20121107_Environmental Assessment Comments_20111129

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NCDEI��
No�th Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H Sullins Dee Freeman
Governor Director Secretary
November 29 2011
MEMORANDUM
To Marc Hamel Manager of Environmental Programs NCDOT Rail
From Amy Euliss Division of Water Quality Winston Salem Regional Office
Sub�ect Comments on the Environmental Assessment related to proposed construction of a
second track and safety improvements along the NCRR from Salisbury (Reid) to
Kannapolis (N Kannapolis) m Rowan County TIP P 5206 WBS No
52000 1 STR02T2
This office has reviewed the referenced document dated October 2011 The NC Division of Water
Quality (NCDWQ) 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 understandmg that the pro�ect as
presented will result m impacts to�urisdictional wetlands streams and other surface waters NCDWQ
offers the following comments based on review of the aforementioned document
Pro�ect Specific Comments
Town Creek and Irish Buffalo Creek are class C 303(d) waters of the State in the pro�ect study area
Town Creek is on the 2010 303(d) list for impaired use for aquatic life due to ecological and
biological mtegrity Irish Buffalo Creek is listed for copper ecological and biological integrity and
turbidiTy NCDWQ is very concerned with sediment and erosion impacts that could result from this
pro�ect NCDWQ recommends that the most protective sediment and erosion control BMPs be
implemented in accordance with Deszgn Standards in Sensitrve Watersheds to reduce the nsk of
nutrient runoff to Town Creek Irish Buffalo Creek and their unnamed tributaries NCDWQ requests
that rail and 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
Practrces
2 Review of the pro�ect reveals the presence of surface waters classified as Water Supply Critical Area
in the pro�ect study area Given the potential for impacts to these resources during the pro�ect
implementation NCDWQ requests that NCDOT strictly adhere to North Carolina regulations entrtled
Design Standards in Sensitive Watersheds (15A NCAC 04B 0124) throughout design and
construction of the pro�ect This would apply for any area that drams to streams having WS
CA(Water Supply Crrtical Area) classifications
3 Should the pro�ect be located within the Crrtical Area of a Water Supply NCDOT may be required to
design construct and maintam hazardous spill catch basins m the pro�ect area The number of catch
basins mstalled shall be determined by the design of the stream crossings so that runoff would enter
said bastn(s) rather than flowmg dtrectly mto the stream and in consultation wrth NCDWQ
North Carolina Dwision of Water Quality Winston Salem Regional Office
Location 585 Waughtown St Winston Salem North Carolina 27107 �pe
Phone [phone] FAX [phone] Customer Service 1 877-623 6748 NorthCarolina
Internet www ncwaterquality org �atur�rll�
An Equal Opportunity 1 Affirmative Action Employer

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General Comments
The environmental document shall provide a detailed and rtemized presentation of the proposed
impacts to wetlands and streams with corresponding mappmg If mrtigation is necessary as required
by 15A NCAC 2H 0�06(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 Envtronmental assessment alternatives shall constder design cnteria that reduce the impacts to
streams and wetlands from storm water runoff These alternatives shall include rail and road
designs that allow for treatment of the storm water runoff through best management practices as
detatled n1 the most recent version of NCDWQ s Storf�lwater I3est Manageme��f 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 the NCDOT is respectfully remmded that they will need to demonstrate the avoidance
and mmimization of impacts to wetlands (and streams) to the maximum extent practical In
accordance wrth 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
mrtigatton is required the mrtigation plan should be designed to replace appropriate lost functions
and values The NC Ecosystem Enhancement Program may be available for use as wetland
mrtigation
In accordance wrth the Environmental Management Commission s Rules { 15A NCAC
2H 0506(h)} mrtigation 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 mrtigation
Future documentation mcluding the 401 Water Quality Certification Application should contmue
to include an rtemized listing of the proposed wetland and stream impacts with correspondmg
mapping
NCDWQ is very concerned wrth sediment and erosion impacts that could result from this pro�ect
NCDOT shall address these concerns by descnbing the potential impacts that may occur to the
aquatic environments and any mrtigating factors that would reduce the impacts
7 An analysis of cumulative and secondary impacts anticipated as a result of this pro�ect is required
The type and deta�l of analysis shall conform to the NC Division of Water Quality Policy on the
assessment of secondary and cumulative impacts dated April 10 2004
8 NCDOT is respectfully reminded that all impacts mcluding but not limited to bridg�ng fill
excavation and clearmg and rip rap to �urisdictional wetlands streams and riparian buffers need to
be included in the final impact calculations These impacts in addrtion to any construction impacts
temporary or otherwise also need to be included as part of the 401 Water Qualrty Certtfication
Application
9 Where streams must be crossed NCDWQ prefers bridges be used m lieu of culverts However we
realize that economic considerations often requtre the use of culverts Please be adv�sed that

