NCDWR Scoping Comments for U_5898_Guilford_Co

;`�<
R;ia
ROY COOPER
Covernor
MICHAEL S. REGAN
Secretcary
Environmental LINDA CULPEPPER
Quallty Lilerrn7 Drrector
June 4, 2018
MEMORANDUM
To:
From:
Jennifer Evans, NC Department of Transportation
April Norton, NC Division Water Resources, Transportation Permitting Unit
Subject: Scoping comments for improvements to US at NC 150 Interchange in Guilford County, TIP No. U-5898.
A request for comments was dated and received May 30, 2018 for the subject property. Preliminary analysis of the
project reveals the potenrial for multiple impacts to streams and jurisdictional wetlands in the project area. More
specifically, impacts to:
Stream Name River Basin & Sub Stream Stream Index Number 303(d) Listing?
Basin Classifications
Benaja Creek Cape Fear; CPFO1 WS-V; NSW 16-4 No
Further investigations at a higher resolution should be undertaken to verify the presence of additional streams and/or
jurisdictional wetlands in the area. If any jurisdictional areas are identified, the Division of Water Resources requests
that the following environmental issues for the proposed project are considered:
Project Specific Comments:
Benaja Creek is classified as water supply five (WS-V); nutrient sensitive waters (NSW) of the State. The
NCDWR is very concerned with sediment and erosion impacts that could result from this project. NCDWR
recommends that highly protective sediment and erosion control BMPs be implemented to reduce the risk of
nutrient runoff to Ingle Branch. Additionally, to meet the requirements of NCDOT's NPDES permit
NCS0000250, NCDWR requests that road design plans provide treatment of the storm water runoff through
best management practices as detailed in the most recent version of the North Carolina Department of
Transportation Stoi^mwater Best Management Practices Toolbox manual.
This project is within the Jordan Lake Watershed. Riparian buffer impacts shall be avoided and minimized
to the greatest extent possible pursuant to 15A NCAC 2B .0267. New development activities located in the
protected 50-foot wide riparian areas within the basin shall be limited to "uses" identified within and
constructed in accardance with 15A NCAC .02B .0295. Buffer mitigation may be required far buffer impacts
resulring from acrivities classified as "allowable with mirigation" within the "Table of Uses" section of the
Buffer Rules or require a variance under the Buffer Rules. A buffer mirigation plan, including use of the
North Carolina Division of Mitigation Services, must be provided to the NCDWR prior to approval of the
Water Quality Certification. Buffer mitigation may be required for buffer impacts resulting from activities
classified as "allowable with mitigation" within the "Table of Uses" section of the Buffer Rules or require a
variance under the Buffer Rules. A buffer mitigation plan, coordinated with the North Carolina Division of
Mitigation Services, must be provided to the NCDWR prior to approval of the Water Quality Certification.
`'�Nra11�i���, C:t�r�•.��f�rc�� - .
State of North Carolina � Environmental Quality
1617 Mail Service Center I Raleigh, North Carolina 27699-1617

General Project Comments:
The environmental document should provide a detailed and itemized presentation of the proposed impacts to
wetlands and streams with corresponding mapping. If mitigation is necessary as required by 15A NCAC
2H.0506(h), it is preferable to present a conceptual (if not finalized) mitigation plan with the environmental
documentation. Appropriate mitigation plans will be required prior to issuance of a 401 Water Quality
Certification.
2. Environmental impact statement alternarives shall consider design criteria that reduce the impacts to streams
and wetlands from stormwater runoff. These alternatives shall include road designs that allow for treatment of
the stormwater runoff through stormwater control measures (SCM, previously referred to as best management
practices) as detailed in the most recent version of the North Carolina Department of� Transportation
Stormwater Best Management Practices Tool box manual, such as grassed swales, buffer areas, preformed
scour holes, retention basins, etc.
3. After the selection of the preferred alternative and prior to an issuance of the 401 Water Quality Certification,
avoidance and minimization of impacts to wetlands, buffers, and streams must be demonstrated to the maximum
extent practicaL In accordance with the Environmental Management Commission's Rules (15A NCAC
2H.0506[h]), mitigation will be required for impacts of greater than one acre to wetlands. If 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 mirigation.
4. In accordance with the Environmental Management Commission's Rules (15A NCAC 2H.0506[h]), mitigation
will be required for impacts of greater than 300 linear feet to any perennial stream. If 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 401 Water Quality Certification Application, shall continue to include an
itemized listing of the proposed wetland and stream impacts with corresponding mapping.
6. The NCDWR is very concerned with sediment and erosion impacts that could result from this project. These
concerns shall be addressed by describing the potential impacts that may occur to the aquaric environments and
any mitigaring factors that would reduce the impacts.
7. An analysis of cumulative and secondary impacts anricipated 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. 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 ar 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 streams are impacted, a bridge may prove preferable. When applicable, bridge bents should
not be installed within the creek, to the maximum extent practicable.
10. Whenever possible, the NCDWR prefers spanning structures. Spanning structures usually do not require work
within the stream or grubbing of the streambanks and do not require stream 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 stream when possible.

11. 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 entering the stream. Please refer to the most recent version of the North Carolina Department of
Transportation Stormwater Best Management Practices Toolbox manual for approved measures.
12. Sediment and erosion control measures should not be placed in wetlands or streams.
13. 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 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, buffers, or surface waters.
15. If concrete is used during construcrion, a dry work area shall be maintained to prevent direct contact between
curing concrete and stream water. Water that inadvertently contacts uncured concrete shall not be discharged
to surface waters due to the potenrial for elevated pH and possible aquaric life and fish kills.
16. If temporary access roads or detours are 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.
17. 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 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 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 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 modiiication
will be required.
18. If mulriple pipes or barrels are required, they shall be designed to mimic natural stream cross secrion 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 requires increased
maintenance and disrupts aquatic life passage.
19. If foundation test borings are necessary; it shall be noted in the document. Geotechnical work is approved under
Genera1401 Certification Number 4132/Nationwide Permit No. 6 far Survey Activities.
20. 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.
21. All wark in or adjacent to stream waters shall be conducted in a dry work area. Approved SCMs 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.

22. 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.
23. 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 toxic materials.
24. 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.
25. Riparian vegetation (native trees 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 complerion of construcrion.
Thank you for requesting our input. The 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 require additional information, please contact April Norton at april.norton(a�ncdenr.gov.
Sincerely,
DocuSigned by:
�4p,,_,�;C nl'e.,��,
03BAC6376A6340D_.
Electronic copy only distribution:
David Bailey, US Army Corps of Engineers, Raleigh Field Office
File Copy