U-5790 College Rd improvements SOS.pdf

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Fnvironrne��lal LINDA CULPLPPER
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April 6, 201 S
MEM012ANllUM
To: Trace Howell, PE, NCDOT Division 3
Frotn: Joanne Steenhuis, NC Division of Water Resources, Wil�uington Regioi�al Office �
SubjecL Swping comments on proposed improvemen[s to College Road (NC 132) in New Hanover County, ST[P
U-5790.
Reference your correspondence dated March 28, 2018 in which you reques[ed comments for the referenced project.
Preliminary analysis of the project reveals [he poten[ial for mul[iple impacts to streams and jurisdictional wetlands
in the project area. More specifically, impacts to:
Sh•eam Name River Basin Stream Classiftcatiou(s) Stream Index 303(d) Listing
Number
Mott Creek Ca e Fear C;Sw 18-82 No
Fudher imestigations at a liigher resolution should be undertake� to verify the presence of other streams and/or
jurisdictional wetlands in the area. ln the event that any jurisdic[ional areas are identified, Ihe Divisioi� of Water
Resources requests tha[ NCllOT consider the following environmental issues for [he proposed project:
General Project Co�mnents:
I'he environmental document should provide a detailed and itemized presentation of the proposed impacts lo
wetlands and streams with corresponding mapping. If mi[igation is necessary as required by I SA NCAC
2H.0506(h), it is preferable to presen[ a concep[ual (if not finalized) mitigation plan wi[h Ihe environmental
documen[ation. Appropriate miliga[ion plans will be required prior to issuance of a 401 Water Quality
Certification.
2. Environmen[al impact statement altematives shall consider design criferia that reduce fhe impacts to streams
and wetlands frout storm water runoff. 7'hese alternatives shall include road designs thaf allow for treatment
of the stonn water runoff through best management practices as detailed in the most recent version of the
No��[h Ca��o(inn Dcprrrhne�v( of�Trnnspa•!alion Slo�•imvnler Best Mm�ugement R��re(ices Too( box manual,
such as grassed swales, buffer areas, prefonned scour holes, relen[ion basins, etc.
Afler the selectioi� of ihe preferred allernalive and prior to an issuance of Ihe 401 Wa[er Quality Cer[ificatioq
the NCDO'f is respectfiilly reminded [hat they will need to demonslrate the avoidance and minimization of
impacts to wedands (and slreams) to the maximmn extenl prac[ical. ln accordance wi[h Ihe Environmenlal
Mnnagemenl Commission's Rules ( I SA NCAC 2H.0506�h]), mitigation will be reyuired for impacts of
greater than I acre [o wedands. In the event that mifigation is required, [he mitigation plan shall be designed
to replace appropria[e lost functions and values. North Carolina Division of Mitigalion Services may be
available for assistance with wetland mitigation.
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4. In accordance with the Environmental Management Commission's Rules (15A NCAC 2H.0506[h]),
mitigation will be required for impacts of greater than I50 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 Mi[igation Services may be available for assistance with stream
mitigation.
5. Future documentation, including the 40l Water Quality Certification Application, shall continue to include an
itemized listing of the proposed wetland and sheam impacts with corresponding mapping.
6. The NCD WR 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. An analysis of cumulative and secondary impacts anticipated as a result of this project is required. The type
and detail of analysis shall conform ro 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, 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 constructio� impacts, temporary or otherwise,
also need to be included as part of the 401 Water Quality 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
countersunk to allow unimpeded passage by fish and other aquatic organisms. Moreover, in areas where high
quality wetlands or sheams aze impacted, a bridge may prove preferable. When applicable, the NCDOT
should not install the bridge bents in the creek, to the ma�cimum extent practicable.
10. Whenever possible, the NCDWR prefers spanning structures. Spanning structures usually do not require
work within the sheam or grubbing of the streambanks and do not requae stream channel realignment. The
horizontal and vertical clearances provided by bridges shall allow for human a�d 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.
