20191462 Ver 1_U-5724-scoping_20171108

ROY COOPER
G n rnr�� n r
MICHAEL S. REGAN
S�c��elii���
Environmental LINDA CiILPEPPER
Quallty Inlcrim Directr,r
Noveinber 8, 2017
MEMORANDUM
To
Fro m:
Matt Clarke, P.E., NCDOT Division 4 Project Manager
Rob Ridings, NC Division Water Resources, Trausportation Peinutting Branch
Subject Scoping comments on proposed improvements to Intercliange of US 70, US 13, & Central Heights Roaci
in Goldsboro, Wayne County, State Project No. 54016.1.FR1; TIP No. U-5724.
Reference your con-espondence received Novembc,r 7> 2017, in which you requested coirvnents for the referenced
projcct Prclinvnary analysis ofthc project revcals thc potcntial for multiple impacts to sri-cams, buffers and
jurisdictional wetlands in the project are;a. Mare specific�lly, implcts to:
Stream Name River Basin & Subbasin Stream Classifications Stream Indes Number 303(cn ListinQ?
Richland Creek N�U OS C; NSW 27-62 No
Billy Branch
aka Billy Bud NI:iJ OS C; NSW 27-62-3 No
Creek
Further invcstigations at a higher resolution should bc undcrtalccn to vcrify thc prescncc of othcr strcan�s and/or
jurisdictional wctlands in the area. In thc event that any jurisdictional areas are idcntified, thc Division of Water
Rcsources requcsts thatNCDOT considertlie followu�g e�lvironmcntal issues forthcproposcdprojcct:
Project Specific Comments:
Richland Creek, Billy Branch (Billy Bud Creek) and their tributaries are class C; NSW waters of tl�e State. The
NCDW R is very concen�ed witl� sedvnent and erosion impacts tl�at cottld result fi-oi1� this project The
NCDWR recorrvnends that highly protective sed'unent and erosion control BMPs Ue unplemented to reduce the
rislc of nutrient runoffto these streams. Additionally, to meet tlie requu�ements of NCDOT's NPDES pemvt
NCS0000250, the NCDWR requests tl�at road des ign plans provide trearnlent of the stonn water ninoff ttlrough
best managetnent practices as detailed in the nlost recent version of the North Ccrroli»c� Depurtrnent o f
Ti^ren.s�o�•tatio» Stormivater�Best Mancager�zerrtPr�nctices Too/bo.i manual.
2. This project is within the Neuse River Basin. Riparian buffer unpacts shall be avoided and minunized to the
grcatestc�ent possiblepLusuantto 15A NCAC 2B.0233. Ncw developmcnt activitics locatcd in thcprotcctcd
50-foot widc riparian arcas within thc basin shall bc limited to "uses" idcntificd within and constitiictcd in
accordancc with 15� NCAC .02B .0295. Buffcr nutigation may bc rcquu-cd for buffcr impacts resulting fi•om
activities classified as "allowable with miti�ation" withn� the "Table ofUses"sectionoftlieBuffer Rules or
require a variance undertheBuffer Rules. A Uuffer mitigation plan, including useofthe North Carolina
Division of Mitigation Services, must beprovided to the NCDWR prior to approval ofthe Water Quality
Certification. Buffer nutigation roay be required for bLiffer u»pacts resulting fi•om activities classitied as
"allowable witl� mitigatiou" within tl�e"Table ofUses" section oftl�e B�iffer Rules orrequire a variance under
the Buffer Rules. A buffer mitigation plan, coordinated with the North Carolina Division of Mitigation
Seivices, must be provided to the NCDWR prior to approval of the Water Quality Certification.
�.r i�.r�9 f�ni��� C=�rrr:��,� r r,r;
Statc ofNorth Carolina I Enviromncntal Quality
1617 Mail Se�vicc Center I Raleigh, North Carolina 27(i99-1617

