Bridge 77 on SR 1321

Beverly Eaves Perdue
Governor
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North Carolina Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullins
Director
November 8, 2010
MEMORANDUM
To: Matthew Jones, Bridge Program Manager, NCDOT Division 9
From: Amy Euliss. NC Division of Water Quality, Office
Dee Freeman
Secretary
Subject: Scoping comments on proposed replacement of Bridge nos. 277 (SR 2504), 282 (SR 2533), 338
(SR 2265), and 349 (SR 2099) in Davidson County, Bridge nos. 53 (SR 1406) and 77 (SR 1321)
in Davie County, Bridge no. 2(SR 1470) in Forsyth County, .
, and Bridge no. 2(SR 1103) in Stokes County
Reference your correspondence dated November 4, 2010 in which you requested comments for the
referenced project. The NC Division of Water Quality offers the following comments:
Project Specific Comments:
Brid�e no. 277 (SR 2504) over UT to Lick Creek
1. Lick Creek are class WSN; 303(d) waters of the State. Lick Creek is on the 303(d) list for
impaired use for aquatic life due to low pH and dissolved oxygen. NCDWQ is very concerned
with sediment and erosion impacts that could result from this project. NCDWQ recommends that
the most protective sediment and erosion control BMPs be implemented in accordance with
Design Standards in Sensitive Watersheds to reduce the risk of nutrient runoff to Lick Creek.
NCDWQ requests that road design plans provide treatment of the storm water runoff through best
management practices as detailed in the most recent version of NCDWQ's Stormwater Best
Management Practices.
Brid�e no. 282 (SR 2533) over Cabin Creek
*Potential Impacts to Cabin Creek-class WSN; no project specific comments.
Brid�;e no. 338 (SR 2265) over Flat Swamp Creek
*Potential impacts to Flat Swamp Creek-class C; no project specific comments.
Bridde no. 349 (SR 2099) over Brier's Creek
*Potential impacts to Brier's Creek-class WS III; no project specific comments.
Bridne no. 53 (SR 1963) over Frost Mill Creek � �
*Potential impacts to Frost Mill Creek-class C; no project specific comments.
Brid�e no. 77 (SR 1321) over Dutchman's Creek
�*Potential impacts to UT to Dutchmen's Creek- class B; no'project specific comments.
Brid�e no. 2 SR 1470� over Fries Creek
*Potential impacts to Fries Creck-class WSIV; no project specific comments.
NoRh Carolina Division of Water Quality. Winston-Salem Regional Office
Location: 585 Waughtown St. Winston-Salem, NoRh Carolina 27107
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer �
NonrthCarolina
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Brid�e no. 2 SR 1103) over Crooked Run Creek
*Potential impacts to Crooked Run Creek-class WS IV; no project specific comments.
General Project Comments:
1. Please note some of the classifications listed on the Low Impact Bridge Project data sheet were
incorrect. Please update the list using the classifications listed above.
2. Proposed impacts suggest that these projects will be permitted using a Nationwide 3 from the US
Army Corps of Engineers. NCDWQ would like to respectively remind NCDOT that WQC 3687, or
its most recent equivalent, will also be required. NCDOT shall be in compliance with all of its
applicable conditions.
3. DWQ understands that these bridges will be replaced using an off-site detour, if at any time these
plans change, DWQ shall be contacted to determine if this project can remain in the Low-Impact
Bridge Replacement process.
4. The environmental document shall provide a detailed and itemized presentation ofthe proposed
impacts to wetlands and streams with corresponding mapping. If mitigation is necessary as required
by 1 SA 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.
5. Environmental assessment 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 Stormwater Best tl%Ianagement Practices, such as grassed swales,
buffer areas, preformed scour holes, retention basins, etc. �
6. After the selection of the preferred alternative and prior to an issuance of the 401 Water Quality
Certification, NCDOT is respectfully reminded that they will need to demonstrate the avoidance and
minimization of impacts to wetlands (and streams) to the masimum extent practical. In accordance
with the Environmental Management Commission's Rules { 15A 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. The NC Ecosystem
Enhancement Program may be available for use as wetland mitigation.
7. In accordance with the Environmental Management Commission's Rules { 15A NCAC 2H.0506(h)},
mitigation wifl 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. Tlie NC Ecosystem Enhancement Program may be available for use as stream
mitigation.
8. 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.
9. If a bridge is being replaced with a hydraulic conveyance other than another bridge, NCDWQ
believes the use of a Nationwide Permit may be required. Please contact the US Army Corp of
Engineers to determine the required permit(s).
10. If the old bridge is removed, no discharge of bridge material into surface waters is allowed unless
otherwise authorized by the US ACOE. Strict adherence to the Corps of Engineers guidelines for
bridge demolition will be a condition of the 401 Water Quality Certification.

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1 l. Whenever possible, NCDWQ prefers spanning structures. Spanning structures usually do not require
work within the stream or grubbing of th� 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) shall not be placed in the stream when possible.
12. 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.
13. 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.
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 should 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. Placement of culverts and other structures in waters, streams, and wetlands shall be 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.
16. 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, floodplain benches, and/or
sills may be required where appropriate, Widening the stream channel shall 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.
17. If foundation test borings are necessary; it should be noted in the document. Geotechnical work is
approved under Genera1401 Certification Number 3624/Nationwide Permit No. 6 for Survey
Activities. .
18. 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.

19. ^All work in or adjacent to stream waterg� shall be conducted�in a dry work area unless otherwise .
approved by NCDWQ. 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 should be used to prevent excavation in flowing water.
20. Sediment and erosion control measures shall not be placed in wetlands and streams.
21. Borrow/waste areas shall avoid wetlands to the maximum extent practical. Impacts to wetlands in
borrow/waste areas could precipitate compensatory mitigation.
22. 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.
23. Heavy equipment shall 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 froin leaking fuels,
lubricants, hydraulic fluids, or other toxic materials.
24. In most cases, NCDWQ prefers the replacement of the existing structure at the same location with
road closure. If road closure is not feasible, a temporary detour should 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 fills should be removed and restored to the natural
ground elevation. The area shall be stabi�ized with grass and planted with native tree species. Tall
fescue shall not be used in riparian areas.
25. 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.
Thank you for requesting our input 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 Amy Euliss at [phone].
cc: John Thomas, US Army Corps of Engineers, Raleigh Field Office
Federal Highway Administration
KentBoyer, Division 9Environmental Officer _
Chris Militscher, EPA-e-copy
Marla Chambers, NC Wildlife Resources Commission-e-copy
Wetlands/ 401 Transportation Permitting Unit :
File �opy • .
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