20181716_Scoping Reivew Comments_20150604

Beverly Eaves Pertlue
Governor
MEMORANDUM
TO:
FROM:
SUBJECT
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North Carolina Department of Enviranment and Natural Resources
Division of �Nater Quality
Charies �Nakild, P.E.
Director
May 30, 2012
Josh Deyton, Division 14 Bridge Manager, NCDOT
Michael R. Parker, NCDWQ, Asheville Regional Office ��
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Division 14 2012 Bridge Replacement Program Scoping Review Comments
In reply to your request, the NCDWQ offers the following comments for the projects listed below:
Proiect Specific Comments
430175 Bridge No. 175'over Big Creek, NCSR 1332, Haywood County
430174 Bridge No. 174 over Big Creek, NCSR 1332, Haywood County
l. Big Creek is classified as C-trout HQW waters. NCDWQ recommends that the most protective
sediment and erosion control BMP's 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 the
NC Division of Land Resources and NC Wildlife Resources Commission.
2. Should NC Wildlife Resources Commission (NCWRC) identify these waters as naturally reproducing
trout waters, NCDOT will be required to observe the NCWRC recommended moratoria for trout. In
addition, NCDWQ will require 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.
3. Review of the project reveals the presence of surface waters classified as C-trout-High Quality Waters
of the State in the project study area. This is one of the highest classifications for water quality.
Pursuant to 15A NCAC 2H .1006 and 1 SA NCAC 2B .0224, NCDOT will be required to obtain a
State Stormwater Permit prior to construction except in North Carolina's twenty coastal counties.
430144 Bridge No. 144 over Dutch Cove Creek, NCSR 1836, Haywood CounTy
-.. . . _ - -
1. Dutch Cove Creek is class C waters.
2. NCDWQ has no specific comments for this project.
490129 Bridge No. 129 over Scott Creek, NCSR 1445, Jackson County
1. Scott Creek is classified C-trout waters. NCDWQ recommends that the most protective sediment and
erosion control BMP's 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 the NC Division
of Land Resources and NC Wildlife Resources Commission.
SURFACE WATER PROTECTION SECTION-Asheville Regional Office
2090 U.S. Highway 70; Swannanoa, North Carolina 28778-8211
Phone: [phone] FAX: [phone]
Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity'� A�rmafive i�ction Employer
NorthCa.rolina
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� 2. Should NC Wildlife Resources Commission (NCWRC) identify these waters as naturally reproducing
;' trout waters, NCDOT will be required to observe the NCWRC recommended moratoria for trout. In
,. additions, NCDWQ will require 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.
r`490102 Bridge No. 102 over Moses Creek, NCSR 1740, Jackson County
1. Moses Creek is classified as WS-III-trout waters. NCDWQ recommends that the most protective
sediment and erosion control BMI''s 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 the
NC Division of Land Resources and NC Wildlife Resources Commission.
2. Should NC Wildlife Resources Commission (NCWRC) identify these waters as naturally reproducing
trout waters, NCDOT will be required to observe the NCWRC recommended moratoria for trout. In
additions, NCDWQ will require 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. � �
370011 Bridge No. 11 over Longs Creek, NC 143 Business, Graham County
1. Longs Creek is classified as C-trout waters. NCDWQ recommends that the most protective sediment
and erosion control BMP's 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 the
NC Division of Land Resources and NC Wildlife Resources Commission.
2. Should NC Wildlife Resources Commission (NCWRC) identify these waters as naturally reproducing
trout waters, NCDOT will be required to observe the NCWRC recommended moratoria for trout. In
additions, NCDWQ will require 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.
370012 Bridge No. 12 over Atoah Creek, NC 143 Business, Graham County
1. Atoah Creek is classified as C-trout waters. NCDWQ recommends that the most protective sediment
and erosion control BMP's 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 the
NC Division of Land Resources and NC Wildlife Resources Commission.
2. Should NC Wildlife Resources Commission (NCWRC) identify these waters as naturally reproducing
trout waters, NCDOT will be required to observe the NCWRC recommended moratoria for trout. In
--- additions,-NGDWQ-will-require-that NCDOT strictly adhere to North Carolina regulations entitled
"Design Standards in Sensitive Watersheds" [15A NCAC 04B .0124] throughout design and
construction ofthe project.
190163, Bridge No. 163 over Bates Creek, NCSR 1348, Cherokee County
1. Bates Creek is class C waters.
2. NCDWQ has no specific comments for this project.
210086 Bridge No. 86 over Hyatt Mill Creek, NCSR 1140, Clay County
210087 Bridge No. 87 over Hyatt Mill Creek, NCSR 1140, Clay County
1. Hyatt Mill Creek is class C waters.
2. NCDWQ has no specific comments for this project.
�2)

