U-6072B SOS.pdf

ROY COOPER
Goverua
MICHAEL S. REGAN
S'ecretary
Environmental LINDA CULPEYPER
Qll��l� y lnterim Uirec(or
April 12, 2018
MEMORANllUM
To: Sean P. Matuszewski Design Engineer, NCDOT Division 6
From: Joanne Steenhuis, NC Division of Water Resources, Wilmington Regional Office ���
Subject: Scoping comments on proposed widening to Multi-Lanes of SR l l l2 (Rockfish Road) &om SR 1003
(Camden Road) to SR 1 I 15 (Golfview Road) in Hope Mills. Cumberland County, STIP U-6072B.
Reference your correspondence dated April 2, 2018 in which you requested comments for the referenced project.
Preliminary analysis of the project reveals the potential for multiple impacts to streams and jurisdictional wetlands
in the project area. More specifically, impacts to:
Stream Name R1°er S[ream Classification(s) Stream Index Number 303(d) Listing
Basin
UT to Permastone Lake Ca e Fear B 18-31-22 1 No
Further investigations at a higher resolution should be undertaken to verify the presence of other streams and/or
jurisdic[ional wetlands in [he area. In the event that anyjurisdictional areas are identified, the Division of Water
Resources requests tha[ NCDOT wnsider the following environmental issues for the proposed projech
General Project Commeuts:
The environmental document should provide a de[ailed and itemized presentation of the proposed impac[s to
weHands and streams with corresponding mapping. If mi[igation is necessary as required by 15A NCAC
2H.0506(h), it is preferable to present a conceptual (if not finalized) mi[igation plan wi[h the environmental
documentation. Appropriate mitigation plans will be required prior to issuance of a 40l W ater Quality
Cer[ification.
Environmental impact statement altematives shall consider design criteria that reduce the impacts to streams
and wetlands from storm water runoff. These altematives shall include road designs that allow for treatment
of the storm water runoff through best management practices as detailed in the most recent version of the
NaTh Curo[rna Departn�ent of Transportation Stormwater Best Management Practices Tool box manual,
such as grassed swales, buffer areas, prefonned scour holes, retention basins, etc.
After the selection of the preferred alternative and prior to an issuance of the 401 Water Quality Cer[ification,
the NCDOT is respectfully reminded that they will need to demonstrate [he avoidance and minimization of
impacts to wetlands (and streams) to the maximum extent prac[ical. In accordance with the Environmental
Management Commission's Rules (ISA NCAC 2H.0506[h]), mitigation will be required for impacts of
greater than I acre to wetlands. In the event that mitigation is required, the mitigation plan shall be designed
[o replace appropriate lost functions and values. North Carolina Division of Mitigation Services may be
available for assistance with weNand mitigation.
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4. In accordance widi the Environmental Management Commissiods Rules (ISA NCAC 2H.0506[h]),
mitigation will be required for impacts of greater Ihan 150 linear feet to any perennial s[ream. 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 witl� stream
mitigation.
5. Future documentation, including the 401 Water Quality Certification Application, shall continue to include an
itemized listing of [he proposed weNand and stream impac[s with corresponding mapping.
6. The NCDWR is very concerned with sedimen[ and erosion itnpacts 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 cu�nulative and secondary impacts anticipated as a result of this project is required. The type
and detail of analysis shall conform [o Ihe NC Division of Water Kesource Policy on the assessment of
secondary and cumulative impacts da[ed April 1 Q 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 construction impacts, temporary or otherwise,
also need to be included as part of the 401 Water Quality Certification Applica[ion.
9. Where streams must be crossed, the NCDWR prefers bridges be used in lieu of culverts. However, we realize
that economic considerations often require [he 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 NCDO'C
should not install the bridge bents in the creek, to the maximum extent practicable.
10. Whenever possible, the NCDWR prefers spanning structures. Spanning structures usually do not requ've
work within tlte stream or grubbing of the streambanks and do not require s[ream channel realignmenL 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.
I 1. 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 en[ering Ihe stream. To meet the requiremen[s of NCDOT's NPDES permit NCS000025Q please refer
to the most recent version of the North Carolinu Department of Transportatron Sta•mwater Best Managemen[
Practices Toolbox manual for approved measures.
