BR-0014 Ver 1_Br-0014 Bridge 25 over Beaver Dam Ck Cumberland SOS May 18_20180521

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May 2L, 2018
MEMOI2AN D U M
To
From
Jim Rerko, DCO, NCUOT Division 6
Joanne Steenhuis, NC Division of Water Resources, Wilming[on Regional Office J���
Subject Scoping comments on proposed bridge replacement of k3ridge No. 250025 over E3eaver Dam Creek on NC
242 in Cumberland County, Project No. WBS 67014.1.1, STIP No. BR-0014.
Reference e-mail correspondence dated May 16, 2018 in which it requested commen[s for the referenced project.
Prel'uninary analysis of the project reveals the poten[ial for multiple impac[s to streams and jw�isdictional wetlands
in the project area.
Stream Name River 13asin Stream Stream ludex 303(d) Listing
Classificatioo s Number
Beaver Dzm Creek Ca e Fear C;Sw IS-68-12-]0 N/A
Further investigations at a higher resolution should be undertaken to verify Ihe presence of any streams and/or
jurisdictional weHands in the area. [n the event that any jurisdictional areas are identified, the Division of Water
Resources rzquests lhat NCDOT consider the following enviromnental issues for [he proposed project
Project Specific Commen[s:
1. "fhe DWR cannot comme��[ on permit requirements wi[h [he limited infornia[ion provided. De[ailed field
delinea[ion is required to detennine the presence or absence ofjurisdictional resources wi[hin the project
limits. ln �ddition, NCDOT must provide an es[imate [o any resources located within the construc[ion limi[s
of fhe projec[ area before we can specifically comment on NCUWR pennit eligibility.
General Projec[ Comments:
2. The environmental documenf should provide a detailed and itemized presentation of the proposed impacts to
wetlands and sheams with con�esponding mapping. If mitigalion is necessary as required by I SA NCAC
2H.0506(h), it is preferable [o present a concep[ual (if not finalized) mi[igation plan wi[h [he environmental
documenta[ion. Appropriate mi[igation plans will be required prior to issuance of a 401 Water Quality
Certification.
3. Enviromnental impac[ sta[emen[ alternatives shall consider design criteria tha[ reduce Ihe impacts to streams
and wetlands from stonn water rwiotf. �fhese alternatives shall include road designs [hat allow for treaUuent
of Ihe storm water runoff through best management practices as detailed in die most recent version of the
North Cnrolinn Depnrtment qJ'Tronsporintion S�a•urwnlei• 6est Mnnngenien� Prnclrces 7'00! box manual,
such as grassed swales, buffer areas, prefonned scow holes, reteotion basins, etc.
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4. After the selection of the preferred altemative and prior to an issuance of the 401 Water Quality Certification,
the NCDOT is respectfully reminded that they will need to demonstrate the avoidance and minimizstion of
impacts to wetlands (and streams) to the maximum extent practicaL ln accordance wi[h the Endvonmental
Management Commission's Rules (15A NCAC 2H.0506[h]), mitigation will be required for impacts of
greater than l acre to weUands. In the event that mi[igation is requ'ved, the mi[igation plan shall be designed
ro replace appropriate lost functions and values. North Carolina Division of Mitigation Services may be
available for assistance with wetland mitigation.
5. In accordance with the Environmental Management Commissiods Rules ( I SA NCAC 2H.0506[h]),
mitigation will be required for impacts of greater than I501inear feet to any perennial sheam. In the event
Utat mitigation is required, the mitigation plan shall be designed to replace appropriate los[ functions and
values. The North Carolina Division of Mitigation Services may be available for assis[ance with sueam
mitigation.
6. Future documentation, including the 401 Water Quality CeRification Application, shall continue to include an
itemized listing of the proposed wetland and stream impacts with corresponding mapping.
7. 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
env'vonments and any mitigating factors that 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 cleazing, 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 conshvction impacts, temporary or otherwise,
also need to be included as part of the 40l Water Quality Certification Application.
