U-6024andR-3608-scoping

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July 16, 2018
MEMORANDUM
To: Steve L. Brown, PE, Senior Transportation Planner, HDR Inc.
Prom: Rob Ridings, NC Division of Water Resources, Transporiation Pei��itting Branch
Subject: Scoping comments on proposed improvements to US 401 & NC 39 in Louisburg, Franklin County,
TIP Nos. U-6024 & R-3608.
Reference your correspondence received July 12, 2018, in wl�ich you requested cotninents for the referenced project.
Preliminary analysis of the project reveals the potential for multiple impacts to streams, riparian buffers, and/or
jurisdictional wetlands in the project area. More specifically, impacts to these streams andlor tl�eir triblitaries:
Stream Name River Basin Stream Classifications Stream index 303(d) Listing?
Numbec
Tar River TAR WS-V; NSW 28-(24.7) No
Fox Creek TAR C; NSW 28-25 No
Wolfpen Branch TAR C; NSW 28-27 No
Further investigations at a higher resolutioi� shotzld be Lindertal<en to verify the presence of other sn-eams and/or
jurisdictional wetlands in the area. In the event that any jurisdictional areas are identified, the Division of Water
Resources requests that NCDOT consider the following environmental issues for the proposed project:
Project Specific Comments:
To meet the requirements of NCDOT's NPDES permit NCS000250, the road design plans shall provide
treatment of the stormwater runoff tlu•o�tgh BMPs as detailed u1 the most recent version of the North Caroli��a
Deparbnent of Tray7sportatior� Stormtivater Best Mnnagen�ent Prnclices Toolbo.x manuaL The BMPs should, to
the MEP, be selected and designed to reduce impacts of the target pollutants of concern (POCs) for the
receiving waters.
2. These streains and tributaries are all class NSW waters of the State. The NCDWR is very concerned with
sediment and erosion impacts that could result fi-om this project. The NCDWR recommends that highly
protective sediment and erosion control BMPs be itnplemented to reduce the rislc of nutrient nlnoff to any of
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North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street I 1617 Mail Service Center � Raleigh, North Carolina 27699-1617
919.707.9000

these streams and tributaries. Post-const�-uction storrnwater BMPs should, to the MEP, be selected and desi�ned
to reduce nutrients.
This project is within the Tar-Pamlico River Basin. Riparian buffer impacts sl�all be avoided and minimized to
the greatest extent possible pursuant to 15A NCAC 2B.0259. New development activities located in the
protected 50-foot wide riparian areas wit�hin the basin sl�all be linvted to "uses" identified witl�in and
constiucted in accordance with I SA NCAC .02B .0295. Buffer mitigation may be required for buffer impacts
resulting fro�n activities classified as "allowable witll mitigation" witliin the "Table of Uses" section of tl�e
Buffer Rules or req�iire a variance �mder the BufFer Rules. A bufFer nvtigation plan, including use of the North
Carolina Division of Mitigation Seivices, tnust be provided to the NCDWR prior to approvaf of thE Water
QuaLity Cerrification. Buffer mitigarion may be required for buffer iinpacts resulting froin activities classified
a5 "allowable with mitigarion" within the "Table of Uses" section of the Buffer Rules or reauire a variance
u�lder the BufFer Rules. A buffer mitigation plan, coordinated with the North Carolina Division of Mitigatio�7
Services, inust be provided to tl�e NCDWR prior to approval of the Water Quality Certitication.
General Project Comments:
Tl�e environmental clocuu�ent should provide a detailed and itemized presentation of tl�e 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 prese��t a conceptual (if not finalized) ir�itigation plai� witl� the enviroumental
docun�entation. Appropriate mitigatiou plans will be reql�ired prior to issuai�ce of a 401 Water Quality
Certi6catioi�.
Environmental iinpact statement alternatives sl�all consider design criteria that reduce the impacts to streams
and wetla��ds from storm water i•unoff. These alternatives shall include road designs tl�at allow for treatrnent
of the storm water cunoff through BMPs as detailed in tl�e most recent version of the North Carolina
Depar•frrrerrl of�Trn��sportation Stor�n�iwater• Best Mrmagen�ent Pr•actices Tool box manual, such as grassed
swales, buffer areas, preformed scour holes, retention basins, etc.
After the selectioil of the preferred alternative 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 miniinization of
impacts to wetlands (and streams) to the maximum extent practical. In accordance with the Eilvironmental
Management Comnussion's Rules (15A NCAC 2H.0506[h]), mitigation will be rec�uued for impacts of
greater than 1 acre to wetlands. ln tl�e 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.
In accordance with the Environmental Management Commission's Rules (15A NCAG 2H.0506[l�]),
mitigation will be re�quired for impacts of greater than 300 linear feet to any perennial sh-eam. In tl�e event
that mitigation is required, the mitigation plan shall be designed to replace appropriate lost functions and
values. Tlie North Carolina Division of Mitigation Services may be available for assistance with stream
mitigation.
Ftitt�re doc�mientation, including the 401 Water Quality Certification Application, shall contin�ie to include an
itemized listing of the proposed wetland and stream impacts with corresponding mapping.
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North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street I 1617 Mail Service Center � Raleigh, North Carolina 27699-1617
919.707.9000

