20120592 Ver 0_Scoping Comments_20090601

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
June 1, 2009
MEMORANDUM
Dee Freeman
Secretary
TO: Pamela R. Williams, NCDOT, Bridge Project Planning Engineer, PDEA-Bridge Unit-
NCDOT, 1551 Mail Service Center, Raleigh NC 27699-1548
FROM: Amy Euliss, NCDWQ, Winston Salem Regional Office
SUBJECT: Seeping Review of NCDOT's Proposed Bridge Replacement Projects:
B-4701(Alleghany), B-4705 (Ashe), B-4707 (Avery), B4721 (Caldwell), B-4821 (Surry),
B-4836 (Watauga), B-4846 (Wilkes), B4947 (Wilkes), B-5118 (Watauga), B-5146
(Wilkes), and B-5147 (Ache).
In reply to your correspondence dated May 7, 2009 (received May 20, 2009) in which you requested
comments for the above referenced projects, the NCDWQ offers the following comments:
Project-Specific Comments
B-4701, Bridge No. 15 Over Elk Creek, Alleghany County
1. Review of the project reveals the presence of surface waters classified as C; + in the project study
area. The + classification symbolizes that these waters drain to Outstanding Resource Waters
(ORW) of the State. The ORW to which Elk Creek drains are the New River (C;ORW) are located
within 1 mile of the project study area. The water quality classification of C; ORW is one of the
highest classifications in the State. NCDWQ is extremely concerned with any impacts that may
occur to streams with this classification. It is preferred that these resources be avoided if at all
possible. If it is not possible to avoid these resources, the impacts shall be minimized to the greatest
extent possible. Given the potential for impacts to these resources during the project
implementation, the NCDWQ requests that NCDOT strictly adhere to North Carolina regulations
entitled "Design Standards in Sensitive Watersheds" (15A NCAC 04B .0124) throughout design and
construction of the project. Pursuant to 15A NCAC 2H .1006 and 15A NCAC 2B .0224, NCDOT
will be required to obtain a State Stormwater Permit prior to construction except in North Carolina's
twenty coastal counties.
B-4705, Bridge No. 690ver Little Helton Creek, Ashe County
1. Review of the project reveals the presence of surface waters classified as C; Tr: + in the project
study area. The + classification symbolizes that these waters drain to Outstanding Resource Waters
of the State. The water quality classification of C; Tr: + is one of the highest classifications in the
State. NCDWQ is extremely concerned with any impacts that may occur to streams with this
classification. It is preferred that these resources be avoided if at all possible. If it is not possible to
avoid these resources, the impacts shall be minimized to the greatest extent possible. Given the
potential for impacts to these resources during the project implementation, the NCDWQ requests
that NCDOT strictly adhere to North Carolina regulations entitled "Design Standards in Sensitive
Watersheds" (15A NCAC 04B .0124) throughout design and construction of the project. Pursuant
to 15A NCAC 2H.1006 and 15A NCAC 2B .0224, NCDOT will be required to obtain a State
Stormwater Permit prior to construction except in North Carolina's twenty coastal counties.
2. Little Helton Creek are class C; Tr: + waters of the State. NCDWQ recommends that the most
protective sediment and erosion control BMPs be implemented to reduce the risk of turbidity
violations in trout waters. In addition, all disturbances within trout buffers shall be conducted in
North Carolina Division of Water Quality 585 Waughtow Street Phone (336) 771 A600 Customer Service No ?` ,Carolina
Internet: h2o.encstate.nc.us Winston-Salem, NC 27107 FAX [phone] rVatAmally
An Equal Opportunity/A(f nnative Action Employer- 50% Recycled/10°/ Post Consumer Paper
r.
accordance with NC Division of Land Resources and NC Wildlife Resources Commission
requirements.
B-4707, Bridge No. 29 Over Curtis Creek, Avery County
1. Curtis Creek are class C; Tr waters of the State. NCDWQ recommends that the most protective
sediment and erosion control BMPs be implemented to reduce the risk of turbidity violations in
trout waters. In addition, all disturbances within trout buffers shall be conducted in accordance with
NC Division of Land Resources and NC Wildlife Resources Commission requirements.
B-4721, Bridge No. 57 Over Middle Little River, Caldwell County
*Class C: No specific comments.
B-4821, Bridge No. 88 Over Paul's Creek, Surry County
I. Paul's Creek are WS IV waters of the State, and drain to Water Supply Critical Area within 1 mile
of the project study area. Given the potential for impacts to these resources during the project
implementation, the NCDWQ requests that NCDOT strictly adhere to North Carolina regulations
entitled "Design Standards in Sensitive Watersheds" (15A NCAC 04B .0124) throughout design
and construction of the project. This would apply for any area that drains to streams having WS
CA(Water Supply Critical Area) classifications.
B-4836, Bridge No. 59 Over South Fork New River, Watauga County
.
*Class C, +: No project specific conditions.
B-4846, Bridge No. 5 Over Little Hunting Creek, Wilkes County
*WS III: No project specific conditions.