210101 Bridge No. 101 over Shooting Creek, NCSR 1353, Clay County
1. Shooting Creek is classified C-trout waters. NCDWQ recommends that the most protective sediment
and erosion control BMP's 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 the NC
Division of Land Resources and NC Wildlife Resources Commission.
2. Should NC Wildlife Resources Commission (NCWRC) identify these waters as naturally reproducing
trout waters, NCDOT will be required to observe the NCWRC recommended moratoria far trout. In
additions, NCDWQ will require 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.
550343 Bridge No. 343 over Alison Creek, NCSR 1448, Macon County
Alison Creek is classified C-trout waters. NCDWQ recommends� that the most protective sediment
and erosion control BMP's 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 the NC
Division of Land Resources and NC Wildlife Resources Commission.
Should NC Wildlife Resources Commission (NCWRC) identify these waters as naturally reproducing
trout waters, NCDOT will be required to observe the NCWRC recommended moratoria for trout. In
additions, NCDWQ will require 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.
550064 Bridge No. 64 over Watauga Creek, NCSR 1328, Macon County
Watauga Creek is classified C-trout waters. NCDWQ recommends that the most protective sediment
and erosion control BMP's 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 the NC
Division of Land Resources and NC Wildlife Resources Commission.
Should NC Wildlife Resources Commission (NCWRC) identify these waters as naturally reproducing
trout waters, NCDOT will be required to observe the NCWRC recommended moratoria for trout. In
additions, NCDWQ will require that NCDOT strictly adhere to North Carolina regulations entitled
"Design Standards in Sensitive Watersheds" [15A NCAC 04B A124] throughout design and
construction of the project.
870064 Bridge No. 64 over North Fork Flat Creek, NCSR 1313, Transylvania County
1. ._ The North Fork.Elat_Creek is classified C-trout waters. NCDWQ recommends that the most - -
protective sediment and erosion control BMP's 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 the NC Division of Land Resources and NC Wildlife Resources Commission.
2. Should NC Wildlife Resources Commission (NCWRC) identify these waters as naturally reproducing
trout waters, NCDOT will be required to observe the NCWRC recommended moratoria for trout. In
additions, NCDWQ will require 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.
(3)

870205 Bridge No. 205 over Little Creek, NCSR 1143, Transylvania County
Little Creek is classified Gtrout waters. NCDWQ recommends that the most protective sediment and
erosion control BMP's 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 the NC Division
of Land Resources and NC Wildlife Resources Commission.
Should NC Wildlife Resources Commission (NCWRC) identify these waters as naturally reproducing
trout waters, NCDOT will be required to observe the NCWRC recommended moratoria for trout. In
additions, NCDWQ will require 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.
870138 Bridge No. 138 over Toxaway Creek, NCSR 1143, Transylvania County
1. Toxaway Creek is classified as C-trout waters. NCDWQ recommends that the most protective
sediment and erosion control BMP's 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 the
NC Division of Land Resources and NC Wildlife Resources Commission
2. Should NC Wildlife Resources Commission (NCWRC) identify these waters as naturally reproducing
trout waters, NCDOT will be required to observe the NCWRC recommended moratoria for trout. In
additions, NCDWQ will require 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.
870117 Bridge No. 117 over East Fork French Broad River, NCSR 1105, Transylvania County
870086 Bridge No. 86 over East Fork French Broad River, NCSR 1107, Transylvania County
1. The East Fork French Broad River is class B-trout-HQW waters of the State. NCDWQ recommends
that the most protective sediment and erosion control BMP's 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 the NC Division of Land Resources and NC Wildlife Resources
Commission.
2. Should NC Wildlife Resources Commission (NCWRC) identify these waters as naturally reproducing
trout waters, NCDOT will be required to observe the NCWRC recommended moratoria for trout. In
additions, NCDWQ will require that NCDOT strictly adhere to North Carolina regulations entitled
"Design Standards in Sensitive Watersheds" [15A NCAC 04B A124] throughout design and
construction of the project. - " -
- 3. Review of tlie project reveals the presence of surface waters classified as C-trout-High Quality Waters
of the State in the project study area. This is one of the highest classifications for water quality.
Pursuant to 15A NCAC 2H .1006 and 15A NCAC 2B .0224, NCDOT will be required to obtain a
State Stormwater Permit prior to construction except in North Carolina's twenty coastal counties.
870045 Bridge No. 45 over French Broad River, NCSR 1127, Transylvania County
1. The French Broad River is classified B-trout waters. NCDWQ recommends that the most protective
sediment and erosion control BMI''s 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 the
NC Division of Land Resources and NC Wildlife Resources Commission.
(4)