12. Sediment and erosion control measures should not be placed in wet(ands or streams.
13. Borrow/waste areas should avoid wetlands to the maximum extent practicaL Impacts to weNands in
borrow/waste areas will need to be presented in [he 401 Water Quality Certification and could precipitate
compensatory mitigation.
14. 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.
15. The DWR cannot comment on permit requirements with the limited infonnation provided. Detailed field
delineation is required to detennine the presence or absence ofjurisdictional resources within the project
limits. In addition, NCDOT must provide an estimate to any resources located witltin the construction limits
of [he project area before we can specifically comment on NCDWR permit eligibility.
Please be advised that a 401 Water Quality Certifica[ion requires satisfactory protection of wa[er quality to
ensure tha[ water quality standards are met and no wetland or stream uses are lost. Final permit authorization

will require the submittal of a formal applica[ion by the NCU07' to tl�e US Army Corps of Engineers and
written concurrence from the NCDWR. Ylease be aware that any approval will be contingent on appropriate
avoidance and minimizatio� of wetland and sheam impac[s [o the maximum extent practical, the development
of an acceptable stormwater management plan, and the inclusion of appropriate mitiga[ion 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 stream water. Water that inadvertently contacts unwred concrete shall not be discharged
to surface waters due to the potential for elevated pH and possible aquatic life and fish kills.
17. [f temporary access roads or derours are constructed, [he site shall be graded to i[s preconstruction contours
and elevations. Dis[urbed areas shall be seeded or mulched to stabilize the soil and appropriate native woody
species shall be planted. When using tetnporary structures [he area shall be cleared but not grubbed. Clearing
the area with chain saws, mowers, bush-hogs, or other mechanized equipment and leaving the s[umps and root
mat intact allows the area to re-vegetate naturally and minimizes soil disturbance.
18. Unless otherwise au[l�orized, placement of culverts and other structures in wa[ers and streams shall be placed
below the elevation of [he streambed by one foot for all culverts with a diameter greater than 48 inches, and
20 percent of the wlvert 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 struc[ures including temporary
erosion control tneasures 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 [hat 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 limi[ing features encountered during construction,
please contact [he NCDWR for guidance on how to proceed and [o determine whether or not a permit
modification will be required.
19. If multiple pipes or barrels are required, they shall be designed to mimic nawral s[ream cross section as
closely as possible including pipes or barcels 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 shuctures typically decreases water velocity causing sediment 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 Certi£cation 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 mos[ recent version of North Carolina Sediment and Erosion Control
Planning and Design Manual and the most recent version of NCS000250.
22. All work in or adjacent to stream waters shall be conducted in a dry work area. Approved BMP nteasures
&om [he most current version of the NCllOT Construction and Maintenance Activities tnanual such as
sandbags, rock berms, cofferdams and oHter diversion structures shall be used to prevent excavation in
flowing water.
23. While the use ofNational Wetland Inventory (NWI) maps, NC Coastal Region Evalua[ion of Wetland
Significance (NGCREWS) maps and soil survey maps are useful tools, their inherent inaccuracies require
that qualified personnel perfonn onsite wetland delineations prior to permit approval.
24. Heavy equipment should be operated from the bank radter than in stream channels in order to minimize
sedimentation and reduce the likelil�ood of introducing other pollu[ants into streams. This equipmen[ shall be
inspected daily and maintained to prevent contamination of surface waters from leaking fuels, lubrican[s,
hydraulic fluids, or other toxic materials.
25. Riprap shall not be placed in tlie active Ihalweg 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 (na[ive trees and shrubs) shall be preserved to [he maximum extent possible. Riparian
vegetation must be reestablished within the construction limits of tlie project by the end of the growing season
following cotnpletion of construction.
Thank you for requesting our input at this time. The NCDOT is reminded that issuance of a 40l Water Quality
Certifica[ion requires that appropriate measures be ins[ituted 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
Joanne Steenhois at [phone] orjoanne.stee�ilmis@�cdenr.gov.
Electronic copy only distribution:
Susan Westberry, SEPI
Jim Rerko, DEO NC DOT Division 6
Liz Hair, US Army Cotps of Engineers, Wilmington Field Office
Kristi Lynn Carpenter, NCDWR
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