HomeMy WebLinkAbout20210633 Ver 1_Scoping Comments_20180521ROY COOPER
Go��n�nm�
MICf1AGL S REGAN
S'a<'relary
Fnvrroi�mer�lul I.INDA CULPEPPBR
Quality laleriui l)irerlm
May 21, 2018
MGMORANDUM
To: Jim Rerko, DEO, NCDOT Division 6
From: Joanne Steenhuis, NC Division of Water ftesources, Wilming[on Regional Office���``�
Subject: Scoping comments on proposed bridge replacemen[ of Bridges No. 770125 and 770175 over lhe Lumber
River on NC 41MC 72 and SR 160Q respec[ively in Robeson County, Project No. WBS 47749.1.1, STIP
No. B-5985.
Reference e-mail correspondence dated May 16, 2018 ui which it requested comments for the referenced project.
Preliminary analysis of the project reveals the potential for multiple impacts to streams and,jurisdictional wetlands
in tlie project u�ea.
Stream Name River Basin Stream Stream Index 303(d) Listing
Classification s Number
Lumber River Lumber C;Sw l4- 13 N/A
Further investigations at a higher resolution should be undertaken to verify the presence of any streams and/or
jurisdictional wetlands in the area. ln the event that anyjurisdictional areas are identified, the Uivision of Water
Resources requests that NCDOT consider the following env'vonmental issues for the proposed project:
Project Specifie Comments:
1. The DWR cannot comment on pennit requirements wi[h the limited infornia[ion provided. Detailed fieid
delineation is required to detennine the presence or absence ofjurisdictional resources within the project
limits. ln addi[ion, NCDO'i' must provide an estima[e to any resources located within [he consh'uclion limi[s
of tl�e projec[ area beFore we can specifically comment on NCDWR penni[ eligibility.
General Projec[ Comments:
2. 7'he env'vonmei�tal document should provide a detailed and itemized presentation of [he proposed impacts to
we[lands and streams with corresponding mapping. If mitigation is necessary as required by I SA NCAC
2H.0506(h), it is preferable to presenf a conceptual (if not finalized) mitigation plan with the environmental
documentation. Appropria[e mitigation plans will be required prior [o issuance of a 401 Water Quality
Ce�tification.
3. Environmental impac[ statement alterna[ives shall consider design criteria that reduce the impacts lo s(reams
and wedands fi�om storm water runoff. 1'hese alternatives shall include road designs lhat allow for h'eatment
of tl�e storm water runoffthrough best managemenl practices as de[ailed in the most recent version of Ihe
Nor(h Cnro(ina Depm�Iniwvl of Trnnspa�tatio�t Smnnwate�� Bes[ Mnnngeuieiu Yrnclices To��! box manual,
such as grassed swales, buffer areas, preformed scour holes, reten[ion basins, e[c.
'- N�Nliiny(�uiupai�•ti
timte u( Nanh l ai ul inn I 6i� ironineinnl Qualit�
1617 Mail Sei � mr ('rniei i Italeigh. Nui ih Carul �mi '7ny9-I h 17
4. After the selection ofthe preferred alternative and prior to an issuance of the 401 Water Quality Certification,
the NCDOT is respectfully reminded that they will need ro demonstrate [he avoidance and minimization of
impacts to wetlands (and streams) ro the maximum extent practicaL In accordance with the Env'vonmental
Management Commission's Rules (15A NCAC 2H.0506[h]), mitigation will be required for impacts of
greater than 1 acre to wetlands. In the event that mitigation is required, the mitigation plan shall be designed
to replace appropriate lost functions and values. North Carolina Division of Mitigation Services may be
available for assistance with wetland mitigation.
5. ln accordance with the Environmental Management Commissiods Rules (15A NCAC 2H.0506[h]),
mitigation will be requ'ved for impacts oFgeater than 1501inear feet ro any perennial stream. In the event
that mitiga[ion 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.
6. 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.
7. The NCDWR is very concemed with sediment and erosion impacts that could result from this project. The
NCDOT shall address these concems by describing [he potential impacts that may occur to the aquatic
endvonments and any mitigating factors [hat would reduce the impacts.