B-4847, Bridge No. 42 Over Moravian Creek, Wilkes County
*Class C: No project specific conditions.
B-5118, Bridge No. 55 Over Lance Creek, Watauga County
1. Lance Creek are class C; Tr waters of the State. NCDWQ recommends that the most protective
sediment and erosion control BMPs be implemented to reduce the risk of turbidity violations in
trout waters. In addition, all disturbances within trout buffers shall be conducted in accordance with
NC Division of Land Resources and NC Wildlife Resources Commission requirements.
B-5146, Bridge 302 Over Middle Fork Reddies River, Wilkes County
1. Middle Fork Reddies River Creek are class WS II; Trout, High Quality Water waters of the State.
NCDWQ recommends that the most protective sediment and erosion control BM-Ps be implemented
to reduce the risk of turbidity violations in trout waters. In addition, all disturbances within trout
buffers shall be conducted in accordance with NC Division of Land Resources and NC Wildlife
Resources Commission requirements.
2. Review of the project reveals the presence of surface waters classified as WSII; Tr; High Quality
Waters of the State in the project study area. This is one of the highest classifications for water
quality. Pursuant to 15A NCAC 2H. 1006 and 15A NCAC 2B .0224, NCDOT will be required to
obtain a State Stormwater Permit prior to construction except in North Carolina's twenty coastal
counties.
B-5147, Bridge 327 Over Little Buffalo Creek, Ashe County
1. Little Buffalo Creek are class C;Tr, + waters of the State. NCDWQ recommends that the most
protective sediment and erosion control BMPs be implemented to reduce the risk of turbidity
violations in trout waters. In addition, all disturbances within trout buffers shall be conducted in
accordance with NC Division of Land Resources and NC Wildlife Resources Commission
requirements.
General Comments Regarding All of the Above Bridge Replacement Projects
1. Any anticipated dewatering or access structures necessary for construction of bridges should be
addressed in the CE. It is understood that final designs are not determined at the time the CE is
developed. However, the CE should discuss the potential for dewatering and access measures
necessary due to bridge construction.
2. Any anticipated bank stabilization associated with culvert installations or extensions should be
addressed in the Categorical Exclusion (CE) document. It is understood that final designs are not
determined at the time the CE is developed. However, the CE should discuss the potential for bank
stabilization necessary due to culvert installation
3. NCDWQ is very concerned with sediment and erosion impacts that could result from this project.
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.
4. If foundation test borings are necessary; it shall be noted in the document. Geotechnical work is
approved under General 401 Certification Number 3687/Nationwide Permit No. 6 for Survey
Activities.
5. If a bridge is being replaced with a hydraulic conveyance other than another bridge, NCDWQ
believes the use of a Nationwide Permit may be required. Please contact the US Army Corp of
Engineers to determine the required permit(s).
6. If the old bridge is removed, no discharge of bridge material into surface waters is allowed unless
.otherwise authorized by the US ACOE. Strict adherence to the Corps of Engineers guidelines for
bridge demolition will be a condition of the 401 Water Quality Certification.
.7. '.Whenever possible, NCDWQ 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.
8. 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 current version of
NCDWQ's Stormwater Best Management Practices.
9. 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 concrete shall
not be discharged to surface waters due to the potential for elevated pH and possible aquatic life and
fish kills.
10. 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.
11. 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.
12. All work in or adjacent to stream waters shall be conducted in a dry work area unless otherwise
approved by NCDWQ. Approved BMP measures from the most current version of 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.
13. Heavy equipment shall 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.
14. In most cases, the NCDWQ prefers the replacement of the existing structure at the same location
with road closure. If road closure is not feasible, a temporary detour shall be designed and located
to avoid wetland impacts, minimize the need for clearing and to avoid destabilizing stream banks.
If the structure will be on a new alignment, the old structure shall be removed and the approach fills
removed from the 100-year floodplain. Approach fills shall be removed and restored to the natural
ground elevation. The area shall be stabilized with grass and planted with native tree species. Tall
fescue shall not be used in riparian areas.
General Comments if Replacing the Bridge with a Culvert
15. Placement of culverts and other structures in waters, streams, and wetlands shall be 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 down stream of the
above structures. The applicant is required to provide evidence that the equilibrium is being
maintained if requested in writing by NCDWQ. If this condition is unable to be met due to bedrock
or other limiting features encountered during construction, please contact the NCDWQ for guidance
on how to proceed and to determine whether or not a permit modification will be required.
16. 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 shall 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.
17. 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 shall be properly designed,
sized and installed.
Thank you for requesting our input at this time. 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 Amy Euliss at [phone].
cc: Monte Matthews, US Army Corps of Engineers, Raleigh Field Office
Federal Highway Administration
Kathy Matthews, Environmental Protection Agency, e-copy
Marla Chambers, NC Wildlife Resources Commission, e-copy
Troy Wilson, USFWS, Asheville Field Office
Wetlands/401,.Transportation=Permitting Unit
File Copy