HomeMy WebLinkAboutDWR Comments_ROY COOPER
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MICHAEL S. REGAN
Secretar��
Environrrcental S. JAY ZIMMERMAN
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November 2, 2017
MEMORANDUM
To: Al Blanton, NCDOT R-oject Development Team Lead
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From: Dave Wanuch2, NC Division of Water Resources, Winston Salem Regional Ofifiice ,vo��zo,�
Subject Scoping comments for Project No. U-2729; Widening oi' SR 1672 (Hanes Mill Road) from Museum Drive to SR 4000
(University Parkway) in Winston Salem; and, U-5899; Forum Parkway Coni�ector from SR 3955 (Forum Parkway) to
NC 66 (U��iversity Parkway) in Rural Hall; Forsyth County.
Reference your correspondeilee dzited October 27, 2017 in which you requested comments for the refierencec� projects.
Preliminary analysis ofi the proje�ets reveals the potential for multiple imp�cts ro streams and jurisdictional wetlands in or
downstream fi�om the project areas. More specifically, impacts to:
Stream Name River Basin Stream Classification(s) Stream Index Number 303(d) Listin
Grass � Creek�` Yadkin Pee Dee C 12-94-7-3 No
Mill Creek Yadkin Pee Dee C 12-94-7 No
� Potential impacts to Urassy G�eek would be relative to Project U-589N only.
Further investiQations at a higher resolution should be undertaken to verify the presence of other streams and/or jurisdictional
wetlands in the project areas. if any jurisdictional areas are identified, the Division of Water Resources requests that NCDOT
consider the followinb environmental issues for the proposed projects:
General Project Comments:
The environmei�tal doc�nnent sho�ild provide a detailed and itemizecl presentation of the proposed impacts to wetlands and
streains with corresponding inapping. Ifi mitigation is necessary as required by 15A NCAC 2H.�506(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 isst�ance ofi a 401 Water Qualiry Certifiication.
2. Environmental iinpact statement alternatives shall conside�r design criteria that reduce the i�npacts to sneams and wetlands
from stonn water runof£ These alternatives shall include road designs that allow far treatment of the storm water runoff
through best management practices as detailed in the most recent version of the North Cn�ro[i��a Depcart�rient o f
Trnnsportatio�i Stot�n�vater Best Managen2er�at Practices Tool box man�ial, such as grassed swales, b�iffer areas, prefarmed
scour holes, retention basins, etc.
3. After the selection of the preferred alternative and prior to an issuance of the 401 Water Qualiry Certification, the NCDOT
is respectfiully reminded that they will need to demonstrate tlle avoidance and minimization of impacts to wetlands (ai�d
streams) to the maxii��um extent practical. In accordance with the Environmental Management Coininission's Rules (15A
NCAC 2H.0506[h]), imitigation will be rec�uired for impacts of greater than l acre to wetlands. In the event that mitigation
is required, the miti�ation plan shall be designed to replace appropriate lost functions and val�ie�s. North Carolina Division
of Mitigation Services may be available for assistance with wetland mitigation.
4. In accordance witl� the Environmental Management Commission's Rules (15A NCAC 2H.0506[h�), initigation will be
required for impacts of greatex dlan 300 linear feet to any perennial streanl. Ii� the event that �nitigation is require�d, tl�e
''hJntl�ir�a� C°n�r,��r€�� -
State of Narth Carolina I Environmental Quali[y
1617 Mail Service Center I Raleiah, Norlh Carolina 27699-1617
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 stream mitigation.
5. Future documentation, including the 401 Water Qualiry Certification Application, shall continue to include an itemized
listing of the proposed wetland and stream impacts with corresponding mapping.
6. The NCDWR is very concerned with sediment and erosion impacts that could result from this project. The 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.
7. The NCDOT is respectfully reminded that all impacts, including but not limited to, bridging, fill, excavation and clearing,
and rip rap to jurisdictional 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.
8. Where streams 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 streams 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.
9. Whenever possible, the NCDWR 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.
10. 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. To meet the requirements of NCDOT's NPDES pernut NCS000250 please refer to the most recent version of the
North Carolina Department of Transportation Stormwater Best Management Practices Toolbox manual for approved
measures.
11. Sediment and erosion control measures should not be placed in wetlands or streams.
12. Borrow/waste areas should avoid wetlands to the ma;cimum 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.
13. 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.
14. Based on the information presented in the document, the magnitude of impacts to wetlands and streams may require a
Nationwide (NW) permit application to the Corps of Engineers and corresponding 401 Water Quality Certification.
Please be advised that a 401 Water Quality 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.
15. 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.
16. 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 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.
17. Unless otherwise authorized, placement of culverts and other structures in waters and streams 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 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 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.
18. 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 velociry causing sediment deposition that requires increased maintenance and disrupts aquatic life
passage.
19. 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.
20. 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.
21. 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.
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 pernut approval.
23. 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.
24. 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.
25. Riparian vegetation (native trees and shrubs) shall 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.
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 Dave Wanucha at (336) 473-9703
or Dave.Wanucha@ncdenr.gov.
Electronic copy only distribution:
James Lastinger, US Army Corps of Engineers, Raleigh Field Office
Aileen Mayhew, PE, Mott MacDonald
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