HomeMy WebLinkAboutDWR Scope and Comments_U-5757ROY COOPER
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MICHAEL S. REGAN
Secr� rro � �
Environmental LINDA CULPEPPER
QUClllty Interim Drre�vor
February l2, 2018
MEMORANDUM
To: Lynn Hardison, SEPA Coordinator, DEQ; and
William Blanton, Projeet Development Teain Lead, NCDOT, Division 9
February 12, 2018
From: Dave Wanucha, NC Division of Water Resources, Winstoil Salem Regional Office ��yV
Subject: Scoping co�n�nents for U-5757; Proposed NC 8 wideuing. SEPA Project, 18-0199.
Reference your correspondence dated January 22, 2018 in which you rcquested commei�ts for tL�e rcfcrenced projc,ct.
Preli�ninary anaLysis of the projects reveals the potential for multiple impacts to streams and jurisdictional wetlands
in the project area. More specifically, impacts to stt�eams in Tab(e 1 below.
Table l. Streams otent
Stream Name
UT to Michael Branch
UT to Leonard Creek
impacted by proposed ro'ect.
River Basin Stream
Classificatio
Yadlcin Pee Dee C
Yadlcin Pee Dee C
Stream Index Number
12-113-3
12-119-8-(3)
303(d) Listing
1►Ci7
No
Further investigations at � higher resolution should be Lmdert�lcen to verify the presence of other sh-eams and/or
jtuisdictional wetlands in the area. In the eve�nt that any jurisdictional areas are identified, tl�e Division of Water
Reso�u-ces requests that NCDOT consider the following enviroml�ental issues for the proposed project:
General Project Comments:
1. Furiire environmental documents should provide a detailed and itemized presentation of the proposed impacts
to wetlands and streams with corresponding mapping. if mitigation is necessary as required by 1 SA NCAC
2H.0506(h), it is preferable to present a conceptual (if not finalized) mitigation plan with the environmental
doctmientation. Appropriate mitigation plans will be required prior to issuance of a 401 Water Quality
Certiiication.
2. Enviromilental impact statement alternatives shall consider design criteria that reduce the iinpacts to streams
and wetlands fi•om storm water iitn�ff. These alternatives shall include road designs that allow for treatment
of the storin water runoff through best management practices as detailed in the most recent version of the
North Carolrna Departm�ent o f Ti-aizsportation Storn�ti-vater Best Mnrragernent Practrces Tool box manual,
such as grassed swales, buffer areas, preformed scour holes, retention basins, etc.
3. After the selection of the preferred alternative and prior to an issuance of the 40l Water Qualiry Certificatioi�,
the NCDOT is res�ectfiilly ren�inded that they will need to demonsh-ate the avoidance and �ninimization of
impacts to wetlands (aild streams) to the inaximum extent praetical. in accordance with the Ei�vironmental
Management Commission's Rules (1 SA NCAC 2H.0506[h]), mitigation will be required for impacts of
greater than 1 aere to wetlands. Ti� the evei�t that mitigation is required, the mitigation plan sl�all be designed
to replace appropriate lost f�mctions and values. Nort11 Carolina Division of Mitigation Services may be
available for assistance with wetland initigation.
4. ln accordance witl� the Environmental Management Coininission's Rules (15A NCAC 2H.0506[h]),
mitigation will be required for iinpacts of greater than 3001inear feet to any perennial stream. ln the event
that mitigation is required, the mitigation pLan shall be designed to replace appropriate lost fiincrions and
=�`T�Jnfihi�� Cnr���a�res --
State of Noitli Carolina I Enviromnental Qutlity
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
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 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, fi11, 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 permit 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 maximum 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 autharization 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 autharized, 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, adj acent 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 velocity 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 Genera1401 Certification Number 4085/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 permit 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 sha11 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) 776-9703 or Dave.Wanucha@ncdenr.gov.
Electronic copy only distribution:
Bryan Roden-Reynolds, US Army Corps of Engineers, Charlotte Field Office
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