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.