6. The NCDWR is very concerned with sediment and erosion impacts that could result fi-om this project. The
NCDOT shall address these concerns by describing the potential impacts that may occur to the aquatic
environments and any mirigating factofs tl�at would reduce tl�e impacts.
7. An analysis of cumulative and secondary impacts anticipated as a result of this project is renuired. The type
and detail of analysis shall confoi�n to the NC Division of Water Resource Policy on tl�e assessment of
secondary and c�imulative impacts dated April 10, 2004.
8. The NCDOT is respectfully reminded that all impacts, including but not limited to, bridging, fll, excavation
and clearing, and rip rap to jurisdictional wetlands, streams, and riparian buffers need to be included in the
final impact calculations. Tliese impacts, in addition to any consh-uction impacts, temporary or otherwise,
also need to be included as part of the 401 Water Quality Certification Application.
�. Where streams must be crossed, the NCDWR prefers bridges be used in lieu of culverts. However, we realize
that econoil�ic considerations often require the use of culverts. Please be advised that c�ilverts should be
counte�sunl< to allow uniil�peded passage by fisl� and other aquatic organisms. Moreover, in areas where high
quality wetlands or sh-ea�vs are impacted, a bridge may prove preferable. When applicable, the NCDOT
should not install the bridge bents in tl�e creek, to the maximum extent practicable.
10. Whe��ever possible, the NCDWR prefers spam��ing st�•uctures. Spanning structures usually do not rec7uire
work within the stream or grubbing of the streambanks and do not require stream cl�annel reali��ment. Tl�e
horizontal and vertical clearances provided by bridges shall allow for 11u�r�an and wildlife passage beueath tl�e
sn•ucture. Fish passage and navigation by canoeists and boaters shall not be blocked. Bridge supports (bents)
sl�ould not Ue placed in tl�e stream wheu possible.
1 1. Bridge deck drains shall not discharge directly into the stream. Stormwater shall be directed across the Uridge
and pre-treated tivoligh site-appropriate means (grassed swales, pre-formed scour holes, vegetated buffers, etc.)
before entering the streain. To meet the requirements of NCDOT's NPDES pernut NCS000250, please refer
to the most recent version of fl�e Noetli Car�•olina Departr��aerlt of Tr•arisportation Storn�ivatei� Best Mnnagernent
Pf-«etices Toolbox manual for approved measures.
12. Sediinent and erosion control meastu�es should not be placed in wetlands or streams.
13. Borrow/waste areas should avoid wetlands to tl�e maximum extent }�racticaL Impacts to wetlands i��
borrow/waste areas will need to be pre�sented in tl�e 40l Water Quality Certification and could precipitate
compensatory tnitigation.
14. The 401 Water Quality Certification application will need to specifically address the proposed methods for
stormwater manageinent. More specifically, stormwater shall not be pennitted to discharge directly into
streams or surface waters. To ineet tl�e requirements of NCDOT's NPDES permit NCS000250, please refer
to the most rece��t version of the North Car•olina Depar�tment of T�-ansportcrtion Stornan�ater• Best Mu��c�gernent
Practices Toolbox manual for approved measures.
15. Based on the infonnatioi� presented in the document, the ��lagnih►de of impacts to wetlands and streams may
require a 404 application to the Corps of Engii�eers and correspoilding 40l Water Quality Certification.
Plelse Ue advised that a 401 Water Quality Certification requires satisfactory protection of water quality to
ensiu•e that w�ter q�iality standards are met and no wetland or stream uses are lost. Final permit authorization
will require the subinittal of a formal application by the NCDOT and written conc�urence fi•oin tl�e NCDWR.
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North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street I 1617 Mail Service Center � Raleigh, North Carolina 27699-1617
919.707.9000