8. M 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.
9. 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
fmal impact calculations. These impacts, in addition to any consWction impacts, temporary or otherwise,
also need to be included as part of the 401 Water Quality Certification Application.
l0. Where streams must be crossed, the NCDWR prefers bridges be used in lieu of culverts. However, we realize
that economic considerations often requ've 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 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.
11. Whenever possible, [he NCDWR prefers spanning structures. Spanning structures usually do not require
work within the sVeam or grubbing of the streambanks and do not require stream channel realigcunent. The
horizontal and vertical clearances provided by bridges shall allow for human and wildlife passage beneath the
shvcture. Fish passage and navigation by canoeists and boaters shall no[ be blocked. Bridge supports (bents)
should not be placed in the stream when possible.
l2. 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, etcJ
before entering the sheam. To meet [he requirements of NCDOT's NPDES permit NCS0000250, please refer
to the most recent version of the North Carolina Deparhnent of Transportation Stormwater Best Management
Practices Toolbox manual for approved measures.
13. Sediment and erosion control measures should not be placed in weUands or streams.
14. Borrow/waste areas should avoid wetlands to the maximum extent practicaL [mpacts to wetlands in
borrow/waste areas will need to be presented in the 40l Water Quality Certification and could precipitate
compensatory mitigation.
I5. The 40l Water Quality Certification application will need to specifically address the proposed methods for
srormwater management. More specifically, stormwater shall not be permitted to discharge directly into
streams or surface waters.
16. Please be advised that a 401 Water Quality Certification requires satisfactory protection of water quality to
ensure [hat water qualiry standards are met and no wetland or sheam uses are lost. Final permit authorization
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 [he inclusion of appropriate mitigation plans where appropriate.
l7. If concrete is used during construction, a dry work area shall be maintained ro prevent direct contact between
curing concrete and stream water. Water that inadvertently contacts uncured concrete shall not be discharged
to surface waters due ro the potential for elevated pH and possible aquatic life and fish kills.
18. If [emporary access roads or detours aze constructed, the site shall be graded ro 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 na[urally and minimizes soil disturbance.
l9. Unless otherwise authorized, placement of culverts and other slructures 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 [he culvert diame[er 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, adjacent to or upstream and downstream of the above structures. The applicant is
requ'ved to provide evidence that the equilibrium is being maintained if requested in writing by the NCDWR.
[Fthis condition is unable to be met due to bedrock or other limiting features encountered during consWction,
please contact the NCDWR For guidance on how to proceed and to determine whether or not a permit
modification will be required.
20. If multiple pipes or barrels are required, they shall be designed to mimic natural stream cross sectio� as
closely as possible including pipes or barrels at tlood plain elevation, floodplain benches, and/or sills may be
required where appropriate. Widening the sheam channel should be avoided. Stream channel widening at the
inlet or outlet end of structures typically decreases water velocity causing sed'unent deposition that requ'ves
increased maintenance and disrupts aquatic life passage.
21. If foundation [est borings are necessary; it shall be noted in the document. Geotechnical work is approved
under General 401 Certi6cation Number 41323/Nationwide Permit No. 6 for Survey Activities.
22. 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.
23. 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 shvc[ures shall be used to prevent excavation in
flowing water.
24. While the use of National Wetland Inventory (N WI) maps, NC Coastal Region Evaluation of Wetland
Significance (NGCREWS) maps and soil survey maps are useful rools, their inherent inaccuracies require
that qualified personnel perform onsite wetland delineations prior to pertnit approval.
25. 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 shall be
inspected daily and maintained to prevent contamination of surface waters from leaking fuels, lubricants,
hydraulic fluids, or other roxic materials.
26. 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.
27. Ripazian vegetation (native trees and shrubs) shall be preserved ro the maximum extent possible. Riparian
vegetation must be reestablished within the consWction 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 requ¢es that appropriate measures be instituted to ensure that water quality standards aze met and
designated uses aze not degraded or lost. If you have any questions or require additional information, please contact
Joanne Steenhuis at (910) 796-7306 orjoanne.steenhuis@ncdenr.gov.
Electronic copy only dishibution:
Liz Ha'v, US Army Corps of Engineers, Wilmington Field Office
Greg Purvis, PE, Project Manager Wetherill Engineering
Kristi Lynn Carpenter, NCDWR
File Copy