Scoping letter U-5788 Wall Street Brunswick

ROY COOPCR
Cnrcrnm�
MIGiA�LS.ftEGAN
Srcrrrm�l•
£nvironn2ental S. JAY ZIMME2MAN
Quality n;,�«m,�
September 25, 2017
M�MORANI)UM
To:
Prom:
Trace R. Howell, NCDOT Division 3 Engineer -DDC
Joanne Steenhuis, NC Division of Water Resources, Wihnington Offce �� �
Subjecl: Scopiiig connnents on proposed realignment of Wnll Street at US 17 f3usiness (Main Street) and Sh�llotte
Avenue in E3runswick County, S97P No. U-5788.
Reference yow� con�espondence dated September I8, 2017 in whieh you requcstcd commcnts for the rcfcrenced
project Preliminary analysis ofthe project reveals tl�e potential for multiplc impacts to slreams and jurisdic[ional
wetlands in lhe project area. More specific�lly, impacts to:
Stream Namc River Basin Strenm Classification(s) Sh�eam Index 303(d) Listiug
Number
Sh�llotte River Lwnber SC; HQW IS-25-2-(7.5)
Ftu'lher invesligations at a higher resolution shotdd be imdertaken [o verify the presence of o[her s[reams and/or
jw�isdictional wedands in lhc area. In Ihe event thal anyjw'isdic[ional areas are iden[itied, [he Division of Water
Resources requests thal NCDO'C consider the following environmental issues for [he proposed project:
Pro,ject Specific Comments:
Review of �he projecf reveals the presence of surface wa[ers cl�ssified as HQW; High Quality Waters o£lhe
S[a[e in the project study area. This is one of tlie highes[ classitications for wa[er quality.
General Project Comments:
Thc environmen[al document should providc a detailed and i[einized presentation of Ihe proposed imp�cts to
wetlands and s�reains wilh correspondin� mapping. If initigl�ion is necessary ns required by I SA NCAC
2H.0506(h), i[ is prcferable to presenl a conceptual (if nol finalizcd) initigation plan �vith the environment�l
documen[a[ion. Appropriate mitig�[ion pl�us will bc required prior lo issuance of � d01 Water Quality
Certifc�tion.
3. C:nvironmentnl impact statemcnt allern�tives sh�ll consider design crileria [hat reduce ihe imp�cts to streams
and wetlands fiom storm water runofC Thesc �Iternn[ives s•hall include road designs thnt allow for he��ment
of the storm water runoff �hrough best menagement practices �s detailed in the mos[ recent version of the
North C�rolinn Depm��n�en� o(Trnnsporin(ion Storm�v�ler 13es� A�lanngenren� Pi•ac�ices Tool box manuTl,
such as grnssed swales, buffer nreas, prcformed scour holes, retenlion basins, etc.
d. Afler [he selection of �he preferred al[crna�ive and prior to an issuance of the 401 Water Qu�lity Certitic�tion,
Ihe NCDO'I' is respeclfully reminded tli�[ Ihey will nced lo dcmonslnte the avoid�ncc and minimization of
impacts to wetlands (and stre�ims) to Uie maxiuuun extent practical. ln accordnnce with the Environmen[al
M�nagemen[ Commission's Rules (ISA NCAC 2H.0506�h]), mitigation will bc required for imp�cts of
greater th�u I acre to weUands. In [he event [ha[ mi[igaliun is required, the mitigation plan shall be designed
�'Nothhig Compares'" ._�.
Stalc u(Nonh Camlina I Envimnmenlnl Qualiry
I G 17 Mail Scrvim Center I Italeigh, Notlh Caml ina 27699-1617

