20120747 Ver 1_Mitigation Plan Review_20120815

Strickland, Bev
From: Kulz, Eric
Sent: Wednesday, August 15, 2012 12:53 PM
To: Witherspoon, Lauren
Cc: Strickland, Bev
Subject: Devils Racetrack - Johnston Co. (12 -0747)
Attachments: 12 -0747 Devils Racetrack Draft Mit plan comments 8- 15- 12.docx
See my comments attached. Let me know once you have looked at it if you want to enter the comments or if you want
me to.
Eric W. Kulz
Environmental Senior Specialist
N.C. Division of Water Quality
Program Development Unit
1650 MSC
Raleigh, NC 27699 -1650
Phone: [phone] Please note this is a new phone number effective May 10, 2012
Fax: [phone]
E -mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties

Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman
Governor Director Secretary
MEMO
From: Eric Kulz — WPDU
To: Lauren Witherspoon — RRO
Project File
Date: 8/15/12
Re: Devil's Racetrack Mitigation Site — Johnston County
DWQ 4 12 -0747
Hey Lauren:
The following are my comments for the EEP portal on the draft Mitigation Plan for this site.
1) Several potential problem areas were identified that warrant concern. Significant cut is
proposed along the eastern downstream reach of Devil's Racetrack Creek. Between four
and 10 feet of cut are proposed to bring the stream down to the invert of the Neu se River.
In addition, a gravel road located parallel to Devil's Racetrack Creek East is proposed for
removal. Both of these areas will need significant attention if survival and growth of
vegetation is successful. Side slopes along the cut areas should be very gradual, and
retention of topsoils is recommended, as is aggressive planting. These areas will require
frequent monitoring to watch for erosion/rilling. Also, road bed removal areas are
frequently areas where vegetation does not do well due to compaction. These areas will
need to be addressed.
2) The plan proposes growing sod mats of Bermuda grass (Cynodon sp.) and overseeding
with native seeds, cutting these mats and using them for streambank stabilization.
Bermuda grass, while not listed as a noxious weed, is indicated on the USDA plants
website as "can be weedy or invasive ". The provider should consider a native species in
place of Bermuda grass.
3) The plan states that longitudinal profiles will not be performed unless indications of
vertical or lateral instability are identified during monitoring. Without a baseline
longitudinal profile, later profiles will not have any data with which to compare.
1617 Mail Service Center, Raleigh, North Carolina 27699 -1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone :919- 807 - 6300 \ FAX :919 - 807 -6492
Internet: www.ncwatergualitv.org
An Equal Opportunity 1 Affirmative Action Employer

Comments of Devil's Racetrack Site — Johnston Co.
8/15/12
Page 2 of 2
A longitudinal profile of the thalweg, water surface, bankfull, and top of bank, should be
collected during the as -built survey of the constricted channel to compare with future
geomorphological data, if necessary. Longitudinal profiles shall not be required during
routine monitoring (years 1 through 7) unless the monitoring efforts demonstrate channel
bank or bed instability, in which case additional longitudinal profiles can be collected and
compared with as -built data.
4) The plan calls for annual measurement of cross - sections. Due to the increased of the
monitoring period from five to seven years, DWQ recommends monitoring of cannel
cross - sections at the as -buit survey, and then in years 1, 2, 3, 5, and 7.
5) No information on the delineation of the easement boundary was included in the plan.
Please provide information on the type of fencing (if used) and /or other easement
marking methods to ensure encroachment into the conservation easement does not occur.
1617 Mail Service Center, Raleigh, North Carolina 27699 -1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone :919- 807 - 6300 \ FAX :919 - 807 -6492
Internet: www.ncwatergualitv.org
An Equal Opportunity 1 Affirmative Action Employer