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N�ViRC]NMEIVTAL �lSIiLITY
December 4, 2015
MEMORANDUM
To: Jahn Rouse, PE, Division En�ir�eer, NC�OT Di�rision 2
From: Garcy Ward, NC Division of Water Resources, Washington Regional Office
Subject: Scopin� comments on Aroposed improvements to NC 148 (C.F. Harwey Parkway Cxtension} in Lenoir
County, STIP R-5703
Reference yaur cor�'espondence dated October 27, 2015 isl which y�u requested comments far the referenced
project. Fretiminary anaiysis ofthe project reveals the potential for multiple iinpacts to strearns andjurisdictional
wetlands it� the project area. More specifically, �mpacts to:
Stream Name River Basin ��rea�n Sfream Index 303(dj
Classification s R!uml�cr Listin
Ston on Cre�k Neuse C;Sw,NSW 27-81 No
Brie Run Neuse C;Sw,NSW 27-$1-1 No
Purth�r investigations at a hibher resalufson should �e undertaken to verify the presence of atl�er st���an�s and/or
jurisdictional �vetlands in the area. In the event that any jurisdictio��al areas are identified, the Division af Water
f�esources requests that NCDOT consider the foilawing er�vironmental issues for the proposed project:
Pro�ect Specif�c Comments:
Stonyton Creek and 8riery Run are c9ass C;Sw,NSW waters of the State. The NCDWR is very concernec�
with sedianent and erosion impacts that cquld result from this project. The NGDWR recommends that
h's�hly protective sediment and erosion control BMPs be implerne�ted to reduce ihe risk of nutrient runoff
to Stonty€on Creek and Briery Run. Additionally, to meet the requirernents of NCiDdT's NFDES Permit
NCSQQ00250, the NCDWR requests that road desi�sn plans provide treatment afthe storm water runoff
tl�rough best management practic�s as detailed in the mosk recent version of the Nr�rFh Carolina
Departmerrr of Transportation Stormwater Best Manag�»aerar Practiccs Toofbo.r inanual.
This projecY is �uithsi� tY�e Neuse River Basin. Riparian buffer impacts shall be �voided and minimized to
the greatest extent possibfe pursuant to 15A NCAC 2B.0233. l�lew dewelapment activities iacateci in the
protected 5�-foot wide riparian areas within the basin shall be [i�nited to "uses" identified wit�in and
constructed in accordance with 15A NC�1C .02B ,0295. Buffer mitigation may be �•equired for buffer
impacts resultin� from activities classifie�i as "allowable with mitigation" wit�hin the "Table of Uses"
section ofthe Buff�r Rules or require a variance under the Buffer Rudes. A bufPer mitigation pl�n, including
use of the North Caralina Division of Miti�ation Services, must be provided ko the NCDWR prior to
appro�al of the Water Quality Certific�tion. Buffer rnitigation may be reRuired for buffer impacts resulting
from activities classiiied as "allowable with mitigation" within the "Table of Uses" section of the Buffer
Rules or require a vari�nce under the Buffer Rules. A buffer m4tigation plan, caordinated with the Notrth
Carolina Division of Mitigation Services, must be pro�ided to the NCDW R prior to a�praval of the Water
Quality Certification.
State of Norlf� Clrolina �Environmental Q�talit}' � Water Rcso�irces
'[6�7 Mail Service Center, RaEeigh, No€fh Carolina 27fi9�1617
Ppone:919-807-6300
General Project Comments;
The enviroi3mental document slzoulcf provide a detaiied and itesr�izecf presentation af the proposed impacts to
�vetlands and streams with corresponding mapping. [f mitigation is necessary as required by 15A NCAC
2H.�506(h), it is prefer�b4e to present a conceptual (if not finalized) mitibatio� p4an with the enwiran►nentak
documentat'son. Appropriate mit's�atian plans wil] be requirsd prior to issuance af a 44l Water Quaiity
Certification.
2. Enviranmenta! impact statement alternatives shall consider desigrs criteria that reduce the impacts to streams
and wetlands frsm storrn water runoff. These alternatives shall ynclude road designs that allow for treatment
of the storm water runoff through best maz�agennent practices as detailed in the most recent version of
NCDWR's Stormwater Best Management Practices ,M'arrual, July 2007, such as grassed swales, buffer areas,
prefQrmed scour hales, retention basins, etc.
