20050688 Ver 2_WRC Comments_20061228

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FAX COVER
Date 12/28/06
Number of pages including cover sheet 4
To: Cyndi Karoly
NC Wildlife Resources Commission
Habitat Conservation Program
P. O. Box 129
Sedalia, NC 2T3d2-0129
From: Shari Bryant
Phone Phone [phone]
Fax Phone [phone] Fax Phone [phone]
CC:
REMARKS:
^ Urgent ^ For your review ^ Reply ASAP ^ Please comment
Corps Action ID No.: SAW-2005-21057-201 (DWQ ID: V2 05-0688))
Martin Marietta Materials, Inc., East Alamance Quarry, Alamance County
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I North Carolina'VV~ildlife Resources Commission ~I
Richard B. Hamilton, Executive Director
MEMORANDUM
TO: Mr. Monte Matthews, U.S. Army Corps of Engineers
,~,R~aleigh Re latory Field Office
FROM: Shalri~ rant, Piedmont Region Coordinator
y
Habitat Conservation Section
DATE: 28 December 2006
SUBJECT: Public Notice for Martin Marietta Materials, Inc, East Alamance Quarry, Alamance
County, North Carolina. Corps Action ID #: SAW-2005-21057-201
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the
subject document and we are familiar with the habitat values of the area. Our comments are provided in
accordance with provisions of the Clean Water Act of 1977 (as amended}, Fish and Wildlife Coordination
Act (48 Stat. 401, as amended; 16 U.S.C. bb 1-667d), and North Carolina General S#atutes (G.S. 113-131
et seq.}.
Martin Marietta Materials, Inc. proposes to expand the East Alamance Quarry. The proposed
project would permanently impact 0.44 acres of jurisdictional wetlands, 9851inear feet of stream channels
exhibiting important aquatic functions (of which 981inear feet are considered perennial), and 1,230 linear
feet of stream channels lacking important aquatic functions. Impacts to the wetlands and an unnamed
tributary to Boyd's Creek would result from expanding the mine pit area and construction of the berm.
Impacts to Boyd's Creek would result from construction of the mine entrance. The purpose of the project
is to expand the existing mine pit to meet the local demand for aggregate material. The applicant
proposes payment to the North Carolina Ecosystem Enhancement Program to mitigate for unavoidable
impacts to jurisdictional features.
Boyd's Creek is a tributary to Haw River in the Cape Fear River basin. According to information
provided in the Public Notice, the site is primarily forested with some cleared agricultural fields and
pastures and contains four streams and two wetland areas.
in the document, Stormwater Impact Analysis and Minimization, portions of the watershed for
Stream A and Wetland B/Scream C would be removed by mine pit expansion To provide supplemental
hydrology to Wetland B, the applicant proposes to divert stormwater flows from an off-site farm pond
into Wetland B. A 36-inch CMP riser would be installed in the existing farm pond and approximately
1,300 linear feet of 24-inch CMP, 3 junction boxes, and a headwall to daylight the pipe would be used to
convey the stormwater. The 24-inch pipe system would flow through a trapezoidal grass lined channel to
a dry detention pond designed to reduce the post-development Z-year, 24-hour peak discharge to pre-
Mailing Address: Division of Inland Fisheries 1721 Mail Service Cerrter • Raleigh, NC 27699-1721
Telephone: [phone]U • Fax: [phone]
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Page 2
28 December 2006
East Alamance Quarry
Corps Action ID #: SAW-2005-21057-201
development levels. A 24-inch CMP riser would outfall to a level spreader and larger flows would pass
through an 18-inch CMP that directly outfalls to Wetland B. This design would provide extended
hydration and diffused flow to Wetland B/Stream C.
To reduce impacts to approximately 1,000 linear feet of intermittent stream channel {Stream A)
downstream of the proposed mine pit expansion, water would be pumped from Boyd's Creek into the
stream channel to provide periodic flow. The pump intake hose would be located in a deep pool in
Boyd's Creek and would include a sediment screen to protect the pump. Water would be conveyed
through approximately 304 linear feet of4-inch ductile iron pipe. The pre-development base flow for
Stream A is approximately 0.54 cfs or 220 gallons per minute. The pump would be set to turn on and off
when the water level in Boyd's Creek reaches a field determined elevation. Once the mine pit is
expanded, a modification to the mine's NPDES permit would be requested to allow for a discharge to
Stream A.
