of the erosion control matting and also provide a good healthy stand of permanent groundcover in accordance with the approved plans. 8. The area from the fence on the top of the northern slope of the wetland to the northern property line does not have a good stand of permanent grass and should be prepared and seeded in accordance with the approved construction plans. 9. No tilling or discing was observed prior to placement of the sod in and around the wetland. The in-situ soils over which the sod is being installed appeared to be mostly clay type soils. This is not in accordance with the approved plans, which calls for incorporating 4" of topsoil into all unsurfaced areas disturbed by construction. 10. No soil amendments were observed prior to placement of the sod. Per the approved plans, Lime and Fertilizer were to be added to the topsoil placed prior to establishing permanent ground cover. 11. The subgrade under the sod is very wet, soft, clay like material with considerable standing water under the sod in some locations, especially on the top of the dam. The dam should have been fine graded and properly prepared in accordance with the approved construction plans prior to installing sod. 12. Sod was installed directly on top of the plastic erosion control matting next to the concrete emergency spillway. No topsoil was observed under the plastic erosion control matting. 13. Some of the sod strips on the slopes on the interior of the wetland are slumping/separating in the areas of the steep re-graded slopes. These slopes should be addressed and should be a maximum slope of 3:1. Rip Rap Aprons 1. Rip-Rap Aprons are not installed at the flared end sections of Culverts C35 and C36 in accordance with the chart on Sheet E-5 of the approved construction plans. The rip-rap aprons should be installed per the specifications on Sheets E-5 and detail on Sheet E-6. 2. The rip rap pad at the end of the 48" outlet pipe (C21 from the KHA plans) from the wetland needs to be repaired and installed in accordance with the chart on Sheet E-5 and the detail on Sheet E-6 in the approved construction plans. The pipe and rip rap pad as constructed are not in accordance with the approved plans. The pipe and rip rap apron should be installed per the approved plans or the revision should be approved by the DWQ and the town of Morrisville. 3. Sediment has accumulated in the rip rap pad downstream of the 48" outlet pipe C21. There is also erosion occurring at the downstream end of the rip rap pad prior to reaching the existing stream bank. All sediment should be removed, erosion repaired, and rip rap pad installed to the creek per the details and in accordance with the approved plans. Miscellaneous 1. The drain valve in the riser remained in an open position keeping the water level below normal pool elevation. Once construction on the wetland is complete the drain valve should be fully closed. 2. The erosion control matting for the access road from Shiloh Glenn Drive has been removed and sodded. The access road should be repaired and constructed in accordance with the approved construction plans. 3. Erosion Control matting had been installed on a portion of the access drive at Shiloh Glenn Drive and silt fence has been installed across the entrance to the access drive. The matting appeared to have been installed over compacted clay soils. No sod, topsoil, or seeding was observed in the exposed areas where the erosion control matting was installed. This should be remedied. 4. A section of sidewalk is cracked and some grassed area behind the curb has been damaged due to construction traffic onto the access road. The damaged areas should be repaired. 5. Trash and construction debris has accumulated in the wetland. This debris should be removed and disposed of properly. The following is from our response on November 19, 2009 to the comments from Wal-mart in regards to our report dated August 26, 2009. These items are still outstanding and need to be addressed: Level Spreader #1 (LS-1) 1. No action required. No comment. 2. The contractor has stated this was constructed per the plan, no action is proposed. The design invert of this pipe shown on Sheet C-1 1.01 of the approved construction plans is 343.0. The design and as-built elevation of the level spreader is approximately 349.0, six feet above the design invert of FES-5A. This is not in accordance with the detail for the level spreaders and level spreader forebays found on Sheet C-11-07 of the approved plans. Based on this discrepancy in the approved construction plans, please address which design FES-5A and Level Spreader #1 was constructed by. 3. The Developer may pump and survey the forebay if desired. See Response to #2 above. In addition to the comments regarding Level Spreader #1 above, erosion and channeling is occurring in the buffer downstream of this device. All erosion should be repaired and revegetated. Level Spreader #2 (LS-2) 1. No action required. No Comment 2. The contractor has stated this was constructed per the plan, no action is proposed. The design invert of this pipe shown on Sheet C-11.02 of the approved construction plans is 334.30. The design elevation of the level spreader is 339.0. The as-built elevation of the level spreader is approximately 339. 