20201515_R-2561CA SOS_20180521

Carpenter,Kristi
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Steenhuis, Joanne
Monday, May 21, 2018 4:34 PM
Rerko, James J; Carpenter,Kristi; Hair, Sarah E CIV
CESAW CESAD (US)
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R-2561CA SOS
R-2561CA NC 87 AND NC 11 intersection SOS
Columbus May 18.pdf
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If you have any questions please let me know.
J�a � �t�� uis
Environmental Senior Specialist
Transportation Permitting Branch
Department of Environmental Quality
(910) 796�7306 (office)
(910) 30��4021 (rnobile)
[e-mail]
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MLMORANDUM
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H'rom:
Jim Rerko, PWS DEO, NCDOT Division 6
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Joanne Steenhuis, NC Division of Water Resources, Wilmington Regional Office� �
Subject: Scoping comments on proposed upgrade of the Intersection NC 87 (Old Slage Hwy) and NC 11 (General
Howe Highway) into a Full-lliamond lnterchange in Sandyfield ln Columbus County, W BS Project No.
34466.4.5, STIP R-2561CA.
Reference your correspondence dated May I6, 2018 in which you requested comments for the referenced project.
Preliminary analysis of fhe project reveals the potential for multiple impac[s to streams and jwisdic[ional wetlands
in the project area. More specifically, impacts to:
Sfream Name River Basin Stream Classification(s) Stream Index 303(d) Listiog
IYumber
We m�n Creek Ca e Fear WS-lV; Sw 18-61 N/A
Fwther investigalions at a higher resolution should be undertaken to verify the presence of ofher streams and/or
jurisdictional wetlands in the area. In the event that any jurisdictional areas are identified, the Division of Water
Resources requests [hat NCDO'P consider [he following environmenfal issues for the proposed project:
Project Specific Comments:
I. Review of the project reveals the presence of surface waters classified as Water Supply Critical Area in the
project study area [ I SA NCAC 02B .0202(20)]. Given ihe potential for impacts to these resources during the
projec[ implementation, lhe NCDWR requests that NCDOT strictly adhere [o North Carolina regulatiais
en[itled Design S�avd�i�rls in Sena�itive Wutersheds ( I SA NCAC 04B A 124) throughout design and
cons[ruction of the project. This would apply for any area that drains to streams having WS CA (Wa[er Supply
Critical Area) classifca[ions.
Should the brid�;e projec[ be located witliin [he Cri[ical Area of a Water Supply, [he NCDO'1' may be required
lo design, cons[ruct, and main[ain hazardous spill catch basins in [he projec[ area. 'Phe �umber of ca[ch basins
installed should be determined by the design of the bridge, so tliat runoff would en[er said basin(s) ra[her than
flowing direcdy into the stream, and in consul[a[ion wifh [he NCDWR.
Ceneral Project Comments:
2. The DWR cannot comment oii permit reyuiremenfs with the limited inf'onnation provided. Defailed field
delineation is required to detennine the presence or absence ofjurisdictional resources within the project
limits. In addition, NCDOI' must provide an esfimare to any resources located within lhe conshuction limics of
fhe project area before we can specifically comment on NCDWR permit eligibility.
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3. The environmental document should provide a detailed and itemized presentation of the proposed impacts to
wetlands and streams with corresponding mapping. [f mitigation is necessary as requ'ved by I SA NCAC
2H.0506(h), it is preferable to present a conceptual (if not fina►ized) mitigation plan with the environmental
documentation. Appropriate mitigation plans will be required prior to issuance of a 401 Wa[er Quality
Certitication.
4. Environmental impact statement alternatives shall consider design criteria that reduce the impacts to streams
and wetlands from storm water runof£ 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 North
Carolrna Department of Transportation Stormwater Best Management Practrces Tool box manual, such as
grassed swales, buffer areas, preformed scour holes, retention basins, etc.
5. After the selection of the preferred alterna[ive 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 minimization of
impacts to wetlands (and streams) to the maximum extent practical. In accordance with the Environmental
Management Commission's Rules (ISA 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.
6. In accordance with the Endvonmental Managemeut Commission's Rules (15A NCAC 2H.0506[h]),
mitigation will be required for impacts of greater than 150 linear feet to any perennial stream. In the event
that mitigation is requ'ved, the mitigation plan shall be designed to replace appropriate lost functions and
values. The NoRh Carolina Division of Mitigation Services may be available for assistance with sheam
mitigation.
