R-5829-scoping

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ROY COOPER
G u rnr�� n r
MICHAEL S. REGAN
S�c��e1u���
Environmental LINDA CiILPEPPER
Quallty Intcrim Directr,r
November 27, 2017
MEMORANDUM
To
Fro m:
Matt Clarke, P�, NCDOT Division 4
RoU Ridings, NC Division of Water Resources, Transportatiou Peinutting Branch
SuUject: Scoping corrnnents on proposed upgrades to US Hwy 70 in Johnston & Wayne Counties, TIP # R-5829
Reference your con�esponclence receivEcl Noveinber 14, 2017 in which you requested coibments for the referenced
project. PreGminary analysis of the project reveals the potenYial for multipLc impacts to strean�s , ri�arian bufters,
and juiisdictional wctlands in thc projcct arca. Moec spccifically, iropacts to thc following str�an�s (and thcir
trib utaries ):
River Basin & Stream Index
Stream Name Subbasin Stream Classifications Number 303(c� Listing?
Little River NEU 06 W S-N; NSW 27-57-(20.2) No
Cl�arles Branch N�U 12 W S-N; NSW 27-55-1 No
Beaverdain Creek NEU 12 W S-N; NSW 27-55 No
MoccasinCreek NEU 12 C; NSW 27-53-(0.5) Yes
(& Holts Pond)
Further ulvestigations at a 1ligher resolution sllould be undertalcen to verify the presence of other streail�s and/or
jurisdictionaL wetlands ul the area. In the eventthat any jurisdictional areas are identified, the Division of Water
Rcsources requests thatNCDOT considerthc following e��v�-onmental isstiics fortheproposcdproject:
Project Specific Comments:
Little River, Charles Branch, Beaverdam Creek, and their Yributaries are class WS-1V; NSW waters ofthe StaYe.
The NCDW R is very concerned with sediment and erosion impacts tl�at couid result froin this project. The
NCDWR reconunends that highly protective sediinent and erosion control BMPs Ue implemented to reduce tlie
rislc of nutriznt n�noffto these streams. Additioually, to meet the requu-ements of NCDOT's NPD�S pennit
NCS0000250, tl�e NCDWR requests thatroaddesign plans provide treatment ofthe stonr� water �unoffthrough
best management practices as detailed in the most recent version of the North Cczrolina Departrraentof'
Ti�unspo��tation Stoi-��nwaterBest Managemerit P�^actices Toolbox manual.
2. Moccasin Creek, Holts Pond, and their tributaries are class C; NSW; 303(d) impaired waters of the State. The
N�CDW R is very concemed witl� sediment and erosion impaets tl�at could result from this pi•oject. The NCDW R
recoilunends that the imost protective� sediillent and erosion control BMPs be implemented in accordance witl�
Desig��7 Stcii2clardsinSensitive d�ater-.sheds (15A NCAC 04B .0124) to reduce theris]< o�ffurt�her impauinent to
tl�ese waters. Additionally, to i��eet the requirements of NCDOT's NPDES pennit NCS0000250, the NCDWR
reqttests that roaddesign plans provide treatment of the stonll water runofFthrougl� bestmanagement practices
as detailed in the most recent version of the North Ccrrolina Depnrtmentof Truraspor-tatior� Ston7�waterBcst
Mcrfzagerne»tPractices Toolbox manual.
"NnThir��q Cnr����re� - _
Statc ofNorth Carolina I Enviromncntal Quality
1617 Mail Se�vicc Center I Raleigh, North Carolina 27(i99-1617

3. This project is within the Neuse River Basin. Riparian buffer impacts shall be avoided and minimized to the
greateste�ent possiblepursuantto 15A NCAC 2B.0233. New development activities located in theprotected
50-foot wide riparian areas within the basin shall be limited to "uses" identified within and constructed in
accordancewith 15A NCAC .02B .0295. Buffer mitigation may be required for buffer impacts resultmg from
activities classified as "allowable with mitigation" within the"Table ofUses"sectionoftheBuffer Rules or
require a variance under the Buffer Rules. A buffer mitigation plan, including use of the North Carolina
Division of Mitigation Services, must be provided to the NCDWR prior to approval of the Water Quality
Certification. Buffer mitigation may be required for buffer irrypacts resulting from activities classified as
"allowable with mitigation" within the"Table ofUses" sectionofthe Buffer Rules orrequire avariance under
the Buffer Rules. A buffer mitigation plan, coordinated with the North Carolina Division of Mitigation
Services, must be provided to the NCDWR prior to approval of the Water Quality Certification.
General Project Comments:
The environmental document should provide 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 altematives shall consider design criteria thatreduce the impacts to streams
and wetlands from stormwater runoff. These altematives shall mclude road designs that allow for treatment
ofthe storm water runoffthrough best 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�mum e�ent practical. In accordance with the Environmental
Management Commission'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 Commission'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
iternized listing of the proposed wetland and stream impacts with corresponding mapping.
6. The NCDWR is very concemed with sed'unent 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.
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 irrypacts dated April 10, 2004.
8. 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 irrypact calculations. These unpacts, in addition to any construction irnpacts, temporary or otherwise,
also needto be included as part ofthe 401 WaterQuality Certification Application.

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, m 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.Fishpassageandnavigationbycanoeistsandboatersshallnotbeblocked. Bridge supports(bents)
should not be placed in the stream when possible.
ll. 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 Toolboxmanual for approvedmeasures.
12. Sediment and erosion control measures should not be placed in wetlands or streams or in Zone 1 of Buffers.
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 'm 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 inforn�ation presented in the document, the magnitude of unpacts to wetlands and streams may
require an Individual Permit application to the Corps of Engineers 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
pernut authorization will require the submittal of a forn�al 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 e�ent practical, the development of an
acceptable storniwater 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 rinilched 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, orother mechanized equipment and leaving 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 havmg 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 far guidance on how to proceed and to deterrnine whether ar not a permit
modification will be required.
19. If multiple pipes or barrels are required, they shall be designed to nvmic natural stream cross section as
closely as possibleincluding pipes orbarrels at flood plain elevation, floodplam 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 mamtenance 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 irnplemented and
maintained in accordance with the most recent version of North Carolina Sediment and Frosion Control
Planning andDesign Manual andthe most recent version ofNCS000250.
22. 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,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 contarnination of surface waters from leaking fuels, lubricants,
hydraulic fluids, orothertoxic materials.
25. Riprap shall not be placed 'm 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 (native trees and shrubs) shallbe preserved to the maximum e�dent possible. Riparian
vegetation must be reestablished within the construction limits of the project by the end of the growing season
following completion ofconstruction.
Thank you for requesting our input at this time. 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 rob.ridin�sna,ncdenr. o�v or 919-707-8786.
Electronic copy only distribution:
Jackie Obediente, Three Oaks Engineering
Chad Coggins, NCDOT Division 4 DEO
File Copy