U-4414 (6)

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 N//
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 Project 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 project 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 Asa 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 project will likely qualify for a Nationwide 14 If the
project has more than 300 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 environmental 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 environmental documentation Appropriate mitigation plans will be required prior to
issuance of a 401 Water Quality Certification
6 Environmental 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 treatment of the storm water runoff through best management practices as detailed in the
most recent version of NCDWQ s Stormwater Best Management Practices Manual July 2007 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 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)l
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)l 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
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 environments and any mitigating factors that would reduce the impacts
I 1 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 respectfully 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 streams 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 streams 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 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) 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 Best Management Practices
16 Sediment and erosion control measures should not be placed in wetlands or streams
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 streams 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 extent 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
21 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 re vegetate
naturally and minimizes soil disturbance
22 Unless otherwise authorized placement of culverts and other structures in waters and streamsshalI
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 contact
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 floodplam 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 structures 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 work is
approved under General 401 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 recent version of NCS000250
26 All work in or adjacent to stream waters shall be conducted in a dry work area 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 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 (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
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 Environmental Protection Agency
Travis Wilson NC Wildlife Resources Commission
Belinda Henson DWQ Fayetteville Regional Office
Sonia Carrillo DWQ Central Office
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