to replace appropriate lost functions and values. North Carolina Division of Mitiga[ion Services may be
available for assistance with wetland mitigation.
5. In accordance with the Environmental Management Commission's Rules ( l5A NCAC 2H.0506[h]),
mitigation will be required for impacts of greater than 150 linear feet to any perennial 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 assistance with sheam
mitigation.
6. Future documentation, including the 401 Water Quality Certification Application, shall continue to include an
itemized listing oFthe proposed wetland and stream impacts with corresponding mapping.
7. The NCDWR is very concerned with sediment and erosion impacts that could result from this project. The
NCDOT shall address these concems by describing the potential impacts that may occur to the aquatic
environments and any mitigating factors that would reduce the impacts.
8. An analysis of cumulative and secondary impacts anticipated as a result of this project is required. The type
and detail of analysis shall conform to the NC Division of Water Resource Policy on the assessment of
secondary and cumulative impacts dated April 10, 2004.
9. The NCDOT is respectfulty reminded that all impacts, including but not limited to, bridging, fill, excavation
and clearing, and rip rap tojurisdictional wetlands, streams, and riparian buffers need to be included in the
final impact calculations. These impacts, in addition to any construction impacts, temporary or otherwise,
also need to be included as part of the 401 Water Quality Certification Application.
io. Where sheams must be crossed, the NCDWR prefers bridges be used in lieu of culverts. However, we realize
that economic considerations often require the use of culverts. Please be advised that culverts should be
countersunk to allow unimpeded passage by fish and other aquatic organisms. Moreover, in areas where high
quality wetlands or sneams are impacted, a bridge may prove preferable. When applicable, the NCDOT
should not install the bridge bents in the creek, to the maximum extent practicable.
11. Whenever possible, the NCD WR 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 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)
should not be placed in the stream when possible.
l2. Bridge deck drains shall not discharge directly into the stream. Srormwater shall be directed across the bridge
and pre-treated through site-appropriate means (grassed swales, pre-formed scour holes, vegetated buffers, etcJ
before entering the stream. To meet the requirements of NCDOT's NPDES permit NCS0000250, please refer
to the most recent version of the North Carolina Department ojTransportation Stormwater Best Management
Practices Toolbox manual for approved measures.
13. Sediment and erosion control measures should not be placed in wetlands or streams.
l4. Borrow/waste areas should avoid wetlands to the maximum extent practical. Impacts to wetlands in
borrow/waste areas will need to be presented in the 401 Water Quality Certification and could precipitate
compensatory mitigation.
15. The 401 Water Quality Certification application will need to specifically address the proposed methods for
stormwater management. More specifically, stormwater shall not be permitted to discharge directly into
streams or surface waters.
l6. Based on the information presented in the document, the magnitude of impacts to wetlands and streams may
require a Nationwide (NV1� application to the Corps of Engineers and corresponding 401 Water Quality
Certification. Please be advised that a 401 Water Qualiry Certification requires satisfactory protection of

water quality 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 formal application by the NCDOT and written concurrence
from the NCDWR. Please be aware that any approval will be contingent on appropriate avoidance and
minimization of wetland and stream impacts to the maximum extent practical, the development of an
acceptable stormwater management plan, and the inclusion of appropriate mitigation plans where appropriate.
l7. 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.
18. If temporary access roads or detours are cons[ructed, 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. 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.
19. Unless otherwise authorized, placement of culverts and other structures in waters and stceams 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 oFthe culvert diameter for culverts having a diameter less than 48 inches, to al(ow 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 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 bedrock or other limiting features encountered during construction,
please contact the NCDWR for guidance on how to proceed and to determine whether or not a permit
modification will be required.
20. 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 should 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.
21. If foundation test borings are necessary; it shall be noted in the document. Geotechnical work is approved
under General 401 Certification Number 3883/Nationwide Permit No. 6 for Survey Activities.
22. 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.
23. All work in or adjacent to stream waters shall be conducted in a dry work area. Approved BMP measures
from the most current version of the NCDOT Construction and Maintenance Activities manual such as
sandbags, rock berms, cofferdams and other diversion structures shall be used to prevent excavation in
flowing water.
24. While the use ofNational Wetland Inventoty (NWI) maps, NC Coastal Region Evaluation of Wetland
Significance (NGCREWS) maps and soil survey maps are useful rools, their inherent inaccuracies require
that qualified personnel perform onsite wetland delineations prior to permit approval.
25. 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 shall be
inspected daily and maintained to prevent contamination of surface waters from leaking fuels, lubricants,
hydraulic fluids, or other toxic materials.
26. 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.

27. Riparian vegetation (native trees and shrubs) shall be preserved to the maximum extent possible. Riparian
vegetation must be reestablished within the conshuction limits of the project by the end of the growing season
following completion of construction.
Thank you for requesting our input at this time. The 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
Joanne Steenhuis at [phone] or [e-mail].
Elechonic copy only distribution:
Greg S. Purvis, PE, Wetherill Engineering
Brad Shaver, US Army Corps of Engineers, WiRO Field Office
Stephen Lane, NC Division of Coastal Management
Cathy Brittingham, NC Division of Coastal Management
Kristi Lynn Carpenter, NCDWR
File Copy