Please be aware that any approval will be contingent on appropriate avoidance and minimization of wetland
and stream impacts to the maximum extent practical, tl�e development of an acceptable stormwater
management plan, and tl�e inclusion of appropriate �nitigation plans wl�ere appropriate.
16. If concrete is used d�iring construction, a dry work area shall be nlaintained to prevent direct contact between
curing concrete and stream water. Water tl�at ivadvertently contacts uncured concrete shall not be discharged
to surface waters due to the potential for elevated pH and possible aquatic life and fish kills. Concrete shall
be handled in accordauce with tl�e NPDES Construction GeneraL Permit NCGO10000.
17. If temporary access roads or detours are constructed, the site shall be graded to its preconstniction contours
and elevations. Disturbed areas shall Ue seeded or mulched to stabilize the soil and appropriate native woody
species shall be planted. Wl�ei� using teinpora�y struchires tl�e area shall be cleared blit not grubbed. Clearing
the area with cl�ain saws, iroowers, bush-hogs, or other mechanized equipment and leaving the stumps and root
mat intact allows the area to re-vegetate naturally and minimizes soil distw-bance.
18. Unless otherwise authorized, placemei�t of culverts and other sh-uctures in waters and sn•eams shall be placed
below the elevation of the strean�bed by one foot for all c�ilverts with a dian�eter greater than 48 inches, and
20 percent of the culvert diaiveter for cLilverts having a diameter less than 48 inches, to allow low flow
passage of water and aquatic life. Design and pLacement of culverts and other st�•uctures including temporary
erosion control i�ieasures shall not be conducted in a ir�anner tl�at may result in dis-eqliilibrium of wetLands or
streambeds or banks, adjacent to or upstream and downstream of tl�e above struct�ires. Tl�e applicant is
required to provide evidence that t11e eq�iilibrium is being maintained if requested in writuig by the NCDWR.
If tl�is condition is unable to be met due to bedrocl< or other limiting features enconutered during construction,
please contact tl�e NCDWR for guidance on how to proceed and to determine whether or not a permit
modification will be required.
19. If multiple pipes or ban-els are required, tlley shall be designed to miinic natural stream cross section as
closely as possible including pipes or ban-els at flood plain elevation, floodplain benches, and/or sills �nay be
required where appropriate. Widening the stream channel sllould be avoided. Stream chaiinel widening at the
inlet or outlet end of smictures typically decreases water velocity causing sediment deposition that requires
increased maintenance and disiupts aquatic life passage.
20. lf foundation test borings are necessary; it shall be noted in the document. Geotechnical work is approved
under Geuera1401 Certiflcation Number 4085/Nationwide Perinit No. 6 for Survey Activities.
21. Sediment and erosion control meastires sufficient to protect water resources must be implemented and
maintained in accordance with tl�e most recent version of North Carolina Sediment and Erosion Control
Planning and Design Manua] 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 measL�res
from the most cm-rent version of the NCDOT Construction and Maintenance Activities manual such as
sai�dbags, rock berms, cofferdams and other diversion sri-uctures shall be used to prevent excavation in
flowing water.
23. Whilc; the use of National Wetland Inventory (NWI) maps, NC Coastal Region Evaluation of Wetland
Significance (NGCREWS) maps a�nd soil survey m�ps are �tsef�il tools, their inherent inacc�uacies require
that qualified personnel perform onsite wetland delineations prior to permit approval.
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North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street I 1617 Mail Service Center � Raleigh, North Carolina 27699-1617
919.707.9000

24. Heavy equipment should be operated from the bank rather than in stream channels in order to minimize
sediment�ation and reduce the likelil�ood of iiltroducing otl�er pollutants into streams. This equipment shall be
inspected daily and ir�aintained to �revent contaminatio�� of surface waters fron� leaking fuEls, lubricants,
hydraulic fluids, or other toxic materials.
25. Riprap sl�all not be placed in tl�e active thalweg cl�annel or placed in the st�•eambed in a�namler tl�at precludes
aquatic life passage. Bioengineering boulders or shlictures sl�ould be properly designed, sized and installed.
26. Ripat-ian vegetation (native trees and shrubs) shall be prese�ved to Cl�e maximuin extent possible. Ripariail
vegetatio�7 musC be reestablished within Che construction limits of the project by the end of the growing season
following complet�ion of constructiorl.
Tharil< you for requesting olir iuput at tl�is time. The NCDOT is reminded that issuance of a 401 Water Quality
Certification requires tl�at appropriate measures be insrihited 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
Rob Ridings at 919-707-8786.
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North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street I 1617 Mail Service Center � Raleigh, North Carolina 27699-1617
919.707.9000