10. 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.
11. Whenever possible, the NCDWR prefers spanning structures. Spanning struchves usually do not requ've
work within the stream or grubbing of the streambanks and do not require sheam 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 sheam when possible.
12. Bridge deck drains shall not discharge d'vectly 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 J
before entering the stream. To meet the requirements of NCDOT's NPDES permit NCS000025Q please refer
to the mos[ recent version of the North Carolina Deparhnent ofTransportation Stormwater Best Management
Practices Toolbox manual for approved measures.
l3. Sediment and erosion control measures should not be placed in wetlands or streams.
l4. Borrow/waste areas should avoid wetlands to the maximum extent practical. Impacts to wetlands in
borcow/waste areas will need to be presented in the 40l Wa[er Quality Certification and could precipitate
compensatory mitigation.

l5. The 401 Water Quality Certification application will need to specifically address the proposed methods for
s[ormwater managemenk More specifically, srormwater shall not be permitted to discharge directly into
streams or surface waters.
l6. 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 weUand or stream uses are lost. Final permit authoriza[ion
will require the submittal of a formal application by the NCDOT and written concurrence &om the NCDWR.
Please be aware that any approval will be contingent on appropriate avoidance and minimization of wetland
and sVeam impacts to the maximum extent practical, the development of an acceptable stormwater
management ptan, and the inclusion of appropriate mitigation plans where appropriate.
17. If concrete is used during construction, a dty work area shall be maintained to prevent direc[ contact between
curing concrete and stream water. Water that inadvertently contacts uncured concrete shall not be dischazged
to surface waters due to the potential for elevated pH and possible aquatic life and fish kills.
l8. If temporary access roads o� detours aze constructed, the site shall be graded to its preconstruction conrours
and elevations. Disturbed areas shall be seeded or mulched to stabilize the soil and appropriate native woody
species shall be planted. Whe� using temporary sWctures 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.
19. Unless othenvise authorized, placement of culverts and other structures in waters and sVeams shall be placed
below the elevation of Ute 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 culveRs 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 s[ructures. The applicant is
required ro provide evidence that the equilibriwn is being maintained ifrequested in writing by the NCDWR.
If this condition is unable to be met due to bedrock or other limiting features encountered during conshuction,
please contact the NCDWR for guidance on how to proceed and to determine whether or not a permit
modification will be requ'ued.
20. [f multiple pipes or barrels are required, they shall be designed to mimic natural slream cross section as
closely as possible including pipes or barrets at tlood 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 sduc[ures typicalty decreases water velocity causing sediment deposition that requires
increased maintenance and disrupts aquatic life passage.
21. If foundation test borings are necessary; i[ shall be noted in the document. Geotechnical work is approved
under Genera1401 Certification Number 41323/Nationwide Permit No. 6 for Survey Activities.
22. Sediment and erosion conVol measures su�cient to protect water resources must be implemented and
maintained in accordance with the most recent version of North Carolina Sediment and Erosion Conhol
Planning and Design Manual and the most recen[ 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 Ac[ivities manual such as
sandbags, rock berms, cofferdams and other diversion structures shall be used to prevent excavation in
tlowing watec
24. While the use ofNational Wetland Inven[oty (NW[) maps, NC Coastal Region Evaluation of Wetland
Significance (NGCREWS) maps and soil survey maps aze useful tools, the'v inherent inaccuracies require
that qualified personnel perform onsite wetland delineations prior to permit approval.
25. Heary 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 toxic 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. Riparian vegetation (native trees and shrubs) shall be preserved to the maximum extent possible. Riparian
vegetation must be reestablished within the wnslruc[ion limits of the project by the end of the growing season
following completion of consWction.
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 requ've additional information, please contact
Joanne Steenhuis at [phone] or [e-mail].
Electronic copy only dishibution:
Liz Ha'v, US Army Corps of Engineers, WiLnington Field O�ce
Greg Purvis, PE, Project Manager We[herill Engineering
Kristi Lynn Carpenter, NCDWR
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