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HomeMy WebLinkAbout20171649 Ver 1_U-5999-scoping_20171128;::,.� ROY COOPER G u rnr�� n r MICHAEL S. REGAN S�c��e1u��� Environmental LINDA CiILPEPPER Quallty Intcrim Directr,r November 28, 2017 MEMORANDUM To Fro m: Chad Coggins, NCDOT Division 4 Envu-onmental Officer RoU Ridings, NC Division of Water Resources, Transportation Pemutting Branch Subject: Scoping comments on proposed new location road (Kellie Drive) in Johnston Cotmty, State Project No. 47117. L 1, TIP No. U-5999. Reference your con-espondence received Noven�ber 22, 2017 in wl�ich yo�i requested commcnts for the referenced projcct Prelinvnary analysis of the projcct revcals the potential for i�r�pacts to jurisdictional wetlai�ds in the project area. Further uivestigations at a higherresolution should bc undertakei� to veiify the presence ofother streams and/orj�irisdictional wetlands in thcarca. In the eventthatany jurisdictional arcas arc identificd, theDivision of Watcr Rcsources requests tl�atNCDOT considcrthc following environmental issues for thcproposcdprojcct: Project Specific Comments: The nearesrnamed waterUody, Neuse River, and its tributaries, are class WS-IV; NSW waters ofthe State. The NCDWR is very concen�ed with sed'nnent and erosion in�pacts that cottld result froiT� this project. The NCDWR recotrnnends that L�ighly protective sed'nnent and erosion control BMPs be implen�ented to reduce the rislc of ntiitrient ntnoffto the Neuse. Additionally, to meet the requireinents ofNCDOT's NPDES pentut NCS0000250 the NCDWR reqn�sts thatroad design plans provide treatment of the stoimwater itiinoff throLtgl� best management practices as detailed in the most recent version of the Nor•th Ca�-oli»uDe�ar•rnzetrtof Ti�ansportatiot� Storrn�vaterBest ManagernentPractices Toolbo.x manual. 2. This project is within thc Ncusc River Basin. Riparian bliffcr impacts shall bc avoided and nvnnr�ized to d1e greatestezctent possibLep�irsuantto 15A NCAC 2B.0233. New developinent activities located in theprotected 50-foot wide riparian areas within the basu� shall bc li�nited to "uses'" identified within and constnicted ni accordance with 15A NCAC .02B .0295. Buffer mitigation may be required for buffer n�acts resulting fi•om activities classified as "allowable witl� mitigation" within the "Table ofUses" section of tlie Buffer Rules or require a vaiiance undertheBuffer Rules. A buffer mitigation pla�1, u�cluding useoftl�e North Carolina Division of Mitigation Services, must beprovided to the NCDWR p�ior to approval ofthe Water QuaGty Certification. Buffer mitigation may be requued for buffer unpacts resulting from activiries classified as "allowable with nutigation" withul tl�e"Table ofUses" section ofthe Buffer Rules orrec�uire a variance uuder the Buffer Rules. A buffer mitigation plan, coordinated with the North Carolina Division ofMitigation Seivices, must be pcovided to the NCDWR prior to approval of the Water Quality Certificatio��. General Project Comments: The envn-oninental doctunent should provide a detailed and itein'rzed presentation of the proposed impacts to wetlai�ds and sh•can�s witl� coi-responding mapping. If nntigation is necessary as rcquired by 15A NCAC 2�-I.0506(h), it is preferable to presenta conceptual(if notfinalized) initigation plan with the environmental documentation. Appropriate mitigation plans will be requued prior to issuance ofa 401 Water Quality Certification. `''Ne�Thir��q Cnr��pare� _ Statc ofNorth Carolina I Enviromncntal Quality 1617 Mail Se�vicc Center I Raleigh, North Carolina 27(i99-1617 2. Environmental impact statement altematives shall consider design criteria thatreduce the impacts to streams and wetlands from stormwater runoff. These altematives shall include road designs that allow for treatment ofthe 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�mum e�ent practical. In accordance with the Environmental Management Coimiussion's Rules (15A NCAC 2H.0506[h]), mitigation will berequired for irnpacts 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 Corrm�ission's Rules (15A NCAC 2H.0506[h]), mitigation will be required for nr�pacts 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 assistancewith stream mitigation. 5. Future documentation, including the 401 Water Quality Certification Application, shall continue to include an itemized listing ofthe proposedwetland and stream impacts with corresponding mapping. 6. The NCDWR is very concerned with sed'unent 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. 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, eYcavation and clearing, and rip rap to jurisdictional wetlands, streams, and riparian buffers need to be included in the final impact calculations. These impacts, m 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 unirnpeded 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 shouldnot install the bridge bents in the creek, to the maximum e�ent 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 passagebeneaththe 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. 11. Bridge deck drains shall not discharge directly into the stream. Stormwater shall be directed across the bridge andpre-treatedthroughsite-appropriatemeans(grassedswales,pre-fornied 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 streairn. 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 inforn�ation presented in the document, the magnitude of irrypacts to wetlands and streams may require a Nationwide 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 fom�al application by the NCDOT and written concurrence from the NCDWR Please be aware that any approval will be contingent on appropriate avoidance and minitnization 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 stab ilize 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 having a diameter less than 48 mches, 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 bemg maintained if requested 'm writmg 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 determine whether or not a permit modification will be required. 19. If multiple pipes orbarrels are required, they shallbe designedto inimic 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 sed'unent 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 and the 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,rockbern�s, cofferdams and otherdiversion structures shallbe usedto preventeYcavation m flowing water. 23. While the useofNational Wetland Inventory(NWn maps, NC CoastalRegion Evaluation ofWetland Significance (NC-CREWS) maps and soil survey maps are useful tools, their mherent inaccuracies require that qualified personnelperform onsite wetland delineations prior to permit approval. 24. Heavy equipment should be operated from the bank rather than in stream channels m 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. 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 e�entpossible. 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 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.