After the selection af the preferred alternative and prior to an issuance of the 401 Water Qual�ty Certifiication,
the NCDOT is respeGtfully reminded that they wifl need to detnonstrate the avoidance and rr:inirnization of
im�acts ta wetlands (and st�reams) to the maxinlum extent practical. In accardance with the Environrnental
Management Commission's Rules (ISA NCAC 2i-�.Q506[h]}, mitigation will be ret�uired for itnpacts of
greater than 1 acre to wetlands. In the event that miti�ation is required, ths mitigation plan shall be desig�ed
to replace appropriate lost fuaictioi�s and values. Nflrth Carolina Division of Mitigation Services may be
auailable for assistance with wetland mitigation.
4. In accorda�ce with the Environmental Management Corr�rnissi4n's Rules (l5A NCAC 2H,p506�hj),
mitigation will' be required for impacts of greater than 150 iinear feet to any sir�gEe stream. In tf�e �vent that
mitigation �s required, the mitigalior� plan shall be designed to replace appropriate lost functions and values.
`Fhe North Caro�ina Division of IvIifigation Services may be available for assistance with strearn mit€gation.
5. Future documentation, includina the 40l Watex Quality Certification Application, silall continue to include an
itemiz_ed listin; of the proposed wztland and stream impacts with correspanding tnapping.
6. Thc NCDWR is very concerned with sediment and erosian impacts that cou9d result frotn this project. The
NCI�OT shall address these concerns by describing the potential impacts that may occur to the aquatic
environrnents and any mitigating factors that wouid reduce the ifnpaets.
7. An analysis of cumulative and secondary impacts antieipated as a result of this profect is require�3. The type
and detail of analysis shall conf�rm to the NC Division o� Water Resource Policy on the assessment of
secondary and cu�nulative impacts dated l-�prif t0, 2004.
8. The NCDOT is resFectfully reminded that all impacts, ir�cluding but nat limited to, bridging, �fl, exesvation
and clearing, and rip rap to jurisdictional wetlands, streams, and riparian buffers need ta be inc[uded in the
Fnal impact ca�culations. These impacts, in acidition to any construetion impacts, temporary or otherwFse,
also need to be included as part ofthe 40i Water Quality Certification Ap�lication.
9. Where streams must be crossed, the NCDWR prefers bridges be used in [ieu ofculver�s. However, we realize
that ecanomic considerations aften require the use nf culverts. Please be advised that culverts should be
counteesunk to allow unimpeded passage by fish and other aquatic or�anisms. Moreover, �n areas where high
quality wetkands or streams are irr7pacted, a bridge may prove preferable. When applicable, the NCDOT
should not insta]! the 6rid�;e bents in the creek, to the maximum extent practicable.
l0. Wh�never poss�ble, the NCDWR prefers spanning streictures. Spanning structures us�zaify do not require
work within the stream or grubbing of the streambanks and c!o not require stream channe! realignment. The
horizonta[ and uertical clearances provided by brid�es shall allow for human and wildlife passage �eneath the
structure. Fish passage and navieatio�j by canae�sks and boaters shall not be blockec�, Bridge supports {bents)
shauld not be placed in the stream when passible.
1�. Bridbe deck drains shall ��ot dischar�e direc#ly into the stream. Stgrmwater shall be directed acrass tl�e bridge
and pre-kreated thraugh site-appropriate means (grassed swales, pre-formed scour holes, ve�etated buffers,
et�.} before eriterinb the strear��. Please reter to the most current versior� of NCDWR's St��•rnwater Best
�i�lctnagernent Practices.
12. Sediment and erosion control measures should not b� placad in weklands or streams.
13. Sorro��+/waste areas �hou[d auoid wet�ands to the maximum extent practicaL Impacts to wetlands in
borrowlwaste areas will need to be presented in tlte 401 Wates� Quality Certificat�on and couId precipitate
compensatory mitigation.
14, The 401 Water Quality Certification application wi{l need to specifically address the prflposed methods for
stormwater mana�ement. More specifically, storn�water shall not be peranitted to discAiarge directly into
streains or surface waters.
1S. Based on the information presented in ihe docunzent, the ma�nitude of impacts to wetlands and screams may
require an Individual Permit (IP) application to the Co►ps of En�inecrs and corresponding 4f} 1 Water Quality
Certification. PCease be advised that a 4f}1 Water Quality Certificatian requires satisfactory protection of
water quality tv ensure that water quality standards ase met and no wetfand or stream uses are lost. Final
permit autharization wil! require the submittal af a forma� application by t41e NCDOT and written concurrence
fr�m tlie NCDWR, Please 6e a�vare that any approval will be contingent on appropriate avoidance and
minimization of wet[and and strearn impacts to the maximum extent practicai, the developr�tent ofan
acceptable storrnwater management plan, and the inclt�sion of appropriate mi�igation plans �i�here appropr�ate.