11. Bridge deck drains shall not discharge directly into the stream. Stormwater shall be d'vected across the bridge
and pre-treated through site-appropriate means (grassed swales, pre-formed scow holes, vegetated buffers, etc.)
before entering the sheam. To meet the requirements of NCDOT's NPDES permit NCS000025Q please reFer
to the most recent version of the North Carolina Department of Transportation Stormwater Best Management
Practices Toolbox manual for approved measures.
l2. Sediment and erosion conhol measures should not be placed in wetlands or streams.
13. Borrow/waste areas should avoid weHands to the maximum extent practicaL Impacts to wetlands in
borrow/waste azeas will need to be presented in the 401 Water Quality Certification and could precipitate
compensatory mitigation.
l4. The 40l Water Quality Certification applica[ion will need to specifically address the proposed methods for
stormwater management. More specifically, srormwater shall not be permitted to discharge directly into
streams or surface waters.
15. The Division of Water Resources (DWR) cannot comment on permit requirements with the limited
information provided. Detailed field delineation is required to determine the presence or absence of
jurisdictional resources within the project limits. In addition, NCDOT must provide an estimate to any
resources located within the construction limits of the project area before we can specifically commen[ on
NCDWR permit eligibility. Depending on the amount of impacts either an Individual Permit or a Nationwide
Permit application may be required from the US Army Corps of Engineers with a corresponding application to

the D WR. Please be advised that a 401 Water Quality Certification requires satisfactory protection of water
quality [o ensure that water quality standazds are met and no wetland or sheam uses aze lost. Final permit
authorization will require the submittal of a formal application by the NCDOT and written concurrence Gom
the NCDWR. Please be aware that any approval will be contingent on appropriate avoidance and
minimization of wetland and sheam impacts to the maximum extent practical, [he development of an
acceptable srormwater management plan, and the inclusion of appropriate mitigation plans where appropriate.
l6. If concrete is used during construction, a dry work area shall be main[ained to prevent direct contact between
curing concrete and stream water. Water Ihat inadvertently contacts uncured concrete shall not be discharged
ro surface waters due to the potential for elevated pH and possible aquatic life and fish kills.
l7. If temporary access roads or derours are constructed, the site shall be graded to its precons[ruction 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 shuctures the area shall be cleared but not grubbed. Cleazing
the area with chai� 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.
18. Unless otherwise authorized, placeme�t of culverts and other shvctures in waters and streams shall be placed
below the elevation of the streambed by one foot for all culverts with a diameter geater than 48 inches, and
20 percent of the culvert diameter for culverts having a diameter less than 48 inches, to allow low How
passage oFwater 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, adjacent to or upstream and downsheam of the above sWctures. 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.
19. If multiple pipes or barrels are requ'ved, they shall be designed ro mimic natw�al skeam 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 requ'ves
increased maintenance and disrupts aquatic life passage.
20. If foundation test borings aze necessaty; it shall be noted in the document. Geotechnical work is approved
under General 401 Certification Number 41323/Nationwide Permit 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 of NC5000250.
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, rock berms, cofferdams and other diversion structures shall be used to prevent excavation in
flowing water.
23. While the use of National Wetland Inventoty (N WI) maps, NC Coastal Region Evaluation of Wetland
Significance (NGCREWS) maps and soil survey maps are useful tools, their inherent inaccuracies require
that qualified personnel perform onsite wetland delineations prior to permit approval.
24. Heary equipment should be operated from the bank rather than in sheam channels in order to minimize
sedimentation and reduce the likelihood of inhoducing other pollutants into sheams. 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 should be properly designed, sized and installed.
26. Riparian vegetation (native hrees and shrubs) shall be preserved to the maximum extent possible. Riparian
vegetation must be reestablished within the conshuction 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 Utat issuance of a 401 Water Quality
Certification requires that appropriate measures be instituted to ensure that water quality standards are met and
designated uses aze not degraded or lost. If you have any questions or require additio�al information, please contact
Joanne Steenhuis at [phone] [e-mail].
Elechonic copy only dishibution:
Paul Koch, PE, Stantec
Brad Shaver, US Army Corps of Engineers, Wilmington Field Office
Mason Herndon, DEO NC DOT Division 3
Cathy Brittingham, NC Division of Coastal Management
Stephen Lane, NC Division of Coastal Management
Kristi Lynn Carpenter, NCDWR
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