20160939 Ver 1_Scoping Comments_20151203

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Water Resources
ENVIRONMENTAL OUALITY
PAT MCCRORY
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DONALD R. VAN DER VAART
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S. JAY ZIMMERMAN
Uiruror
December l, 2015
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To: Tim Welch, NCDOT, Division 8
Art King, NCDOT, Division 8
From: Dave Wanucha, NC Division of Water Resources, Winston Salem Regional Office � 1� �1' �"� �
Subject Scoping comments on proposed bridge replacements
Reference your correspondence dated November 70 and 17, 2015 in which you requested comments for the referenced projects.
Preliminary analysis of the project locations reveals the potential for multiple impacts to srreams and jurisdictional weUands in the
project area. More specifically, impacts to [he streams listed below in Table 1.
Table 1. Bridge and stream crossing descri tions.
Number TIP# Rou[e Crossing Index Number Classification Basin La[i[ude Longi[ude County
129 e-nes SR2407 BranchofSendyCreek 17-16-(I) WS-IIf Capel�ear 35.8647 -79.6161 Randolph
170 e-s��o SR 2621 Reed Creek 17-17 C Cape Feac 35.7308 -79.6406 Randolph
79 s-neo SR 142A Naked Creek 14-2-6 WS-ll; ORW Lumber 35.1344 -79.6606 Richmond
175 a-s9za SR 2614 Mill Creek I7-18 C Cape Fear 357059 -79.6848 Rendolph
371 - SR 2182 Penwood Branch I7-12-1 C Cape Fear 35.9366 -79.7855 Randolph
Culvcrt - SR3120 CedarForkCreek 13-2-33-2 C S'adkinPee 3�.7225 -79.8�47 Randolph
Dce
1I - SR 1164 GarzCreek 12-131-(2) WS-IV, CA Yad��Pee 35.4927 -80.1425 Montgomery
224 - SR 1562 Big Creek 13-25-27 C ti'adkin Pee 3528I3 -79.7702 Montgomery
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Further investigations at a higher resolution should be undertaken to verify [he presence of other streams and/orjurisdictional wetlands
in the area. In the event that any jurisdictional areas are ide�tified, the Division of Water Resources requests that NCDOT wnsider
the following environmental issues for the proposed projecT.
Project Specific Comments:
1. Review of the project reveals the presence of surface waters classified as Water Supply Critical Area in the projec[ study
area. Given the potential for impacts to these resources during the project implementation, the NCDWR requests that
NCDOT strictly adhere to North Carolina regulations entitled Design Standards in Sensitive Waaersheds (15A NCAC 04B
0124) throughout design and construction of the project. This would apply for any area that drains to streams having WS
CA (Water Supply Critical Area) classifications.
State o(North Camlina.Fmironmental Quality I Wa[er Resourws
1617 Mail Service Center, RaleigA. Nodh Carolina 27699-1617
Phane:91&807-6300

Should the bridge project be located within the Critical Area of a Water Supply, the NCDOT may be required to design,
co�struct, a�d maintain hazardous spill catch basins in the project area. The number of catch basins installed should be
determined by the design of [he bridge, so that runoff would enter said basin(s) rather than flowing direc[ly into the stream,
and in consW[ation with the NCDWR.
2. Review of the project reveals the presence of surface waters dassified as Outstanding Resource Waters (ORW) of the State
in the project study area. The water quality classification of ORW is one of the highest classifications in the State. The
NCDWR is extremely concerned with any impacts that may occur to streams with this classificatioa It is preferred that
these resources be avoided if at all possible. If it is not possible to avoid these resources, the impacts should be minimized
to the greatest extent possible. Given the potential for impacts to these resouroes during the project implementation, the
NCDV✓R requests that the NCDOT strictly adhere to North Cazolina regulations entitled "Design Standards in Sensitive
Watersheds" QSA NCAC 04B .0124) throughout design and construction of the project
General Project Comments:
L The environmental document should provide a detailed and itemized prese�tation of the proposed impacts to wetlands and
streams with corresponding mapping. If mitigation is necessary as required by l5A NCAC 2H.0506 (h), it is preferable to
present a concepmal (if not Snalized) mitigation plan with the environmental documentation. Appropriate mitigatio� plans will
be required prior to issuance of a 40l Water Qualiry Certification.
