U-4414 (4)

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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E Dee Freeman
Governor Director Secretary
April 16, 2012
MEMORANDUM
To: Gregory J. Thorpe, Ph.D., Manager, Project Development and Environmental Analysis
Unit, North Carolina Department of Transportation.
From: Mason Herndon, Division of Water Quality, Fayetteville Regional Office /��f
Subject: Comments on the Environmental Assessment related to proposed widening of All
American Freeway (SR 1007) from existing Owen Drive to the proposed Fayetteville
Outer Loop, Cumberland County, Federal Aid Proj ect No. NHF-1007(13 ), WBS No.
39054.1.1, TIP U-4414.
This office has reviewed the referenced document dated December, 2012. 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 proj ect as
presented will result in impacts to jurisdictional wetlands, streams, and other surface waters. NCDWQ
offers the following comments based on review of the aforementioned document:
Project Specific Comments:
1. This project may become part of the 404/NEPA Merger Process. As a participating team member,
NCDWQ will work with the team.
2. Section II B.7 states that there are four existing hydraulic structures within the proposed project
limits. In Section IV.H, the EA states that "The four existing culverts will be retained and
extended." However, in Table 11 on page 18 of the document, only one of the stream systems listed
in Table 1 in Section II B.7 has impacts listed. The EA should clearly identify the systems that will
be impacted and provide a description of the proposed impacts.
3. The EA states that the proposed project will impact 384 linear feet of perennial stream at Buckhead
Creek. The EA also states on page 18 that the proj ect will likely qualify for a Nationwide 14. If the
proj ect has more than 3 00 linear feet of permanent stream impact, it will exceed the threshold limits
of Nationwide 14 and therefore would require an Individual Permit and not a Nationwide 14 as
stated on page 18.
4. Table 11 on Page 18 has a footnote that states "A portion of this stream is mitigable." It is unclear
why only a portion of the proposed impacts to this perennial system will require mitigation. The
EA should elaborate on this statement or omit the statement from the document.
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General Comments:
5. The environxnental document should 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 environxnental documentation. Appropriate mitigation plans will be required priar to
issuance of a 401 Water Quality Certification.
6. Environxnental impact statement 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 treahnent of the storm water runoff through best mana gement practices as detailed in the
most recent version of NCDWQ's Stormwater BestManagement Practices Manual, July 2007, such
as grassed swales, buffer areas, preformed scour holes, retention basins, etc.
After the selection of the preferred alternative and priar to an issuance of the 401 Water Quality
Certification, the 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.
8. 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.
9. 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.
10. 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 environxnents and any mitigating factors that would reduce the impacts.
11. An analysis of cumulative and secondary impacts anticipated as a result of this project is required.
The type and detail of analysis shall conform to the NC Division of Water Quality Policy on the
assessment of secondary and cumulative impacts dated April 10, 2004.
12. NCDOT is respectfixlly reminded that all impacts, including but not limited to, bridging, fill,
excavation and clearing, and rip rap 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.
13. Where streaxns must be crossed, NCDWQ 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 streaxns are impacted, a bridge may prove
preferable. When applicable, NCDOT should not install the bridge bents in the creek, to the
maximum extent practicable.
14. Whenever possible, NCDWQ prefers spanning structures. Spanning structures usually do not
require wark within the stream or grubbing of the streambanks and do not require stream channel

realignxnent. 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 supparts (bents) should not be placed in the stream when possible.
15. 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 BestManagementPractices.
16. Sediment and erosion control measures should not be placed in wetlands or streaxns.
17. Borrow/waste areas should avoid wetlands 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.
18. 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 streaxns or surface waters.
19. Based on the information presented in the document, the magnitude of impacts to wetlands and
streams may require an Individual Permit application to the Corps of Engineers and corresponding
401 Water Quality Certification. 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 NCDWQ. Please be aware that any
approval will be contingent on appropriate avoidance and minimization of wetland and stream
impacts to the maximum �tent practical, the development of an acceptable stormwater
management plan, and the inclusion of appropriate mitigation plans where appropriate.
20. 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.
2L 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 ravegetate
naturally and minimizes soil disturbance.
22. Unless otherwise authorized, placement of culverts and other strucbxres in waters and streamsshall
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 conta ct
NCDWQ for guidance on how to proceed and to determine whether or not a permit modification
will be required.
23. 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, floodplain benches, and/or

sills may be required where appropriate. Widening the stream channel should be avoided. Stream
channel widening at the inlet or outlet end of strucbxres typically decreases water velocity causing
sediment deposition that requires increased maintenance and disrupts aquatic life passage.
24. If foundation test borings are necessary; it shall be noted in the document. Geotechnical wark is
approved under Genera1401 Certification Number 3883/Nationwide Permit No. 6 for Survey
Activities.
25. 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 recentversion of NCS000250.
26. All wark in or adjacent to stream waters shall be conducted in a dry wark area. Approved BMP
measures from the most current version of NCDOT Construction and Maintenance Activities
manual such as sandbags, rock berxns, cofferdaxns and other diversion structures shall be used to
prevent excavation in flowing water.
27. While the use of National Wetland Inventory (NWI) maps, NC Coastal Region Evaluation of
Wetland Significance (NGCREWS) maps and soil survey maps are useful tools, their inherent
inaccuracies require that qualified personnel perform onsite wetland delineations priar to permit
approval.
28. Heavy equipment should 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.
29. 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.
30. 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 project by the end of
the growing season following completion of construction.
NCDWQ appreciates the opportunity to provide comments on your project. Shall you have any questions
or require any additional information, please contact me at [phone].
cc: Clarence Coleman, Federal Highway Administration
Greg Burns, PE, Division 6 Engineer
William D. Gilmore, PE, Ecosystem Enhancement Program
File Copy
ec: Ronnie Smith, US Army Corps of Engineers, Wilmington Field Office
Jim Rerko, Division 6 Environmental Officer
Chris Militscher, Environxnental Protection Agency
Travis Wilson, NC Wildlife Resources Commission
Belinda Henson, DWQ Fayetteville Regional Office
Sonia Carrillo, DWQ Central Office