We appreciate the applicant's efforts to try to minimize secondary impacts to the remaining
streams and wetlands within the project boundaries. We question whether it would be feasible to
construct a stream channel using natural channel design between the farm pond on Stream A and Wetland
B/Stream C rather than piping flow,. Stream piping eliminates aquatic and terrestrial wildlife habitat,
whereas constructing of a natural channel and establishing riparian buffers would restore some of the lost
aquatic and terrestrial wildlife habitat and further minimize impacts to aquatic and terrestrial wildlife
resources.
We hesitate to concur with the piping of stream channels due to the potential for long-term and
cumulative impacts. Likewise, we hesitate to concur with the excavation of wetlands due to their wildlife
habitat value and the well-known beneficial functions they provide for flood control and water quality
protection. However, should the permit be issued, we recommend the following conditions be
incorporated to further minimize impacts to aquatic and terrestrial wildlife resources.
1. Use natural channel design for conveying water from the farm pond on Stream A to Wetland
BlStream C, if feasible. if piping must be used, implement a monitoring program to ensure that
the engineered stormwater devices (i.e., detention pond/tevel spreader) are adequate to prevent
future degradation to Wetland B(Stream C.
2. The pump in Boyd's Creek should be irtstalled and operated in a manner to minimize
impingement and entrainment of aquatic life. NCWRC's general recommendations regarding
intake structures are these should utilize passive screens with openings not to exceed 1 centimeter
and with a maximum intake velocity of 0.5 fps (feet per second).
3. Use bridges for all permanent roadway crossings of streams and associated wetlands to eliminate
the need to fill and culvert, where practicable. if culverts must be used, the culvert should be
designed to allow passage of aquatic organisms. Generally, this means that the culvert or pipe
inved is buried at least one foot below the natural streambed. If multiple cells are required, the
second and/or third cells should be placed so that their bottoms are at stream bankfull stage. This
will allow sufficient water depth in the culvert or pipe during normal flows to accommodate
movements of aquatic organisms. If culverts are long and sufficient slope exists, baffle systems
are recommended to trap gravel and provide resting areas for fish and other aquatic organisms. If
multiple pipes or cells are used, at least one pipe or box should be designed to remain dry during
normal flows to allow for wildlife passage. In addition, culverts or pipes should be situated so
that no channel realignment or widening is required. Widening of the stream channel at the inlet
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28 December 204b
last Alamance Quarry
Corps Action 1D ~: SAW-2005-21457-201
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or outlet of structures usually causes a decrease in water velocity causing sediment deposition that
will require future maintenance_ Finally, riprap should not be placed on the streambed.
4. To minimize additional stream impacts, while retaining some measure of wildlife habitat, we
recommend a 100-foot undisturbed, native, forested buffer along perennial streams, and a SQ-foot
buffer along intermittent screams and wetlands. Maintaining undisturbed, forested buffers along
these areas will minimize impacts to aquatic and terrestrial wildlife resources, water quality, and
aquatic habitat both within and downstream of the project area. In addition, wide riparian buffers
are helpful in maintaining stability of stream banks and for treatment of pollutants associated with
stormwater runoff. Whereas, a grassed buffer, particularly fescue, is a vegetated buffer but will
not provide the necessary and highly valuable functions as discussed for forested buffers.
S. We recommend all remaining wetlands and streams on the site be protected from additional
impacts by placing them in a permanent conservation easement to prohibit filling, draining,
flooding, and excavation.
6. Specialized efforts and techniques should be implemented to reduce sediment runoff from
construction activities. Excessive silt and sediment loads can have numerous detrimental effects
on aquatic resources including destruction of spawning habitat, suffocation of eggs, and clogging
of gills of aquatic species.
7. The applicant proposes to mitigate for stream and wetland impacts by payment into the North
Carolina Ecosystem Enhancement Program (EEP). It is unclear whether EEP has accepted this
proposal. We request that acceptance by EEP is documented before impacts occur.
Thank you for the opportunity to comment on this project. [f we can provide further assistance,
please contact our office at [phone].
cc: Cyndi Karoly, DWQ (DWQ ID#: V2 OS-0688)
ec: Corey Oakley, WRC
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