20091149 Ver 1_Staff Comments_20080331

~ WgTE Michael F. Easley, Governor
OHO qOG William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
`
~ ~ Coleen Sullins, Director
>_ ~ Division of Water Quality
O 'C
April 3, 2008
MEMORANDUM
To: Melba McGee, DENR Office of Legislative and Intergovernmental Affairs
From: Rob Ridings, Division of Water Quality, Transportation Permitting Unite
Subject: Comments on the Environmental Assessment related to proposed interchange at the
intersection of US 74/NC 130 and NC 242, Columbus County, Federal Aid Project No.
NHF-74(78), State Project No. 40224.1.1, TIP No. R-4900, DENR Clearinghouse No.
08-0284.
This office has reviewed the referenced document dated received March 31, 2008. The Division of Water
Quality (DWQ) is responsible for the issuance of the Section 401 Water Quality Certification for
activities that impact Waters of the U.S., including wetlands. It is our understanding that the project as
presented will result in impacts to jurisdictional wetlands, streams, and other surface waters. The DWQ
offers the following comments based on review of the aforementioned document:
Project Specific Comments:
1. This project is being planned with input from DWQ and other resource agencies. As a participating
team member, the NCDWQ will continue to work with the team.
2. Cow Branch is class C; Sw, waters of the State. DWQ is concerned with sediment and erosion
impacts that could result from this project. DWQ recommends that highly protective sediment and
erosion control BMPs be implemented to reduce the risk of nutrient runoff to these waters. DWQ
requests that road design plans provide treatment of the storm water runoff through best management
practices as detailed in the most recent version of NC DWQ Stormwater Best Management Practices.
General Comments:
1. 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 15A 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.
2. Environmental assessment alternatives should consider design criteria that reduce the impacts to
streams and wetlands from storm water runoff. These alternatives should include road designs that
allow for treatment of the storm water runoff through best management practices as detailed in the
most recent version of NC DWQ Stormwater Best Management Practices, such as grassed swales,
buffer areas, preformed scour holes, retention basins, etc.
3. After the selection of the preferred alternative and prior to an issuance of the 401 Water Quality
Certification, the NCDOT is respectfully reminded that they will need to demonstrate the avoidance
None hCarolina
Transportation Permitting Unit ~~611'a~~l,/
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone: [phone] /FAX [phone]ntemet: http://h2o.enr.state.nc.us/ncwetlands
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and minimization of impacts to wetlands (and stt Commisshon's Rules { I SA NCACi2H.0506(h)},
accordance with the Environmental Managemen
mitigation will be required for impacts of greater be de ac ed t replace appropriate to t functions
mitigation is required, the mitigation plan should ~
and values. The NC Ecosystem Enhancement Program may be available for use as wetland
mitigation.
4. In accordance with the Environmental Management Commission's Rules { 15A NCAC sin le
2H.0506(h)}, mitigation will be required ~ orimpre to°edrthe mit gat on plan should be designed to
perennial stream. In the event that mitiga q
re lace appropriate lost functions and values. The NC Ecosystem Enhancement Program may be
p
available for use as stream mitigation.
Future documentation, including the 40l Water Quality Certification Application, should continue
5.
to include an itemized listing of the proposed wetland and stream impacts with corresponding
mapping.
DW is very concerned with sediment and erosion impatentialtim uac s that mray occu t o the NC
6. Q
DOT should address these concerns by describing the po p
aquatic environments and any mitigating factors that would reduce the impacts.
An anal sis of cumulative and secondary impacts anticipCatDed asion of Wat rhQual~ty Policyqonrthe
7. y
The type and detail of analysis should conform to the
assessment of secondary and cumulative impacts dated April 10, 2004.
g. NC DOT is respectfully reminded that all impacts, streamisgand riparianibuffer Sneed to~belincluded
excavation and clearing, to jurisdictional wetlands,
in the final impact calculations. These im aai~cts, in addition to any construction impacts, tempora
of the 401 Water Quality Certification Application.
or otherwise, also need to be included as p
9, Where streams must be crossed, the DWQ prefers bridges be used in lieu of culverts. However, we
realize that economic considerations often requiaetdhee sa oe bylfish and other aquat c organisms.
culverts should be countersunk tual to wetlands or streams are impacted, a bridge may prove
Moreover, in areas where high q h'
preferable. When applicable, DOT should not install the bridge bents in the creek, to the maximum
extent practicable.
10. Sediment and erosion control measures should not be placed in wetlands or streams. nds in
11. Borrow/waste areas should avoid wetlands to the e 4~1nWatertQualty Certificatpontand could
borrow/waste areas will need to be presented m th
precipitate compensatory mitigation.
12. The 401' Water Quality Certification application willca jeds ormwaterashou d not be perrmitted to
methods for stormwater management. More specifi y,
discharge directly into streams or surface waters.
13. Based on the information presented in the document, thon tto the Corps of Engineers and ds and
streams may require an Individual Permit (IP) apphca

