20130599 Ver 0_Scoping Comments_20081219

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December 19, 2008
MEMORANDUM
TO Hank Schwab, NCDOT Bridge Project Planning Engineer
FROM Rob Ridings, NC Division of Water Quality, Transportation Permitting Unite
SUBJECT: Scopmg Review of NCDOT's Proposed Division 5 Bridge Replacement Projects-
B- 4663, B-4944, B-4835, B-4946, B-4832, and B-4834.
in reply to your correspondence dated November 18, 2008 (received November 21, 2008) in which you requested
comments for the above referenced projects, the NC Division of Water Quality offers the following comments
Protect-Specific Comments
B-4663, Bridge No. 225 over Marks Creek, Wake County
1 Marks Creek and its tributaries are class C, NSW waters of the State DWQ is very 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 Marks Creek 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
2 This project is within the Neuse River Basin Riparian buffer impacts should be avoided and minimized to the
greatest extent possible pursuant to 15A NCAC 2B 0233
B-4944, Bridge No. 225 over UT Knap of Reeds Creek, Granville County
1 Knap of Reeds Creek and is tributaries are class WS-II, HQW, NSW waters of the State The water quality
classification of HQW (High Quality Waters) is one of the highest classifications in the State DWQ is extremely
concerned with any impacts that may occur to streams with this classification It is preferred that these resources be
avoided if at all possible If it is not possible to avoid these resources, the impacts should be minimized to the
greatest extent possible Given the potent for impacts to these resources during the project implementation, the
DWQ requests that DOT strictly adhere to North Carolina regulations entitled "Design Standards in Sensitive
Watersheds" (15A NCAC 04B 0124) throughout design and construction of the project Pursuant to 15A NCAC
2B 0224, NC DOT will be required to obtain a State Stormwater Permit prior to construction
2 This project is within the Neuse River Basin Riparian buffer impacts should be avoided and minimized to the
greatest extent possible pursuant to 15A NCAC 2B 0233
None Carolina
Transportation Permitting Unit Naturally
1650 Mad Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone [phone] / FAX [phone] Internet http //h2o enr state nc us/ncwetlands
Michael F Easley, Governor
William G Ross Jr, Secretary
North Carolina Department of Environment and Natural Resources
Alan W Klimek, P E Director
Division of Water Quality
An Equal Opportunity/Affirmative Action Employer- 50% Recycled/10% Post Consumer Paper
B-4835, Bridge 124 over Reedy Pond Creek, Warren County
1 Reedy Pond Creek is class C, NSW waters of the State DWQ is very 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 Reedy Pond Creek 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
2 This project is within the Tar-Pamlico River Basin Riparian buffer impacts should be avoided and minimized to
the greatest extent possible pursuant to 15A NCAC 2B 0259
B-4946, Bridge 251, Wake County
1 According to the Natural Resource Technical Report, there are no streams or wetlands in the study area for this
project This should be venfied on the ground as usual
B-4832, Bridge 230 over Poplar Creek, Wake County
1 Poplar Creek and its tributaries are class C, NSW waters of the State DWQ is very 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 Poplar Creek 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
2 This project is within the Neuse River Basin Riparian buffer impacts should be avoided and minimized to the
greatest extent possible pursuant to 15A NCAC 2B 0233
B-4834, Bridge 23 over Newman's Creek, Warren County
1 Newman's Creek and its tributaries are class C waters of the State DWQ is very 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 Newman's Creek
General Comments Regarding Bridge Replacement Projects
DWQ is very concerned with sediment and erosion impacts that could result from these projects NC DOT should
address these concerns by describing the potential impacts that may occur to the aquatic environments and any
mitigating factors that would reduce the impacts
If foundation test borings are necessary, it should be noted in the document Geotechmcal work is approved under
General 401 Certification Number 3494/Nationwide Permit No 6 for Survey Activities
3 If a bridge is being replaced with a hydraulic conveyance other than another bridge, DWQ believes the use of a
Nationwide Permit may be required Please contact the US Army Corp of Engineers to determine the required
permit(s)
4 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
Whenever possible, the DWQ prefers spanning structures Spanning structures usually do not require work within
the stream or grubbing of the stream banks 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
6 Bridge deck drains should not discharge directly into the stream Stormwater should be directed across the budge
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
7 If concrete is used during construction, a dry work area should be maintained to prevent direct contact between
curing concrete and stream water Water that inadvertently contacts uncured concrete should not be discharged to
surface waters due to the potential for elevated pH and possible aquatic life and fish kills
Bridge supports (bents) should not be placed in the stream when possible
9 If temporary access roads or detours are constructed, the site shall be graded to its preconstruction contours and
elevations Disturbed areas should be seeded or mulched to stabilize the soil and appropriate native woody species
should be planted When using temporary structures the area should be cleared but not grubbed Cleanng 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
10 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
11 All work in or adjacent to stream waters should 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
12 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
13 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 should 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 should be stabilized with grass and planted with
native tree species Tall fescue should not be used in riparian areas
14 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-equilibnum 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
15 If multiple pipes or barrels are required, they should 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 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
16 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
17 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 should be designed to replace appropriate lost functions and values The NC
Ecosystem Enhancement Program may be available for use as stream mitigation
18 If temporary access roads or detours are constructed, the site shall be graded to its preconstruction contours and
elevations Disturbed areas should be seeded or mulched to stabilize the soil and appropriate native woody species
should be planted When using temporary structures the area should 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 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
20 While the use of National Wetland Inventory (NWl) 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
Thank you for requesting our input at this time The DOT 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 Rob Ridings at (919) 733-
9817
cc Eric Alsmeyer, US Army Corps of Engineers, Raleigh Field Office
Chris Murray, Division 5 Environmental Officer
Chris Milrtscher, Environmental Protection Agency
Travis Wilson, NC Wildlife Resources Commission
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