— -��
N�DENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H Sullins Dee Freeman
Govemor Director Secretary
November 29 2011
MEMORANDUM
To Marc Hamel Manager of Environmental Programs NCDOT Rail
From Amy Euliss Division of Water Quality Winston Salem Regional Office
Sub�ect Comments on the Environmental Assessment related to proposed construction of a
second track and safety improvements along the NCRR from Salisbury (Reid) to
Kannapolis (N Kannapolis) in Rowan County TIP P 5206 WBS No
52000 1 STR02T2
This office has reviewed the referenced document dated October 2011 The NC Division of Water
Quality (NCDWQ) 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 pro�ect as
presented will result m impacts to�urisdictional wetlands streams and other surface waters NCDWQ
offers the following comments based on review of the aforementioned document
Pro�ect Specific Comments
Town Creek and Irish Buffalo Creek are class C 303(d) waters of the State in the pro�ect study area
Town Creek is on the 2010 303(d) list for impaired use for aquatic life due to ecological and
biological integrity Irish Buffalo Creek is listed for copper ecological and biological integrity and
turbidity NCDWQ is very concerned wrth sediment and erosion impacts that could result from this
pro�ect NCDWQ recommends that the most protective sediment and erosion control BMPs be
implemented in accordance wrth Design Standards rn Sensitive Watersheds to reduce the risk of
nutrient runoff to Town Creek Irish Buffalo Creek and their unnamed tributaries NCDWQ requests
that rail and 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
Review of the pro�ect reveals the presence of surface waters classified as Water Supply Crrtical Area
m the pro�ect study area Given the potential for impacts to these resources during the pro�ect
implementation NCDWQ requests that NCDOT strictly adhere to North Carolina regulations entrtled
Design Standards in Sensitive Watersheds' (15A NCAC 04B 0124) throughout design and
construction of the pro�ect This would apply for any area that drains to streams having WS
CA(Water Supply Critical Area) classifications
3 Should the pro�ect be located wrthin the Crrtical Area of a Water Supply NCDOT may be required to
design construct and maintain hazardous spill catch basins in the pro�ect area The number of catch
basins installed shall be determined by the design of the stream crossings so that runoff would enter
said basin(s) rather than flowing directly mto the stream and m consultat►on with NCDWQ
North Carolina Dwision of Water Quality Winston Salem Regional O�ce
Location 585 Waughtown St Winston Salem North Carolina 27107 �pe
Phone [phone] FAX [phone] Customer Serwce 1 877-623 6748 NorthCarollna
Intemet www ncwaterquality org � ^���'!N� //�
An Equal Opportunity 1 Affirmative Action Employer v'/ ��� "