2. E�vironme�tal impact stateme�t alterna[ives shall consider design criteria that reduce the impacts to streams a�d wetla�ds &om
storm water ruoofE These alternatives shall indude road designs thaY al low for treatment of the storm water runoff throagh best
management practices as detailed in the most recent versio� of NCD WR's Stormwater Best Management Practices Marrua[,
July 2007, such as grassed swales, buffer areas, preformed scoar holes, retentio� basins, etc.
3. After the selection of the preferred altemative and prior to an issuance of the 401 Water Quality CeRificatio�, the NCDOT is
respectfully remi�ded that they will �eed to demonsrtate the avoidance and minimization of impacts to wetlands (and streams)
to the maximum extent practicaL In accordance with the E�vironmental Management Commissiods Rules ( I SA NCAC
2H.0506 [h]), mitigation will be required for impacts of greater [ha� 1 acre to wetlands. In the event tha[ mitigation is required,
the mitigation plan shall be designed to replace appropriate lost functions a�d valaes. North Carolina Divisio� of Mitigation
Services may be available for assistance with wetland mitigation.
4. In accordance with the Environmental Management Commission's Rules (ISA NCAC 2H.0506 [h]), mitigatio� 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 North Carolina Division of Mitigation Services may be
available for assista�ce with stream mitigation.
5. Future documentation, including the 401 Water Qaality Certification Application, shall conti�ue to include an itemized listing
of the proposed wetland a�d stream impacts with corresponding mapping.
6. The NCD WR is very concerned with sediment and erosion impacts that could resul[ from this project The NCDOT shall
address these concerns by describing the potential impacts that may occur [o the aquatic environments and any mitigating
factors that would reduce the impacts.
7. The NCDOT is respectfully reminded that all impacts, ineluding but not limited to, bridging fill, exeavation and cleari�g, and
rip rap to jurisdictiona] wetlands, streams, and riparian buffers need to be included in the final impact calculatio�s. These
impacts, in addition to any construction impacts, temporary or otherwise, also need to be included as part of the 401 Water
Qualiry Certification Application.
8. Where streams must be crossed, the NCDWR prefers bridges be used in lieu of culverts. However, we realize tha[ economic
considerations often require the use of culverts. Please be advised that culverts should be countersunk to allow unimpeded
passage by fish and other aquaCic organisms. Moreover, in areas where high quality wetlands or streams are impacted, a bridge
may prove preferable. When applicable, the NCDOT should not instal] the bridge bents in the creek, to the maximum extent
practicable.
9. lYhenever possible, the NCDWR prefers spa[ming structures. Spanning structures usually do not require work within the
stream or grubbing of the streambanks and do not require stream cha��el realignmenk The horizontal a�d vertical clearances
provided by bridges shall allow for human and wildlife passage beneath the structure. Fish passage and navigation by ca�oeists
and boaters shall not be blocked. Bridge supports (ben[s) should not be placed in the stream when possible.

10. Bridge deck drains shall not discharge directly into the stream. Stormwater shall be direc[ed 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 cunent version of NCDWR's Stormwater Best Management Practices.
11. Sediment and erosion control measures should not be placed in weUands or sReams.
12. Borrow/waste azeas should avoid wetlands to the maximum extent practicaL [mpacts to wetlands in borrow/waste areas will
❑eed to be presented in the 40l Water Quality Certification and could precipitaYe compensatory mitigation.
13. The 40l Water Quality Certification application will need to specifically address the proposed methods for srormwater
management. More specifically, stormwater shall not be permitted to discharge directly into streams or surface waters.