7. Future documentation, including the 401 Water Quality Certification Application, shall continue to include an
itemized listing oFthe proposed wetland and sheam impacts with corresponding mapping.
8. The NCDWR is very concerned with sediment and erosion impacts that could result Gom this project. The
NCDOT shall address these concerns by describing [he potential impacts that may occur to the aquatic
environments and any mitigating factors that would reduce the impacts.
9. 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 1 Q 2004.
10. The NCDOT is respectfully reminded that all impacts, including but not limited to, bridging, fill, excavation
and clearing, and rip rap to jurisdictional wetlands, sheams, and riparian buffers need to be included in the
final impact calwlations. 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.
11. 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 aze impacted, a bridge may prove preferable. When applicable, the NCDOT
should not install the bridge bents in the creek, to the maximum extent practicable.
12. 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 suppoMs (bents)
should not be placed in [he s[ream when possible.
13. Bridge deck drains shall not discharge d'vectly into the stream. Stormwater shall be directed across the bridge
and pre-heated through site-appropriate means (grassed swales, pre-formed scour holes, vegetated buffers, etc.)
before entering the sheam. To meet the requirements of NCDOT's NPDES permit NCS0000250, please refer

ro the most recent version of the North Carolina Department of 7ransportation Stormwater Best Management
Practrces Toolbox manual for approved measures.
l4. Sediment and erosion control measures should not be placed in wetlands or streams.
I5. Borrow/waste areas should avoid wetlands to the maximum extent practicaL Impacts to we[lands in
borrow/waste areas will need to be presented in the 401 Water Quality Certification and could precipitate
compensatory mitigation.
16. 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.
17. Please be advised that a 401 Water Quality Certification requires satisfactory protection of water quality to
ensure that water quality 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 sheam impacts to [he maximum extent practical, the developmen[ of an acceptable srormwater
management plan, and the inclusion of appropria[e mitigation plans where appropriate.
18. 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 uncured concre[e shall not be dischazged
to surface waters due to the potential for elevated pH and possible aquatic life and fish kills.
19. If temporary access roads or detours are construc[ed, the site shall be graded ro its preconstruction contours
and elevations. Disturbed areas shall be seeded or mulched ro stabilize the soil and appropriate native woody
species shall be planted. When using temporary structures the area shall be cleazed but not grubbed. Cleazing
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.
20. Unless otherwise authorized, placement of culverts and other structures in waters and streams shall be placed
below [he 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, to allow low flow
passage of water and aquatic Iife. Design and placement oF culverts and other structures including temporary
erosion conhol measures shall not be conducted in a manner that may result in dis-equilibrium of wetlands or
sheambeds 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 [he 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 de[ermine whether or not a permit
modification will be required.
21. 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
required where appropriate. Widening the sheam channel should be avoided. Sheam channel widening at the
inlet or outle[ end of structures typically decreases water velocity causing sediment deposition that requires
increased maintenance and disrupts aquatic life passage.
22. lf foundation test borings are necessary; it shall be noted in the document. Geotechnical work is approved
under General 40l Certification Number 41323Mationwide Permit No. 6 for Survey Activities.
23. Sediment and erosion conhol measures sufficient to protect water resources must be implemented and
maintained in accordance with the most recent version of North Cazolina Sediment and Erosion Control
Planning and Design Manual and the most recent version of NCS000250.
24. All work in or adjacent to stream waters shall be conducted in a dry work area. Approved BMP measures
from the most curren[ 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.
25. 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 tools, their inherent inaccuracies requ've
that qualiFied personnel perform onsite wetland delineations prior to permit approval.
26. Heavy equipment should be operated from the bank rather than in sheam channels in order to minimize
sedimen[ation 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.
27. 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.
28. Riparian vegetation (native hees and shrubs) shall be preserved to the maximum extent possible. Riparian
vege[ation must be reestablished within the wnstruction limits of the project by the end of the growing season
following completion of cons[ruction.
Thank you for requesting our input at this time. The NCDOT is reminded [hat issuance of a 401 Water Quality
Certification requires that appropriate measures be instituted to ensure that water quality standazds aze met and
designated uses aze 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 dishibution:
Liz Hair, US Army Corps of Engineers, Wilmington Field Office
Susan Westberry, SEPI Engineering and Construction, Inc.
Kristi Lynn Carpenter, NCDWR
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