20150546 Ver 1_Scoping Comments_20110113

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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Dualily
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
January 26, 2011
MEMORANDUM
TO: Natalie Lockhart, Bridge Project Planning Engineer, NCDOT
FROM: Michael R. Parker, NCDWQ, Asheville Regional Office Of
SUBJECT: Bridge Scoping Review Comments
B-5403 Bridge No. 196, Transylvania County
B-5404 Bridge No. 136, Jackson County
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Jn reply to your letter dated December 30, 2010 in which you requested comments for the above
referenced projects, the NCDWQ offers the following:
Project Specific Comments
B-5403 Bridge No. 196 over Crab Creek, Transylvania County
1. Crab Creek is class C-Trout-HQW waters of the State. NCDWQ recommends that the most
protective sediment and erosion control BMP's be implemented to reduce the risk of turbidity
violations in trout waters. In addition, all disturbances within trout buffers shall be conducted in
accordance with the NC Division of Land Resources and NC Wildlife Resources Commission.
2. Should NC Wildlife Resources Commission (NCWRC) identify these waters as naturally reproducing
trout waters, NCDOT will be required to observe the NCWRC -recommended moratoria for trout. In
additions, NCDWQ will require that NCDOT strictly adhere to North Carolina regulations entitled
"Design Standards in Sensitive Watersheds" [15A NCAC 04B .0124] throughout design and
construction of the project.
3. NCDOT may be required to obtain a State Stormwater Permit for this project in accordance with 15A
NCAC 2H.1000. This will depend on the impervious surface of the new bridge.
4. There appears to be a small stream parallel to north side of NCSR 1532. The water flows into Crab
Creek just downstream of the existing bridge. Since there was melting snow from the recent snow
storm it was difficult to make a stream determination at the time of site visit. Further investigation of
this stream/ditch will need to be made at a later date.
B-5404 Bridge No. 136 over Pine Creek, Jackson County
1. Big Pine Creek is class WS-III-Trout @ waters. NCDWQ recommends that the most protective
sediment and erosion control BMP's be implemented to reduce the risk of turbidity violations in trout
waters. In addition, all disturbances within trout buffers shall be conducted in accordance with the
NC Division of Land Resources and NC Wildlife Resources Commission.
SURFACE WATER PROTECTION SECTION-Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, North Carolina 28778-8211
Phone: [phone] FAX: [phone]
Customer Service: 1-877823-6748
Internet: www.ncwaterquality.org
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2. Should NC Wildlife Resources Commission (NCWRC) identify these waters as naturally reproducing
trout water's, NCDOT will be required to observe the NCWRC recommended moratoria for trout. In
additions, NCDWQ will require that NCDOT strictly adhere to North Carolina regulations entitled
"Design Standards in Sensitive Watersheds" [15A NCAC 04B .0124] throughout design and
construction of the project.
3. The supplemental classification noted by the @ symbol in the stream classification indicates that
these waters are subject to HWQ Standards and in accordance with Title 15A NCAC 0.213 .0224,
NCDOT may be required to obtain a State Stormwater Permit for this project in accordance with 15A
NCAC 21-1.1000. This will depend on the impervious surface of the new bridge. Further discussions
may be required to determine if a State Stormwater Permit is needed for this project.
4. There appears to be two areas of wetlands adjacent to the project area. The first area is located on
each side of Pine Creek on the downstream side of the bridge. The second area is located near the
intersection of NCSR 1145 and NCSR 1163, on the downstream side of NCSR 1163 adjacent to an
unnamed tributary to Pine Creek.
General Comments Regarding Bridge Replacement Projects
In accordance with the Environmental Management Commission's Rules ( 15A NCAC 21-1.0506 (h)),
mitigation will be required for impacts of greater than 150 linear feet to any single perennial or
intermittent stream. In the event that mitigation is required, the mitigation plan shall be designed to
replace appropriate lost function and values. The NC Ecosystem Enhancement Program may be
available for use as stream mitigation.
2. 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.
3. NCDWQ is very concerned with sediment and erosion impacts that could result from these projects.
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.
4. NCDOT 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.
5. Where streams must be crossed, the DWQ 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, NCDOT should not install the bridge bents in the stream, to the maximum extent
practicable.
6. Sediment and erosion control measures should not be placed in wetlands or streams.
Borrow/waste areas should avoid wetland 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.
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.

9. 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
permit authorization will require the submittal of a formal application by the NCDOT and written
concurrence from the NCDWQ. 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.
10. If foundation test borings are necessary; it shall be noted in the document Geotechnical work is
approved under General 401 Certification Number 3687/Nationwide Permit No. 6 for Survey
Activities.
11. Whenever possible, NCDWQ prefers spanning structures. Spanning structures usually do not require
work within the stream or grubbing of the stream banks 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.
12. 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.
13. Strict adherence to the most recent version of NCDOT's Best Management Practices For Bridge .
Demolition and Removal approved by the US Army Corps of Engineers is a condition of the 401 Water
Quality Certification.
14. Bridge piles and bents shall be constructed using driven piles (hammer or vibratory) or drilled shaft
construction methods. More specifically, jetting or other methods of pile driving are prohibited without
prior written approval from NCDWQ first.
15. No drill slurry or water that has been in contact with uncured concrete shall be allowed to enter surface
waters. This water shall be captured, treated, and disposed of properly.
16, All pile driving or drilling activities shall be enclosed in turbidity curtains unless otherwise approved by
NCDWQ in this certification.
17. All bridge construction shall be performed from the existing bridge, temporary work bridges, temporary
causeways, or floating or sunken barges. If work conditions require barges, they shall be floated into
position and then sunk. The barges shall not be sunk and then dragged into position. Under no
circumstances should barges be dragged along the bottom of the surface water.
18. 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 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.
19. 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.
20. Heavy equipment shall be operated from the banks rather than in the stream channel in order to
minimize sedimentation and reduce the introduction of other pollutants into the stream. 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. 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.
22. 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.
23. In most cases, the NCDWQ prefers the replacement of the existing structure at the same location with
road closure. If road closure is not feasible, a temporary detour shall 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 shall 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.
General Comments if Replacing the Bridge with a Culvert
Placement of culverts and other structures in waters, streams, and wetlands 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, 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 NCDWQ. 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.
2. 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 and/or sills 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.
3. 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 shall be properly designed, sized
and installed.
Thank you for the opportunity to provide comments 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 Mike Parker at 828-296-4500.
cc: Lori Beckwith, USACE, Asheville Field Office
Joshua B. Deaton, NCDOT, Division 14 Bridge Manager
Mark Davis, NCDOT, Division 14 Environmental Officer
Marla Chambers, NCWRC
Transportation Permitting Unit
Scoping Comments of B-5403 and B-5404