New Hanover U-5710_DWR scoping comments

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NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
April 7, 2015
MEMORANDUM
To: Kim Gillespie, NCDOT Project Planning Engineer
Donald R. van der Vaart
Secretary
From: Mason Herndon, NC Division of Water Resources, Transportation Permitting Unit, �
Fayetteville/Wilmington Region.
Subject: Scoping comments on proposed improvements to US 74 (Eastwood Road) at SR 1409 (Military Cutoff
Road) Intersection in Wilmington, New Hanover County, Federal Aid Project No. NHPP-0074(159).
State Project No. SO115.1.FS1. TIP U-5710.
Reference your correspondence dated March 23, 2015 in which you requested comments for the referenced project.
Preliminary analysis of the project area reveals the potential far multiple impacts to streams and jurisdictional
wetlands in the project area. More specifically, impacts to:
Stream Name River Basin Stream Classification(s) Stream Index Number 303(d) Listing
Bradley Creek White Oak SC; HQW # 18-87-24-4-(1) Yes (Cat 3)*
Wrightsville Recreation Area White Oak SB # 18-87-14 Yes (Cat 4)*
# Discharges of sewage are prohibited to segments classified as SB or SC with a pound sign accarding to the provisions of 15
NCAC 2B .0203 and 2 H.0404(a) in arder to protect adjacent shell fishing waters.
*Not turbidity related therefare Design Standards in Sensitive Watersheds (15A NCAC 04B .O124) is not required, however to
meet the requirements of NCDOT's NPDES permit NCS0000250 the road design plans should provide treatment of the storm
water runoff through best management practices as detailed in the most recent version of the North Carolina Department of
Transportation Stormwater Best Management Practices Toolbox manual.
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 any jurisdictional areas are identified, the Division of Water
Resources requests that NCDOT consider the following environmental issues for the proposed project:
Project Specific Comments:
1. Review of the project reveals the presence of surface waters classified as SC; High Quality Waters of the
State in the project study area. This is one of the highest classifications for water quality. The NCDWR
requests that road design plans provide treatment of the storm water runoff through best management
practices as detailed in the most recent version of the North Carolina Department of Transportation
Stormwater Best Management Practices Toolbox manual.
2. DWR cannot comment on permit requirements with the limited infarmation provided. Detailed field
delineation is required to determine the presence or absence of jurisdictional resources within the project
limits. In addition, NCDOT must provide an estimate of impacts to any resources located within the
construction limits of the project before we can specifically comment on NCDWR permit eligibility
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General Project Comments:
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 l SA NCAC
2H.0506(h), it is preferable to present a conceptual (ifnot finalized) mitigation plan with the environmental
documentation. Appropriate mitigation plans will be required prior to issuance of a 40l Water Quality
Certification.
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
NCDWR's Stormwater Best Management PNactices 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 (l SA 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. North Carolina Division of Mitigation Services may be
available for assistance with wetland mitigation.
6. In accordance with the Environmental Management Commission's Rules (15A NCAC 2H.0506[h]),
mitigation will be required for impacts of greater than 1501inear 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 Narth Carolina Division of Mitigation Services may be available far assistance with stream mitigation.
7. 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.
8. The NCDWR is very concerned with sediment and erosion impacts that could result from this project. The
NCDOT shall address these concerns by describing the potential impacts that may occur to the aquaric
environments and any mitigatin� factors that would reduce the impacts.
9. The 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.
10. 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.
1 l. If foundation test borings are necessary; it shall be noted in the document. Geotechnical wark is approved
under General 401 Certification Number 3883/Nationwide Permit No. 6 for Survey Activities.
12. 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, tt�eir inherent inaccuracies require
tl�at qualified personnel perform onsite wetland delineations prior to permit approval.

Thank you for requesting our input at this time. The NCDOT is reminded that issuance of a 40l 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
Mason Herndon at [phone] or mason.herndon@ncdenr.�ov.
Electronic copy only distribution:
Brad Shaver, US Army Corps of Engineers, Wilmington Field Office
Dr. Cynthia Van Der Wiele, US Environmental Protection Agency
Cathy Brittingham, NC Division of Coastal Management
NC Division of Water Resources Raleigh Central Office
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