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+! culverts shall 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 mstall the bridge bents in the creek to the
maximum extent practicable
10 Whenever possible NCDWQ prefers spanning structures Spanning structures usually do not
require work withm 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 navigatton by canoeists and boaters shall
not be blocked Bridge supports (bents) shall not be placed in the stream when possible
11 Bridge deck drains shall not discharge directly mto the stream Stormwater shall be directed across
the bndge and pre treated through srte appropnate means (grassed swales pre formed scour holes
vegetated buffers etc ) before entermg the stream Please refer to the most current version of
NCDWQ s Stormwater Best Management Practices
12 Sediment and erosion control measures shall not be placed in wetlands or streams
13 Borrow/waste areas shall avoid wetlands to the maximum extent practical Impacts to wetlands in
borrow/waste areas will need to be presented m the 401 Water Quality Certification and could
precipitate compensatory mitigation
14 The 401 Water Quality Certification application will need to specifically address the proposed
methods far stormwater management More specifically stormwater shall not be permitted to
discharge directly mto streams or surface waters
15 Based on the information presented in the document the magnrtude of impacts to wetlands and
streams may require an Individual Permrt (IP) application to the Corps of Engineers and
corresponding 401 Water Quality Certification Please be advised that a 401 Water Quality
Certificahon 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 NCDWQ Please be aware
that any approval will be contingent on appropriate avoidance and mmimization of wetland and
stream impacts to the maximum extent practical the development of an acceptable stormwater
management plan and the inclusion of appropriate mrtigation plans where appropriate
16 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 tnadvertently contacts uncured concrete shall
not be discharged to surface waters due to the potential for elevated pH and possible aquatic life and
fish kills
17 If temporary access roads or detours are constructed the srte shall be graded to rts preconstructton
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 Clearmg 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 mmimizes so�l disturbance
18 Placement of culverts and other structures m waters streams and wetlands shall be placed below
the elevation of the streambed by one foot for all culverts w�th a diameter greater than 48 inches

and 20 percent of the culvert diameter for culverts having a diameter less than 48 mches 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 m
dis equilibnum of wetlands or streambeds or banks ad�acent to or upstream and down stream of the
above structures The applicant is required to provide evidence that the equilibrium is bemg
maintamed if requested in wrrting by NCDWQ If this condrtion is unable to be met due to bedrock
or other limiting features encountered during construction please contact the NCDWQ for guidance
on how to proceed and to determine whether or not a permit modification will be required
19 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 floodplam benches and/or
sills may be required where appropriate Widening the stream channel shall be avoided Stream
channel widening at the mlet or outlet end of structures typically decreases water veloc�ty causmg
sediment deposition that requires increased maintenance and disrupts aquatic life passage
20 If foundatton test borings are necessary it shall be noted in the document Geotechnical work is
approved under Genera1401 Certification Number 3687/Nationwide Permit No 6 for Survey
Activities
21 Sediment and erosion control measures sufficient to protect water resources must be implemented
and maintained m accordance wrth the most recent version of North Carolina Sediment and Eroston
Control Planning and Design Manual and the most recent version of NCS000250
22 All work m or ad�acent to stream waters shall be conducted in a dry work area Approved BMP
measures from the most current version of NCDOT Construchon and Mamtenance Activrties
manual such as sandbags rock berms cofferdams and other diversion structures shall be used to
prevent excavation tn flowmg water
23 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 mherent
inaccuracies require that qualified personnel perform onsrte wetland delineations prior to permit
approval
24 Heavy equipment shall be operated from the bank rather than in stream channels m order to
minimize sedimentation and reduce the likelihood of introducmg other pollutants into streams This
equipment should be inspected daily and maintained to prevent contamination of surface waters
from leaking fuels lubricants hydraulic fluids or other toxic materials
25 Riprap shall not be placed m the active thalweg channel or placed m the streambed in a manner that
precludes aquatic life passage Bioengineering boulders or structures shall be properly designed
sized and mstalled
26 Riparian vegetation (native trees and shrubs) shall be preserved to the maximum extent possible
Riparian vegetation must be reestablished within the construction limits of the pro�ect by the end of
the growing season followmg completion of construction
NCDWQ appreciates the opportunity to provide comments on your pro�ect Shall you have any questions
or require any additional information please contact Amy Euliss at [phone]

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�� cc John Thomas US Army Corps of Engineers Raleigh Field Office
Chris Milistcher Environmental Protection Agency (electronic copy only)
Marla Chambers NC Wildlife Resources Commission (electronic copy only)
Wetlands/ 401 Transportation Permitting Unrt
File Copy