US 221-NC 226 Improvements

Ivllld lace I - W " -
O? WATT- William G Ross Jr, Secretary
Q North Carolina Department of Environment and Natural Resources
Coleen Sullins, Director
Division of Water Quality
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September 15, 2008
MEMORANDUM
To Gregory J Thorpe, Ph D , Manager, Project Development and Environmental
Analysis Branch
Transportation Permitting Unit d.J'
From Brian Wrenn, NC Division of Water Quality,
Subject Scoping comments on proposed improvements l, of US TIP 221-NC 25002B26 Woodlawn to Spruce
Pine in McDowell County, WBS No 41158 1
No R- ich These comments are in reference to your correspondence dated the July 28,t reveals eals he pot you requesin utiple ntial for
comments for the referenced project Preliminary analysis
impacts to perennial streams in the project area More specifically, impacts to
Stream Stream Index
Stream Name River Basin Number
Classification s
C,H W 11-24-14-12
Cox Creek Catawba 11-24-14 -12
Catawba C,HQW
Rai Creek
Further investigations at a higher resolution should
the event that any jurisdictional areas are identified, the ms
and/or jurisdictional wetlands in the area In
Division of Water Quality requests that USFS consider the following environmental issues for the
proposed project
Project Specific Comments: extend The scopmg comment request subject line d only onlof t e ent re p jedlalwns
to Spruce Pine However the maps provided Y show a sma
the opinion of DWQ that the entire project should be considered in the scoping request and that
one document should be developed for the entire project In considering the entire project, on thit is at an
DWQ's opinion that the project would
impact statement shou d be deDveloQped It is also
environmental assessment or en
unclear whether this project has been through a screening meeting for inclusion in the Merger '0
Process Please provide a response regarding these issues one of
highest
the
water 2 Cox Creek and Rag Creek are class C,HQW waters of the State This to 15A NCAC 2H 11006 and 15A NCAC 2B
quality classifications in North Carolina Pursuant
0224, NC DOT will be required to obtain a State Stormwater Permit prior to construction
Transportation Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone [phone] FAX [phone] Internet htt //h2o enr state nc us/ncwetlands
An Equal opportunity/Affirmative Acton Employer - 50% Recycled110% Post Consumer Paper
Ne
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The NCDOT may be required to design, construct, and maintain hazardous spill catch basins in
the project area The number of catch basins installed shall be determined by the design of the
stream crossings, so that runoff would enter said basin(s) rather than flowing directly into the
stream, and in consultation with the DWQ
3 DWQ has concerns regarding the potential for acidic rock in the project corridor Pre-
construction geotechmcal testing should be conducted for the presence of acidic rock If any
acidic rock is found, efforts should be made to avoid and minimize disturbance of these areas As
part of the 401 Water Quality Certification, DWQ will require a treatment and mitigation plan for
handling and disposing of acidic rock
4 Any anticipated bank stabilization associated with culvert installations or extensions should be
addressed in the Categorical Exclusion (CE) document It is understood that final designs are not
determined at the time the CE is developed However, the CE should discuss the potential for
bank stabilization necessary due to culvert installation
5 Any anticipated dewatermg or access structures necessary for construction of bridges should be
addressed in the CE It is understood that final designs are not determined at the time the CE is
developed However, the CE should discuss the potential for dewatermg and access measures
necessary due to bridge construction
6 All work in or adjacent to stream waters shall be conducted in a dry work area unless otherwise
approved by NC DWQ 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
General Project Comments:
1 The environmental document shall 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 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 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 USFS is respectfully reminded that they will need to demonstrate the avoidance
and mimrmzation of impacts to wetlands (and streams) to the maximum 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
4 In accordance with the Environmental Management Commission's Rules { 15A NCAC
2H 0506(h)), mitigation will be required for impacts of greater than 150 linear feet to any single
perennial stream 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 stream mitigation
5 If an old bridge is removed, no discharge of bridge material into surface waters is allowed unless
otherwise authorized by the USACE Strict adherence to the Corps of Engineers guidelines for
bridge demolition will be a condition of the 401 Water Quality Certification
6 Bridge supports (bents) shall not be placed in the stream when possible
7 Whenever possible, the DWQ prefers spanning structures Spanning structures usually do not
require work within the stream or grubbing of the streambanks and do not require stream channel
realignment The horizontal and vertical clearances provided by bridges allow for human and
wildlife passage beneath the structure, do not block fish passage and do not block navigation by
canoeists and boaters
8 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 NC DWQ Stormwater Best Management Practices
9 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
10 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
11 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 DWQ If this condition is unable to be met due to bedrock
or other limiting features encountered during construction, please contact the NC DWQ for
guidance on how to proceed and to determine whether or not a permit modification will be
required
12 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 and/or sills 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
13 If foundation test borings are necessary, it should be noted in the document Geotechmcal work
is approved under General 401 Certification Number 3624/Nationwide Permit No 6 for Survey
Activities
14 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
15 Sediment and erosion control measures shall not be placed in wetlands and streams
16 Borrow/waste areas shall avoid wetlands to the maximum extent practical Impacts to wetlands
in borrow/waste areas could precipitate compensatory mitigation
17 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
18 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 from leaking fuels, lubricants, hydraulic fluids, or other toxic materials
19 In most cases, the DWQ 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 stabilized with grass and planted with
native tree species Tall fescue shall not be used in riparian areas
20 Riprap shall not be placed in the active thalweg channel or placed in the streambed in a manner
that precludes aquatic life passage Bioengmeermg boulders or structures should be properly
designed, sized and installed
our input at this time The USFS is reminded that issuance of a 4 al Water
Thank you for requesting o wire
nate measures or lost instituted
have any questions r require
Quality Certification requires that approp aded
standards are met and designated uses are not degr
additional information, please contact Brian Wrenn at 919-733-5715
US Army Corps of Engineers, Asheville Field office
cc David Baker, a Administration
Clarence Coleman, Federal Highway
Marla Chambers, NC Wildlife Resources Commission
Mike Parker, DWQ Asheville Regional Office
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