1, almost five feet above the design invert of FES-4A. This is not in accordance with the detail for the level spreaders and level spreader forebays found on Sheet C-1 1.07 of the approved plans. Based on this discrepancy in the approved construction plans, please address which design FES-4A and Level Spreader #2 was constructed by. 3. The Developer may pump and survey the forebay it desired. See Response to #2 above. Level Spreader #3 (LS-3) 1. No action required. No Comment 2. The contractor has stated this was constructed per the plan, no action is proposed. The design invert of this pipe shown on Sheet C-11.03 of the approved construction plans is 329.5. The design and as-built elevation of the level spreader is approximately 332.0, 2.5 feet above the design invert of FES-3A. This is not in accordance with the detail for the level spreaders and level spreader forebays found on Sheet C-11.07 of the approved construction plans. Based on this discrepancy in the approved construction plans, please address which design FES-3A and Level Spreader #3 was constructed by. 3. The Developer may pump and survey the forebay if desired. See Response to #2 above. Level Spreader #4 (LS-4) 1. The buffer impact is being addressed by KHA. Please provide us with a copy of the correspondence, plans, and DWQ approval addressing this impact. 2. KHA to provide a plan to the GC to alleviate this concern. Please provide us with a copy of the plan. 3. The Developer may pump and survey the forebay if desired. No Comment 4. The Developer may pump and survey the forebay if desired. No Comment 5. The buffer impact is being addressed by KHA. Please provide us with a copy of the documentation addressing this buffer impact. Temporary Sediment Basin Devices Sediment Basin #2 (a.k.a. Future Extended Detention Wetland "An Global comment - The Developer has requested that this pond be converted into a dry detention pond. This pond was never permitted as a permanent device as that is the Developer's responsibility. The Town of Morrisville will not allow this conversion without said permit. Leaving this device as installed is not in accordance with the approved plans in regards to closing out the grading and erosion control permits issued for Phase One. In lieu of removing these devices, conversion to dry detention basins was suggested as a less expensive alternative. 1. No action required - This is a temporary riser. No Comment 2. Basin dam should be made to conform to plans and specifications. No Comment 3. Emergency spillway should be made to conform to plans and specifications. Based on GC survey data, the width exceeds the requirements. The emergency spillway should be re-graded and stabilized in accordance with the approved plans to provide the design width of 25' at elevation 362.5. Please provide us with a copy of the GC survey for comparison. 4. No action required. No Comment 5. No action required. No Comment 6. No action required. No Comment 7. Per the survey provided by the GC, the barrel is within 2' of the design plans and rip-rap extends per plan. No action is proposed. The proximity to and angle toward the existing retaining wall is more than shown in the approved construction plans. Additional measures should be taken to protect the integrity of the existing retaining wall. Please provide us with a copy of the GC survey for comparison. 8. Per the survey provided by the GC, the rip-rap extends per plan. No action is proposed. Based on our survey this rip-rap pad does not appear to be constructed in accordance with the chart on Sheet E-5 of the approved construction plans. Please provide us with a copy of the GC survey for comparison. 9. Per the survey provided by the GC, the rip-rap extends per plan. No action is proposed. Based on our survey this rip-rap pad does not appear to be constructed in accordance with the chart on Sheet E-5 of the approved construction plans. Please provide a copy of the GC survey for comparison. 10. This device is not permitted through any jurisdiction in regards to the final design. This final design is to be designed and permitted by the Developer. No Comment Sediment Basin #7 (a.k.a. Future Extended Detention Wetland "E") Global comment - The Developer has requested that this pond be converted into a dry detention pond. This pond was never permitted as a permanent device as that is the Developer's responsibility. The Town of Morrisville will not allow this conversion without said permit. Leaving this device as installed is not in accordance with the approved plans in regards to closing out the grading and erosion control permits issued for Phase One. In lieu of removing these devices, conversion to dry detention basins was suggested as a less expensive option. An additional complicating factor for this area is the existing 36" RCP that discharges into Sediment Basin #7. If this sediment basin is removed, appropriate actions would need to be taken to ensure the discharge from this existing 36" RCP does not create any violation with the DWQ, Town of Morrisville, Durham County, or any other governing body with jurisdiction over this project. No action required - This is a temporary riser. Per the approved construction plans, the top of riser elevation should be 0.5' below the approved emergency spillway elevation. Please address how this will be handled. 2. No action required. No Comment 3. The emergency spillway should be made to conform to the plans and specifications. No Comment. 4. Install spillway per plans and provide stabilization. No Comment 5. Install outlet pipe at elevation per CCD. Please clarify that the intent is to install the outlet pipe per CCD#18 dated 5/1/09 (invert "out" of barrel at elevation 322.0). 6. Install outlet pipe at elevation per CCD. Please clarify that the intent is to install the outlet pipe per CCD#18 dated 5/1/09 (invert "out" of barrel at elevation 322.0). 7. A detail of this area will be provided to include some additional rip rap based on existing performance and some additional plantings. Please provide us with a copy of the detail. 8. Sediment Basin grading should be made to conform to plans and specifications. No Comment 9. No action required. No Comment 10. This device is not permitted through any jurisdiction in regards to the final design. This final design is to be designed and permitted by the Developer. No Comment If you have any further questions or require any additional information, please do not hesitate to call. We will be happy to assist you in any way that we can. Sincerely, Bradley Bowling, PE Priest, Craven & Associates, Inc. Cc: Jim Speake, Shiloh Morrisville, LLC 0- W nn// ? w8 z \ W z? I W W !c. ?? \\ ,?5 a ?, A v y,a ?y U n U1 ft- ? Y I ? Hill I r \ ?r < <Z 3. 