corresponding 401 Water Quality Certificatri of water quality to ensuret thatOw ertquaQlity standards
Certification requires satisfactory protectio
are met and no wetland or stream uses are lost. Fn concurrencetf~om the NCDWQ 1 Please bem~tta
of a formal application by the NCDOT and wrttte
aware that any approval will be contingent on appropriate avoidance and minimization of wetland
and stream impacts to the maximum extent pr riate mit eat onlp ans where appropriatee storrnwater
management plan, and the inclusion of approp g
14. Whenever possible, the DWQ prefers spanning structures. Spanning structures usually do not
require work within the stream or grubbing of the str ro tided by bridges allow~forshuman andnel
realignment. The horizontal and vertical clearances p
wildlife passage beneath the structure, do not block fish passage and do not block navigation by
canoeists and boaters.
15. Bridge deck drains should not discharge directly ro°riatesmeans (grass d swales~ pre formed s our
across the bridge and pre-treated through site app p
holes, vegetated buffers, etc.) before entering the stream. Please refer to the most current version of
NC DWQ Stormwater Best Management Practices.
16. If concrete is used during construction, a dry work area should be maintained to prevent direct
contact between curing concrete and stream ~'~' titers duet tt tie potential for elevat d pH and d
concrete should not be discharged to surface w
possible aquatic life and fish kills.
17. If temporary access roads or detours are construcbe seeded or mulched to stabilizethe soiltand ion
contours and elevations. Disturbed areas should
appropriate native woody species should tin the area with chaingawspmowersr bush-hogs, orr other
should be cleared but not grubbed. Clears g
mechanized equipment and leaving the stumps and root mat intact allows the area to re-vegetate
naturally and minimizes soil disturbance.
18. Placement of culverts and other structures in wat culverts with a diameteagr ate than 48~nches,
the elevation of the streambed by one foot for all
and 20 percent of the culvert diameter for cuDesi s hand pla e~ment oflculverts andlother structures
low flow passage of water and aquatic life. ~
including temporary erosion control measures sh ks ad' acent touor upstream and down tream of the
dis-equilibrium of wetlands or streambeds or ban
above structures. The applicant is requir~ to f thi scondrt onis unable to be~met due tebedrock or
maintained if requested in writing by D Q lease contact the NCDWQ for guidance
other limiting features encountered during construction, p
on how to proceed and to determine whether or not a permit modification will be required.
19. If multiple pipes or barrels are required, they should cls at flood plain a evat on nd/or sills where
section as closely as possible including pipes or barn
appropriate. Widening the stream channel should be e]OOCded ausing sed mentldeposntion thate inlet
or outlet end of structures typically decreases water v ty
requires increased maintenance and disrupts aquatic life passage.

•. . ..
20. If foundation test borings are necessary; it should be noted in the document. Geotechnical work is
approved under Genera1401 Certification Number 3494/Nationwide Permit No. 6 for Survey
Activities.
21. 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. .
22. All work in or adjacent to stream waters should 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 should be used to
prevent excavation in flowing water.
23. 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.
24. Heavy 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 should be inspected daily and maintained to prevent contamination of surface waters
from leaking fuels, lubricants, hydraulic fluids, or other toxic materials.
25. Riprap should 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.
26. Riparian vegetation (native trees and shrubs) should be preserved to the maximum extent possible.
Riparian vegetation must be reestablished within the construction limits of the project by the end of
the growing season following completion of construction.
The NCDWQ appreciates the opportunity to provide comments on your project. Should you have any
questions or require any additional information, please contact Rob Ridings at [phone].
cc: Richard Spencer, US Army Corps of Engineers, Wilmington Field Office
Clarence Coleman, Federal Highway Administration
Jim Rerko, Division 6 Environmental Officer
Kathy Matthews, Environmental Protection Agency
Travis Wilson, NC Wildlife Resources Commission
Ken Averitte, DWQ Fayetteville Regional Office
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