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Home My WebLink AboutUS 421Beverly Eaves Perdue Governor Iff U It 9 ._►ll LY A M=X' NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Coleen H Sullins Director December 29 2011 To Greg Thorpe NCDOT (c /o Marshall Edwards) From Amy Euliss NC Division of Watei Quality Office Dee Freeman Secretary Subject Start of Study comments on proposed improvements to US421 from SR 1226 (Westgate Drive) to the Yadkin River in Wilkes County Federal Aid Project No NHS 0421 (72) TIP U 5312 Reference your correspondence dated December l 2011 in which you requested comments for the referenced project Preliminary analysis of the project reveals the potential for multiple impacts to streams and jurisdictional wetlands in the project area More specifically impacts to Stream Name River Basin Stream Stream Index 303(d) Listing Classifications Number UTs to Yadkin Yadkin Pee WSIV 12 34 Not listed River Dee UT to Fish Dam Yadkin Pee WSIV 12 35 Not listed Creek Dee Millers Creek Yadkin —Pee WSIV 12 36 Not listed and UT Dee Tucker Hole Yadkin —Pee WSIV Tr CA 12 37 (2) Not listed Creek Dee Yadkin River Yadkin Pee C 12 (38) Not listed Dee Further investigations at a higher resolution should be undertaken to verify the presence of other streams and /or jurisdictional wetlands in the area In the event that anyjurisdictional areas are identified the Division of Water Quality requests that NCDOT consider the following environmental issues for the proposed project Project Specific Comments Review of the ptoject reveals the presence of surface waters classified as Water Supply Critical Area in the project studv area Given the potential for impacts to these resources during the project implementation NCDWQ requests 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 This would apply for any area that drains to streams having WS CA(Water Supply Critical Area) classifications North Carolina Division of Water Quality Winston Salem Regional Office Location 585 Waughtown St Winston Salem North Carolina 27107 Phone 336 771 5000 \ FAX 336 771 -4630 \ Customer Service 1 877 623 6748 Internet www ncwaterquality org An Equal Opportunity \ Affirmative Action Employer NorthCarohna Naturally Should the bridge project be located within the Critical Area of a Water Supply NCDOT may be required to design construct and maintain hazardous spill catch basins in the project area The number of catch basins installed shall be determined by the design of the bridge so that runoff would enter said basin(s) rather than flowing directly into the stream and in consultation with NCDWQ Tucker Hole Creek are class WS IV CA Tr waters of the State NCDWQ recommends that the most protective sediment and erosion control BMPs 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 NC Division of Land Resources and NC Wildlife Resources Commission requirements General Project Comments 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 2H 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 11lIanagement 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 Zn 4 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 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 ZD 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 1 I 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 iri 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 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 floodplam 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 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 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 In most 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 (336) 771 4959 cc Monte Matthews US Army Corps of Engineers Raleigh Field Office Federal Highway Administration Chris Milrtscher Environmental Protection Agency (electronic copy only) Marla Chambers NC Wildlife Resources Commission (electronic copy only) Wetlands/401—Transportation Permitting Unit File Copy