14. Based on the information presented in the document, the magnitude of impacts to wedands and streams may require a
Natio�wide (NW) permit application to the Corps of Engineers and corzesponding 401 WaYer Quality Certification. Please be
advised that a 401 Water Quality CeRification requires satisfactory protectio� of water qualiry 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 forma]
application by the NCDOT and written co�c�rrence from the NCDWR. Please be aware that any approval will be contingent
on appropriate avoidance and minimization of wetla�d and stream impacts to the maximam extent practical, the development of
an acceptable stormwater management plan, and the inclusion of appropriate mitigation plans where appropriate.
I5. If concrete is used during conshvction, a dry work area shall be maintained to prevent direct contact between curing concrete
and stream water. Water that inadvertently contacts uncured co�crete shall not be discharged to surface waters due to the
potential for elevated pH and possible aquatic life and fish kills.
16. [f temporuy 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. Whe�
using temporary structures the area shall be cleared but not grubbed. Clearing the area wi[h chain saws, mowers, bush-hogs, or
other mechanized equipment and leaving the stumps and roo[ mat intact allows the area to re-vegeta[e naturally and minimizes
soil disturbance.
17. Unless otherwise authorized, placement of culverts and other structures in waters and streams shall 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 aqaatic life. Design and
placement of culveRs a�d other stmctures including temporary erosion control measures shall not be conducted in a manner that
may result in dis-equilibrium of wetlands or streambeds or barilcs, adjacent to or upstream and downstream of the above
structures. The applicant is required to provide evidence that the equilibrium is being maintained if requested in writing by the
NCDWR. If this condition is unable to be met due to bedroek or other limiting features eneountered during eo�struction, please
contacCthe NCDWR for guidance on how to proceed and to determine whether or not a permit modificatio� will be required.
18. If multiple pipes or barrels are required, they shall be designed to munic natural stream cross sectio� as closely as possible
including pipes or barrels at flood plain elevatio�, 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 structures typically
decreases water velociry ca�sing sediment deposition that requires increased maintenance aud disrupts aquatic life passage.
19. If foundation test borings are necessary; it shall be no[ed in the document. Geotechnical work is approved under General 401
Certification Number 3883/Natio�wide Permit No. 6 for Survey Activities.
20. Sediment and erosion control measures sufficient to pro[ect water resources must be implemented and maintained in accordance
with the most recent vetsion of North Carolina Sedime�t a�d Erosion Co�trol Plan�ing and Design Manual and the most recent
version of NCS000250.
2l. All work in or adjacent [o stream waters shall be wnducted in a dry work azea. Approved BMP measures &om the most current
version of the NCDOT Construction and Maintenance Activities manual such as sandbags, rock berms, cofferdams and other
diversion sh'uctutes shall be used to prevent excavation in flowing water.
22. While the use of National Wedand Inventory (N WI) maps, NC Coastal Region Eval�ation of Wetland Significance (NC-
CREWS) maps and soil survey maps are useful tools, their inherent inaccuracies require that qualified personnel perform onsite
wetland deli�eatio�s prior to permit approval.
23. Heary 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 i�spected daily and maintained to
prevent contamination of surface waters from leaking fuels, lubricants, hydraulic fluids, or other toxic materials.

24. Riprap shall not be placed in the active thalweg channel or placed in the streambed in a manner tha[ precludes aquatic life
passage. Bioengineering boulders or structures should be properly designed, sized and installed.
25. Riparia� vegetation (native trees and shrubs) shall be preserved to the maximum extent possible. Riparian vegetation must be
reestablished within [he construction limits of the project by the end of the growing season following completion of
construction.
Thank you for requesti�g our input at this time. The NCDOT is reminded that issuance of a 401 Water Quality CeRitication requires
that appropriate measures be insti[uted to ensure [hat water quality standards are met and designated uses are not degraded or lost If
you have any questions or require additional information, please contact Dave Wanucha at [phone] or Dave
[e-mail].
Electronic copy only distribution:
Andy Williams, US Army Corps of Engineers, Raleigh Field Offce
Kristi Lynn Carpenter, NCDWR
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