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July 26, 2018
MEMORANDUM
To: Jeffery W. Moore, P.E. Kimley-Horn and Associates, Inc. (jeff.moore@kimley-horn.com) ps
From: Dave Wanucha, NC Division of Water Resources, Winston Salem Regional Office ��� 7/26/2018
Subject Scoping comments on proposed widening and improvements to SR 1173 (Williams Road) in Forsyth County,
WBS Element No. 4708211; TIP U-5617
Reference your correspondence dated July 19, 2018 in which you requested comments for the referenced project.
Preliminary analysis of the project reveals the potential for multiple impacts to streams and jurisdictional wetlands in the
project area. More specifically, impacts to:
Stream Name River Basin Stream Classification(s) Stream Index 303(d) Listing
Number
Ellison Creek Yadkin Pee Dee C 12-88-(0.4) No
Blacks Creek Yadkin Pee Dee WS-IV 12-87-1-1 No
Further investigations at a higher resolution should be undertaken to verify the presence of other streams and/or
jurisdictional wetlands in the area. If any jurisdictional areas are identified, the Division of Water Resources requests that
Kimley-Horn consider the following environmental issues for the proposed project:
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 alternatives shall consider design criteria that reduce the impacts to streams and
wetlands from storm water runoff. These alternatives shall include road designs that allow for treatment of the storm
water runoff through BMPs 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.
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North Carolina Department of Environmental Quality � Division of Water Resources
512 North Salisbury Street � 1617 Mail Service Center � Raleigh, North Carolina 27699-1617
919.707.9000
3. In accordance with the Environmental Management Commission's Rules (15A NCAC 2H.0506[h]), mitigation will
be required for impacts of greater than 3001inear feet to any perennial stream. In the event that 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.
4. 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.
5. 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 environments and any
mitigating factors that would reduce the impacts.
6. 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 final impact
calculations. These impacts, in addition to any construcrion impacts, temporary or otherwise, also need to be
included as part of the 401 Water Quality Certification Application.
7. Sediment and erosion control measures should not be placed in wetlands or streams.
8. 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.
9. The 401 Water Qualiry 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. To meet the requirements of NCDOT's NPDES permit NCS000250, please refer to the most recent
version of the North Carolina Department of Transportation Stormwater Best Management Practices Toolbox
manual for approved measures.
10. Based on the information presented in the document, the magnitude of impacts to wetlands and streams may require a
Nationwide (NW) application to the Corps of Engineers and corresponding 401 Water Quality Certification. Please
be advised that a 401 Water Quality Certification requires satisfactory protection of water quality to ensure that water
qualiry standards are met and no wetland or stream 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 the inclusion of
appropriate mitigation plans where appropriate.
11. If concrete is used during construction, a dry wark 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 potential for elevated pH and possible aquatic life and fish kills. Concrete shall be handled in
accordance with the NPDES Construction General Permit NCGO10000.
12. 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.
13. 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
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North Carolina Department of Environmental Quality � Division of Water Resources
512 North Salisbury Street � 1617 Mail Service Center � Raleigh, North Carolina 27699-1617
919.707.9000
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 modification will be required.
14. 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 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.
15. If foundation test borings are necessary; it shall be noted in the document. Geotechnical work is approved under
Genera1401 Certification Number 4085/Nationwide Permit No. 6 for Survey Activities.
16. 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.
17. All wark in or adjacent to stream waters shall be conducted in a dry wark 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 structures shall be used to prevent excavation in flowing water.
18. 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.
19. 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.
20. 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.
21. Riparian vegetation (native trees and shrubs) shall be preserved to the maximum extent possible. Riparian vegetation
must be reestablished within the construction 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 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 Dave Wanucha at
(336) 776-9703 or dave.wanucha@ncdenr.gov.
Electronic copy only distribution:
Bryan Roden Reynolds, US Army Corps of Engineers, Charlotte Field Office
File Copy
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North Carolina Department of Environmental Quality � Division of Water Resources
512 North Salisbury Street � 1617 Mail Service Center � Raleigh, North Carolina 27699-1617
919.707.9000