U-6001 SOS Cumberland May 18

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Environmenitil LINDA CULPEPPER
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May I 1, 2018
MLMORANDUM
To: Jun Rerko, PWS, DEO, NCDOT Division 6
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From: Joanne Steeiil�uis, NC Division of Wa[er Resources, Wihnington Regional Oftice J�
Subjech Scoping comments on proposed 'unprovemeii[s to NC 59 (South Main Street) &om Shipman Road (SR
1243) to Parkton Road (SR I 1 18) south of downtown Hope Mills in Cumberland County, STIP Projec[
No. U-6001, WBS No.46960.1.1.
Reference your correspondence dated April 17, 2018 and revised April 19, 2018 in which you requested comments
for the referenced project. Preliminary analysis of the project reveals the potential for nmltiple impacts to streams
and jurisdic[ional wellands in [he project area. More speci5cally, impacts to:
Stream Name River Basin Stream Classification(s) Stream Index . 303(d) Listiug
Number
Rockfish Creek Ca e Fear B I 5-31- 18 N/A
Furtlter invesliga[ions at a higher resoWtion should be undertaken to verify tlie presence of other streams and/or
jurisdictional wetlands in the area. In the event tliat airy jurisdic[ional areas are identified, dte Division of Water
Resources requests tha[ NCDOT consider the following environmental issues for the proposed projecr.
General Project Commeuts:
The environmental document should provide a detailed and itemized presenta[ion of [he proposed impacts to
wetlands and streams wilh corresponduig mapping. If mitigation is necessary as required by 15A NCAC
2H.0506(h), it is preferable [o presen[ a conceptual (if no[ finalized) mi[i�ation plan witl� the environmenCal
documentation. Appropriate mitigation plans will be required prior [o issuance of a 401 Water Quality
Certification.
2. Environmental impacl statemenl alternalives shall consider design criteria that reduce [he impacts [o slreams
and wetlands from s[orm wa[er runofE These alternatives shall include road designs [ha[ allow for [rea[ment
of the storm wa[er runoff througli best managemen[ prac[ices as detailed in [he most recent version of the
No��lh Cn�•oliian Depm�lmen! cfTrnnspa�l�rlion S[ori�ewn(er 6es•( Mnnugcmen( Pruclices 7bo! box ntanual,
such as grassed swales, buffer areas, prefonned scour holes, rete�tio�� basins, etc.
ARer Ihe selec[ion oFthe preferred alterna[ive and prior to an issuance of the 401 Wa[er Qualify Certification,
the NCDOT is respectfully reminded tliat [hey will need [o demonstra[e [he avoidance and minimization of
impec[s fo weNands (and slreams) to [he maximum extenl practicaL In accordance with [he Environmental
Managemenl Commission's Rules ( I SA NCAC 2H.OSO6�hJ), miligalion will be required for impacts of
greater lhan I ucre to weHands. In the event [hat mitigation is required, tlte miligation plan shall be designed
to replace appropria[e lost Func[ions and values. North Carolina Division of Mitigation Services may be
available for assistance widi wetland miligation.
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4. In accordance with the Environmental Management Commissiods Rules Q SA NCAC 2H.0506�hj),
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 Mitigation Services may be available for assistance with stream
mitigation.
5. Future documentation, including the 40l Water Quality Certification Application, shall continue [o include an
itemized listing of the proposed wetland and sheam impacts with corresponding mapping.
6. The NCDWR is very concemed with sediment and erosion impacts that could result Gom this project. The
NCDOT shall address these concems 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 a(1 impacts, including but not limited [o, bridging, fill, excavation
and clearing, and rip rap ro 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.
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
qualiry wetlands or sheams are impacted, a bridge may prove preferable. When applicable, the NCDOT
should not install the bridge bents in the creek, to the ma�cimum extent practicab(e.
10. Whenever possible, the NCD WR prefers spanning structures. Spanc�ing structures usualty do not require
work within the stream or grubbing of the streambanks and do not require stream channel realig�ment. The
horizontal and vertical cleazances provided by bridges shall allow for human and wildlife passage beneath the
shucture. Fish passage and navigation by canoeists and boaters shall not be blocked. Bridge supports (bents)
should not be placed in Ute stream when possible.
l 1. Bridge deck drains shall not discharge directly into the stream. Stormwa[er 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 requiremen[s of NCDOT's NPDES permit NCS0000250, please refer
[o the mos[ recent version of the North Carolina Department ofTransportatian Stormwater Best Management
Practices Toolbox manual for approved measures.
12. Sediment and erosion control measures should not be placed in wetlands or streams.
l3. 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 40l 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 information provided. Detailed field
delineation is required to determine the presence or absence ofjurisdictional resources within the project
limits. In addition, NCDOT mus[ provide an estimate to any resources bcated within the construction limits
of the project area before we can specifically comment on NCDWR permit eligibility.
Please be advised that a 40l Water Quality Certification requires satisfactory protection of water quality to
ensure that water quality standards are met and no wetland or stream uses aze lost. Final permit authorization

will require the submittal of a formal application by the NCDOT and written wncurrence from the NCUWR.
Please be aware [hat any approval will be contingent on appropriate avoidance and minimization of wetland
a�d stream impacts to the maximum extent 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 stream watec 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 aze 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.
18. Unless otherwise authorized, 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 geater than 48 inches, and
20 percent of the culvert diameter for culverts having a diameter less than 48 inches, ro 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 bazilcs, adjacent [o or upstream and downstream of the above structures. The applicant is
requ'ved to provide evidence that [he 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 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
requ'ved where appropriate. Widening the stream channel should be avoided. Stream channel wideni�g at the
inlet or outlet end of structures typically decreases water velocity causing sediment deposition that requ¢es
increased maintenance and disrupu aquatic life passage.
20. If foundation test borings are necessary; it shall be noted in the document. Geotechnical work is approved
uc�der Genera1401 CeRification 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 NCS000250.
22. All work in or adjacent to stream waters shall be conducted in a dry work area. Approved BMP measures
&om the most curcent 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 Inventory (NWI) 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. Heavy equipment should be operated &om the bank rather than in stream channels in 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 Gom leaking fuels, lubricants,
hydraulic fluids, or other toxic materials.
25. Riprap shall not be placed in the active thalweg channel or placed in the sheambed in a manner that precludes
aquatic life passage. Bioengineering boulders or structures should be properly designed, sized and installed.

26. 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 wnstruction.
Thank you for requesting our input at this time. The NCDOT is reminded that issuance of a 401 Water Quality
Certi6cation requires [hat appropriate measures be instituted to ensure that water quality standazds are met and
designated uses are not degraded or lost. If you have any questions or require additional information, please contact
Joanne Steenhuis at [phone] or [e-mail].
Electronic copy only distribution:
Sean Matuszewski, PE/, Project Manager NC DOT Division 6
Liz Hair, US Army Corps of Engineers, Wilmington Field Office
Kristi Lynn Carpenter, NCDWR
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