1:1 O \\ '_ J 1: Z ru N W w HI •? ul I f- XF E w LU k z r I C JZq_I: ? m ?W4,? Q N ry ry u1 O -? x - N N S- lil ~ (n > x N wA d .n n Q. M p O Q 3 N IX g 0 N W W? ? ? ? N ry ? w H-jz?QN - w ??? ^ A ? Qpq Q o J? w g¢ 112 g5fill a ? ? ao®ipoameA3%?A@mee®®d6?;oz;g????P-o ? I § Nh? P North Carolina Wildlife Resources Commission 0 TO: David Baker, NCDOT Coordinator Asheville Regulatory Field Office, USACE FROM: Marla Chambers, Western NCDOT Permit Coordinator al. et a,K&a, Habitat Conservation Program, NCWRC DATE: December 18, 2009 SUBJECT: Review of NCDOT's application for a Section 404 permit to replace Bridge No. 3 on SR 1111 (West Road) over Brasstown Creek, Clay County, North Carolina. TIP No. B-4467. North Carolina Department of Transportation (NCDOT) has submitted an application to obtain a Section 404 Permit from the U.S. Army Corps of Engineers (USACE). The application indicated that written approval for a 401 Water Quality Certification from the Division of Water Quality (NCDWQ) is not required. Staff biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the information provided. These comments are provided in accordance with the provisions of the National Environmental Policy Act (42 U.S.C. 4332(2)(c)) and the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d). The NCDOT proposes to replace Bridge No. 3 on SR 111 I (West Road) over Brasstown Creek on existing alignment with an of-site detour. As our scoping comments, dated October 26, 2007, indicated, the sicklefin redhorse (Moxostoma sp. ), Federal Species of Concern (Candidate for listing as Threatened or Endangered) and state Threatened, is likely to occur in Brasstown Creek within the project area. Rainbow (Villosa iris), state SC, is also present in Brasstown Creek. Additional federal and state listed species occur downstream in the Hiwassee River. A moratorium prohibiting in-stream work continues to be recommended from April 1 to June 15 to protect the egg & fry stages of sicklefin redhorse. Sediment and erosion control will be important for this project. NCWRC can concur with the issuance of Section 404 and 401 permits provided that the following conditions are implemented: Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721 Telephone: (919) 707-0220 • Fax: (919) 707-0028 B-4467, SR 1111 (West Road) Brasstown Cr., Clay Co. -2- December 18, 2009 Sediment and erosion control measures shall adhere to the DeSn Standards fur Sensitive Watersheds and be strictly maintained until project Completion. 2. Herbaceous vegetation shall be planted on all bare soil as soon as possible following the completion of permanent or temporary ground disturbing activities to provide appropriate long-term erosion control. 3. Tall fescue and straw mulch shall not be used in riparian areas. We encourage NCDOT to utilize onsite vegetation and materials for bank stabilization when practicable. Erosion control matting shall be used on steep slopes and for establishing permanent vegetation in riparian areas and be well anchored with staples or wooden survey stakes and, whenever possible, include live stakes of native trees. 4. Stormwater, including deck drainage, should be directed to buffer areas or retention basins and should not be routed directly into the waterway. Oiik clean, sediment-free rock should he Used as temporary till (causewavs), and should be rcrrnov-ed \yithout CXCessiyc disturhanCC of the natural channel bottom yyhen construction is completed. 6. Discharge of materials into the waterway from demolition of the old bridge should be avoided as much as practicable. Any materials that inadvertently reach the water should be removed. 7. The natural dimension, pattern, and profile of the waterway above and below the crossing should not be modified by widening the channel or changing the depth of the waterway. 8. Removal of vegetation in riparian areas should be minimized. Native trees and shrubs should be planted along the banks, as appropriate to the setting, to reestablish the riparian zone and to provide long-term erosion control. 9. Grading and backfilling should be minimized, and tree and shrub growth should be retained if possible to ensure long term availability of shoreline cover for fish and wildlife. Backfill materials should be obtained from upland sites. 10. Riprap placed for bank stabilization should be limited to the banks below the high water mark, and vegetation should be used for stabilization above the high water elevation. 11. If concrete will be used during construction, work must be accomplished so that wet (uncured) concrete does not contact surface waters. This will lessen the chance of altering the water chemistry and causing a fish kill. 12. Discharging hydroseeding mixtures and washing out hydroseeders and other equipment in or adjacent to surface waters is strictly prohibited. B-4467, SR 1111 (West Road) Brasstown Cr., Clay Co. -3 - December 18, 2009 13. Heavy equipment should be operated from the bank rather than in the channel whenever possible in order to minimize sedimentation and reduce the likelihood of introducing other pollutants into the waterway. All mechanized equipment operated near surface waters should be inspected and maintained regularly to prevent contamination of surface waters from fuels, lubricants, hydraulic fluids or other toxic materials. 14. The existing roadway that is to be eliminated should be removed back to original ground elevations and the natural floodplain elevations and functions should be restored. 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'. Thank you for the opportunity to review and comment on this project. If you have any questions regarding these comments, please contact me at (704) 485-8291. cc: Troy Wilson, USFWS Brian Wrenn, NCDWQ Mike Parker, NCDWQ Carla Dagnino, NCDOT Elizabeth Lusk, NCDOT