16. tf concrete is uscd durin� construction, a dry work area shall be maintained to prevent direct contact bet�veesl
curing concrcte and stream water. Water tilat inadvertent�y cor+tacts uncured concrete shall nat be discharged
to surface waters due to the potential for elevated pH and possible aquatic life and fish kills.
l7. If temporary access roads or detours are constructed, the site shall be grarled to its preconstruction contours
a�d elevations. Dist�arbed areas shall be seeded or mulehed to stabilize the soil and appropr�ate native �voody
species shall be planted. When using temporary structures kll� area shal] be cleared but not grubbed. Clearinb
the area with chain saws, mawers, busl�-hogs, ar otller mechanized equipment and Ieaving the stumps and root
mat intact allows the lrea to re-vegetate naturally and minimizes so[1 distur�ance.
18. Untess oiherwise authorized, placement of cu3verts and oEher structures in waters and streams shalf be placed
taelow the elevation of the streambed by one foot for all culverts with a diameter ;,reater chan 48 inehes, and
2D percent oithe culvert diarneter for cu�verts ha�ing a d'aameter less than 4$ inches, to allaw ]ow flow
passa�e of water and aquakic life. Design and placement c�f culverts aald othee structures inclt�din� ten�porary
erosion control measures shall not �e canducted in a manner that may result in dis-equ�libri�nn of w�tlands ar
stream�eds or banks, adjacent to or upstream and downsiream o#�the above structures. The applicant is
requirecl to provide evidence that the equilibriurn is being maintained if requested in writing by the NCDWR.
iFthis candition is unable to be met due to bedrack ar other litniting features encountered durin� construction,
please co�itact the PJCDWA for guidance an how to praceed and to deteri�in� whether or not a permit
n�odification wi�l be required.
19. If multiple pipes or barrels are required, they ski�ll be designeck to mimic natural stream cross seczian as
closely as possible including pipes or barrels at flood plain e[evatian, floodplain benches, andfor sills rnay b�
required wherc appropriate, Widening the stream channel should be avoided. S�ream channel �tiridei7ing at �he
inlet or outlet enc3 of structures iypicaEky decreases water velocity causing sediment depositioi� that requires
increased maintena�ice and disrupts aquatic life passage.
�0. If foundatio�i t�st barings are necessary; it shall t�e noted in the document. Geotechnical work is approved
under General 401 Certification Nuntber 3$$3/Nationwide Permit No. 6 far Survey Acti�ities.
2 l. Sediment and erosion contral measures suf�cient ta protect water resources must be itnplemented and
�naintained Fn accordance with the most recent version of Narth Car�lina Sediment and Erosiozz Control
Planning ai�d Design Manua� and the most recent version of NCS000250.
22. All work in or adjacent to stream waters sl�all be canducted in a dry work area. Approved BMP ineasures
from the most current wersior� af the NCl70T Construction and Maintenance Actiwities manual such as
sandbags, rock berms, cafferdams and other diversion s�ructures shall be used to prevent exeavation in
flowing water.
23, While t�e use ofNational Wetland Inventory (NWI) maps, I�IC Coastal Re�ion Evaluation of Wetland
Sigriificance (T�C-CREWS} maps and soil survey maps a�-e useful tools, kheir inherent inaccuraeies require
tliat qua4ified personaiel �erform orisite wetland delineatians prior to permit apprc�val.
2�. Heavy equipment should be operated from the bank rather than in scream channels in arder to minimize
sedimentation and reduce the likelihood of introducirsg ather poflutants into streams. This equipment shali be
inspected daily and maintained to preveni contamination of aurface wate�s fram leaking fuels, lubricants,
hydraul'tc fluids, or other toxic materials.
25. Riprap shall not be placed in the active thaEweg channel or placed in the streamhed in a manner that precludes
aquatic life passage. Bioengin�ering bouldezs or structures should be properly designed, sized and instal[ed.
26. Riparian vegetation (n�,tive trees and shrubs) shall be preserved to the maximurn extent possible. Riparian
vegctation inust be reestablished within the construction limits of Ehe praject by the end of the �,rawin� season
following compietio�i of construction.
Thank you for requesting our input at th�s tirr�e. The NCDi7T is reminded that issuance of a 4Q1 Wster Quality
Certi�'icatior� requires tl�at appropriate measures be �nstituted to ensure that water quality standards are met and
designated uses are not degraded ar lost. If you have any questions or require additional information, please co��tact
Garcy Ward at (252} 948-3917 or garcy.war(�a ncdenr.gov.
Electronic copy only disTribution:
`Cosn Stefferss, lJS Army Corps of En�ineers, Washin�;ton k'ield OfFce
Maria Rogerson, NCDOT Uivision 2
Kristi Lynn Carpenter, NCDWR
File Copy