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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
April 11, 2011
MEMORANDUM
To: Ivan Dishman, NCDOT Division Bridge Program Manager
From: Amy Euliss, NC Division of Water Quality, Office
Subject: Scoping comments on proposed replacement of Bridge no. 316 in Caldwell County, no. 89 in
Surry County, no. 108 in Watauga County, nos. 11, 100, 641, and 688 in Wilkes County, and
nos. 79 and 154 in Yadkin County.
Dee Freeman
Secretary
Reference your correspondence dated March 8, 2011 in which you requested comments for the referenced
projects. The NCDWQ offers the following comments.
Project Specific Comments:
BD-51 1 IL, Bridge No. 316 over Lower Creek (Class C), Caldwell County
1. Lower Creek are class C; 303(d) waters of the State. Lower Creek is on the 303(d) list for impaired
use for aquatic life due to impaired ecological and biological integrity. 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 Lower 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.
BD-51 I IM, Bridge No. 89 over Moores Fork (Class WSIV), Sum County
*No project specific conditions.
BD-51I IN, Bridge No. 108 over Cove Creek (Class C), Watauga County
*No project specific conditions.
BD-51110. Bridge No. 11 over North Little Hunting Creek (WSIII). Wilkes Countv
*No project specific conditions.
BD-51 1 1 P, Bridge No. 100 over Purlear Creek (WSfV), Wilkes Countv
*No project specific conditions.
BD-5111Q, Bridge No. 641 over Little Elkin Creek (WSfV), Wilkes County
*No project specific conditions.
BD-51 1 1 R, Bridge No. 688 over Grassy Fork (WSII, HOW), Wilkes County
1. Review of the project reveals the presence of surface waters classified asWSII; High Quality Waters
of the State in the project study area. This is one of the highest classifications for water quality.
North Carolina Division of Water Quality, Winston-Salem Regional Office
Location: 585 Waughtown St. Winston-Salem, North Carolina 27107
Phone: 336-771-50001 FAX: 336-771-06301 Customer Service: 1-877$23-6748
Internet www.ncwaterquality.org
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An Equal Opportunity 1 Affirmative Acton Employer
Pursuant to 15A NCAC 2H. 1006 and 15A NCAC 2B .0224, NCDOT will be required to obtain a
State Stormwater Permit prior to construction except in North Carolina's twenty coastal counties.
BD-51 1IS, Bridge No 79 over Tanvard Creek (Class C), Yadkin County
*Please note that the classification and the stream index number in the Low Impact Data sheet are
incorrect. Class C is the appropriate classification, and 12-64 is the appropriate stream index number.
BD-51 11T Bridge No 154 over North Deep Creek (Class C), Yadkin County
*No project specific conditions.
General Project Comments:
1. Proposed impacts suggest that this project will be permitted using a Nationwide 3 from the US Army
Corps of Engineers. NCDWQ would like to respectively remind NCDOT that WQC 3687, or its
most recent equivalent, will also be required. NCDOT shall be in compliance with all of its
applicable conditions.
2. DWQ understands that these bridges will be replaced using an off-site detour, if at any time these
plans change, DWQ shall be contacted to determine if this project shall remain in the Low-Impact
Bridge Replacement process.
Currently proposed impacts will not exceed 150 linear feet of impacts to any single stream. However,
if at any point in the future the impact totals change, then in accordance with the Environmental
Management Commission's Rules { 15A NCAC 2H.0506(h)}, mitigation will be required for impacts
of greater than 150 linear feet to any single 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.
4. 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.
5. 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.
6. 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.
7. 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.
8. 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.
9. 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.
10. 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.
11. 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.
12. 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 of NCDOT
Construction and Maintenance Activities manual such as sandbags, rock berms, cofferdams and other
diversion structures should be used to prevent excavation in flowing water.
13. Sediment and erosion control measures shall not be placed in wetlands and streams.
14. Borrow/waste areas shall avoid wetlands to the maximum extent practical. Impacts to wetlands in
borrow/waste areas could precipitate compensatory mitigation.
15. 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.
16. 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 (336) 771-4959.
cc: Monte Matthews, US Army Corps of Engineers, Raleigh Field Office, e-copy only
Heath Slaughter, Division 11 Environmental Officer, e-copy only
Marla Chambers, NC Wildlife Resources Commission, e-copy only
Wetlands/401 Transportation Permitting Unit
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