20160787_Scoping Comments_20090601

?FK
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
June 1, 2009
MEMORANDUM
To: Melba McGee, Environmental Coordinator, Office of Legislative and Intergovernmental
Affairs
From: David Wainwright, Division of Water Quality
U""J
Subject: Comments on the Environmental Assessment related to proposed NC 125 (Williamston
Bypass) from existing SR 1 182 (East College Road) to existing NC 125 (northwest of
Williamston), Martin County, Federal Aid Project No. STP-125(1), State Project No.
8.109050 1, TIP R-3826.
SHC No. 09-0324
This office has reviewed the referenced document dated April 2009. The NC Division of Water Quality
(NCDWQ) is responsible for the issuance of the Section 401 Water Quality Certification for activities that
impact Waters of the U.S., including wetlands. It is our understanding that the project as presented will
result in impacts to jurisdictional wetlands, streams, and other surface waters. The NCDWQ offers the
following comments based on review of the aforementioned document:
Project Specific Comments:
This project is being planned as part of the 404/NEPA Merger Process. As a participating team
member, NCDWQ will continue to work with the team.
General Comments:
Future environmental documents 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 21-1.0506(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.
3. Environmental assessment alternatives should consider design criteria that reduce the impacts to
streams and wetlands from storm water runoff. These alternatives should include road designs that
allow for treatment of the storm water runoff through best management practices as detailed in the
most recent version of NCDWQ's Stormwater Best Management Practices, such as grassed swales,
buffer areas, preformed scour holes, retention basins, etc.
4. After the selection 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 minimization of impacts to wetlands (and streams) to the maximum extent practical. In
accordance with the Environmental Management Commission's Rules t 15A 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 should be designed to replace appropriate lost functions
Transportation Permitting Unit
1650 Mail Service Center, Ralegh, North Carolina 27699-1650
Location: 2321 Crabtree Blvd., Ralegh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: hitpIth2o.encstate.nc.uslncwetlandst
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An Equal Opportunity 1 At<rma6ve Action Employer
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and values. The NC Ecosystem Enhancement Program may be available for use as wetland
mitigation.
5. In accordance with the Environmental Management Commission's Rules (15A NCAC 2H.0506[h]),
mitigation will be required for impacts of greater than 150 linear feet to any single perennial stream.
In the event that mitigation is required, the mitigation plan should be designed to replace
appropriate lost functions and values. The NC Ecosystem Enhancement Program may be available
for use as stream mitigation.
6. Future documentation, including the 401 Water Quality Certification Application, should continue
to include an itemized listing of the proposed wetland and stream impacts with corresponding
mapping.
7. NCDWQ is very concerned with sediment and erosion impacts that could result from this project.
NCDOT should address these concerns by describing the potential impacts that may occur to the
aquatic environments and any mitigating factors that would reduce the impacts.
8. 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 construction impacts,
temporary or otherwise, also need to be included as part of the 401 Water Quality Certification
Application.
9. Where streams must be crossed, NCDWQ 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.
10. Sediment and erosion control measures should not be placed in wetlands or streams.
11. 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.
12. The 401 Water Quality Certification application will need to specifically address the proposed
methods for stormwater management. More specifically, stormwater should not be permitted to
discharge directly into streams or surface waters.
13. Based on the information presented in the document, the magnitude of impacts to wetlands and
streams may require an Individual Permit (IP) 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 quality 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 NCDWQ. 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.
14. If concrete is used during construction, a dry work area should be maintained to prevent direct
contact between curing concrete and stream water. Water that inadvertently contacts uncured
concrete should not be discharged to surface waters due to the potential for elevated pH and
possible aquatic life and fish kills.
15. If temporary access roads or detours are constructed, the site should be graded to its preconstruction
contours and elevations. Disturbed areas should be seeded or mulched to stabilize the soil and

appropriate native woody species should be planted. When using temporary structures the area
should 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.
16. Placement of culverts and other structures in waters, streams, and wetlands should 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 should 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.
17. If multiple pipes or barrels are required, they should 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.
18. 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.
19. All work in or adjacent to stream waters should be conducted in a dry work area. 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 should be used to
prevent excavation in flowing water.
20. 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 should be inspected daily and maintained to prevent contamination of surface waters
from leaking fuels, lubricants, hydraulic fluids, or other toxic materials.
21. Riprap should 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.
22. Riparian vegetation (native trees and shrubs) should 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.
NCDWQ appreciates the opportunity to provide comments on your project. Should you have any questions
or require any additional information, please contact David Wainwright at [phone].
cc: Bill Biddlecome, US Army Corps of Engineers, Washington Field Office
Clarence Coleman, Federal Highway Administration
Chris Militscher, Environmental Protection Agency (electronic copy only)
Travis Wilson, NC Wildlife Resources Commission (electronic copy only)
Garcy Ward, NCDWQ Washington Regional Office
File Copy
Department of Environment and Natural Resources
Project Review Form
Number: 09-0324 County: Martin Date Received: 05/13/2009
Due Date: 6/8/2009
Project Description: Environmental Assessment - NC 125 Williamston Bypass, Martin County,
TIP Project No. R-3826

s ro?ec s emg Ieviewe as m ica e e ow:
Regional Office Regional Office Area In-House Review
Asheville ? Air - Soil & Water ? Marine Fisheries

Fayetteville Water ? Coastal Management Water Resources
-
Mooresville
? Aquifer Protection
Wildlife Environmental Health
?
- ? Wildlife - DOT _ Solid Waste Mgmt
_ Raleigh ? Land Quality Engineer
? Forest Resources
_ Radiation Protection
/ Washington Land Resources Other
Wilmington
-
/ Parks & Recreation
Winston-Salem
-
Water Quality
? Water Quality DOT
Air Quality

Date: - In-House Reviewer/Agency:
Manager Sign-Off/Region:
Response (check all applicable)
No objection to project as proposed. _ No Comment
_
iew
l zOther (specify or attach comments) see_
ete rev
Insufficient information to comp __

If you have any questions, please contact: fp06
Melba McGee, Environmental Coordinator at [e-mail] a E ,? 1 g Zp09
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