2. Should NC Wildlife Resources Commission (NCWRC) identify these waters as naturally reproducing
trout waters, NCDOT will be required to observe theNCWRC recommended moratoria far trout. In
additions, NCDWQ will require 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.
440135 Bridge No. 135 over Shaw Creek, NCSR 1215, Henderson County
1. Shaw Creek is classified as WS-N waters.
2. NCDWQ has no specific comments on this bridge project.
440147 Bridge No. 147 over Mills River, NCSR 1353, Henderson County
1. Mi11s.River is classified as WS-III waters.
2. NCDWQ has no specific comments for this project.
•- 44007�7 Bridge No. �77 over Mud Creek, NCSR 1136, Henderson County . . ....
l. Mud Creek is classified as C waters.
2. NCDWQ has no specific comments for this project.
3. All portions of the proposed project draining to 303(d) listed watersheds that are impaired due to
biological criteria exceedances shall not discharge stormwater directly to surface waters. Stormwater
shall be treated using appropriate best management practices (e.g. vegetated conveyances, constructed
wetlands, detention ponds, etc.) prior to discharging to surface waters.
440073 Bridge No. 73 over Greer Creek, NCSR 1125, Henderson County
1. Greer Creek is classified as B waters.
2. NCDWQ has no specific comments for this project.
740189 Bridge No. 189 over an unnamed tributary to the Green River, NCSR 1151, Polk County
1. The unnamed tributary to the Green River is classified as C waters.
2. NCDWQ has no specific comments for this project.
740049 Bridge No. 49 over Whiteoak Creek, NCSR 1531, Polk County
1. The Whiteoak Creek is classified as C waters. -- ..
2. NCDWQ has no specific comments for this project.
740021 Bridge No. 21 over the North Pacolet River, 1501, Polk County
1. The North Pacolet River is classified as C waters.
2. NCDWQ has no specific comments for this project.
General Comments Re�ardin� Brid�e Replacement Proiects
l. NCDWQ is very concerned with sediment and erosion impacts that could result from these projects.
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.
(5)

2. If foundation test borings are necessary; it shall be noted in the document Geotechnical work is
approved under General 401 Certification Number 3687/Nationwide Permit No. 6 for Survey
Activities.
3. Any Bridge considered a Low Impact Bridge Project must fall under Nationwide Permit No. 3 to
qualify for Low Impact; otherwise, standard permitting procedures will be required. Example
(Regional General Permit No. 31, Nationwide Permit No. 23, Nationwide Permit No. 13, etc.)
4. Whenever possible, NCDWQ prefers spanning structures. Spanning structures usually do not require
work within the stream or grubbing of the stream banks 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.
5. 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.
6. Strict adherence to the most recent version of NCDOT's Best Management Practices For Bridge
Demolition and Removal approved by the US Army Corps of Engineers is a condition of the 401 Water
Quality Certification.
7. Bridge piles and bents shall be constructed using driven piles (hammer or vibratory) or drilled shaft
construction methods. More specifically, jetting or other methods of pile driving are prohibited without
prior written approval from NCDWQ first.
8. No drill slurry or water that has been in contact with uncured concrete shall be allowed to enter surface
waters. This water shall be captured, treated, and disposed of properly.
9. All pile driving or drilling activities shall be enclosed in turbidity curtains unless otherwise approved by
NCDWQ in this certification.
10. All bridge construction shall be performed from the existing bridge, temporary work bridges,
temporary causeways, or floating or sunken barges. If work conditions require barges, they shall be
floated into position and then sunk. The barges shall not be sunk and then dragged into position. Under
no circumstances should barges be dragged along the bottom of the surface water.
11. 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.
12. 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.
13. Heavy equipment shall be operated from the banks rather than in the stream channel in order to
minimize sedimentation and reduce the introduction of other pollutants into the stream. This equipment
shall be inspected daily and maintained to prevent contamination of surface waters from leaking fuels,
lubricants, hydraulic fluids, or other toxic materials. .
(6)

, . .. :
14. 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.
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. In most cases, the NCDWQ prefers the replacement of the existing structure at the same location with
road closure. If road closure is not feasible, a temporary detour shall 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 fi(ls shall 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.
Thank you for the opportunity to provide comments 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 Mike Parker at�828-296-4500.
cc: Lori Beckwith, USACE, Asheville Field Office
Mark Davis, NCDOT, Division 14 Environmental Officer
Marla Chambers, NCWRC
Dave McHenry, NCWRC
Transportation Permitting Unit
NCOT 2012 Bridge Replacement Program Scoping Comments Division 14
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