General Project Comments:
The environmental document shouldprovide a detailed and itemized presentation ofthe 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 ofa 401 Water Quality
Certification.
2. Environmental impact statement alternatives shall consider design criteria that reduce the impacts to streams
and wetlands from stormwater runoff. These alternatives shall include road designs that allow for treatment
of the storm water runoffthroughbest management practices as detailed in the most recent version of the
North Carolina Department of Transportation StormwaterBest ManagementPractices Tool box manual,
such as grassed swales, buffer areas, preformed scourholes, 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 and minimization of
impacts to wetlands (and streams) to the ma�nxm e�ent practical. In accordance with the Environmental
Management Conm�ission's Rules (15A NCAC 2H.0506[h]), mitigation will berequired for impacts of
greater than 1 acre to wetlands. In the event that mitigation is required, the mitigation p lan shall be designed
to replace appropriate lost functions and values. North Carolina Division of Mitigation Services may be
available for assistancewith wetland mitigation.
4. In accordance with the Environmental Management Corrmrission's Rules (15A NCAC 2H.0506[h]),
mitigation will be required for impacts of greater than 300 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 stream
mitigation.
5. Future documentation, including the 401 Water Quality Certification Application, shall continue to include an
itemized listing ofthe proposedwetland and stream irnpacts 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 nr�pacts that may occur to the aquatic
environments and any mitigating factors that would reduce the impacts.
7. 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.
8. The NCDOT is respectfully reminded that all impacts, including but not limited to, bridging, fill, e�avation
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 needto be included as part ofthe 401 WaterQuality Certification Application.
9. 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
countersunkto 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 eadent practicable.
10. Wheneverpossible, theNCDWR 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 passageandnavigationbycanoeists andboaters shall notbe blocked. Bridge supports (bents)
shouldnotbe placed in the stream when possible.

11. Bridge deck drains shall not discharge directly into the stream. Stormwater shall be directed across the bridge
andpre-treatedthroughsite-appropriatemeans(grassedswales,pre-forn�ed scourholes,vegetatedbuffers,etc.)
before entering the stream. To meet the requirements ofNCDOT's NPDFS pemut NCS0000250, pleaserefer
to the most recent version ofthe North CarolinaDepartment ofTransportation StormwaterBest Management
Practices Toolbox manual for approved measures.
12. Sediment and erosion control measures should not be placed in wetlands or streams.
13. Borrow/waste areas should avoid wetlands to the ma�m e�ent practical. Impacts to wetlands in
borrow/waste areas will need to be presented in the 401 Water Quality Certification and could precipitate
compensatory mitigation.
14. The 401 Water Quality Certification application will need to specifically address theproposed methods for
stormwater management. More specifically, stormwater shall notbe permitted to discharge directly into
streams or surfacewaters.
15. Based on the information presented in the document, the magnitude of irnpacts to wetlands and streams would
require a 404 Pernut application to the Corps ofEngineers and corresponding 401 Water Quality
Certification. Please be advisedthata401 WaterQuality Certification requires satisfactoryprotectionof
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 concunence
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 e�ent practical, the development of an
acceptable stormwater management plan, and the inclusion of appropriate mitigation plans where appropriate.
16. If concrete is used during construction, a dry work area shall be maintained to prevent direct contact between
curing concrete and streamwater. 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.
17. 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 areawith chain saws,mowers, bush-hogs,orothermechanized equipment andleaving the
stumps and root mat intact allows the area to re-vegetate naturally and minimizes soil disturbance.
18. Unless otherwise authorized, placement ofculverts and otherstructures 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 ofwater and aquatic life. Design andplacement 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 NCDW R.
If this condition is unable to be met due to bedrock or otherlimiting features encountered during construction,
please contact the NCDW R for guidance on how to proceed and to deterrrrine whether or not a permit
modification will be required.
19. If multiple pipes or barrels are required, they shall be designed to mimic natural stream cross section as
closely as possibleincluding pipes orbarrels at flood plain elevation, floodplain benches,and/orsills 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.
20. If foundation test borings are necessary; it shall be noted in the document. Geotechnical work is approved
under General 401 Certification Number 4085/Nationwide Pernut 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 andthe most recent version ofNCS000250.
22. All work m 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,rockberms, cofferdams and otherdiversion structures shallbe usedto prevente�avation in
flowing water.
23. While the use ofNational Wetland Inventory (NWn maps, NC Coastal Region Evaluation of Wetland
Significance (NC-CREWS) maps and soil survey maps are useful tools, their inherent inaccuracies require
thatqualified personnelperform onsitewetland 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 shall be
inspected daily and maintained to prevent contarmnation of surface waters from leaking fuels, lubricants,
hydraulic fluids, or other toxic materials.
25. 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 shouldbeproperly designed,sized and installed.
26. Riparian vegetation(nativetreesandshrubs)shallbepreservedtothemaximum ea�tentpossible. 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 tnne. The NCDOT is reminded that is suance of a 401 W ater 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 orrequire additional inforn�ation, please contact
Rob Ridings at 919-707-8786.