SEPA Comments

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August 16, 2018
MEMORANDUM
To: Lynn Hardison, Environmental Assistance and SEPA Coordinator ps
From: Dave Wanucha, NC Division of Water Resources, Winston Salem Regional Office �Jv" g/16/2018
S�ibject: Scopulg comments on proposed widening and improvements to SR 1173 (Williams Road) in Farsytl� County,
WBS Element No. 47082.1.1; TIP U-5617; SEPA Project No. 19-0013
Reference your correspondence dated August 16, 2018 in whicl� you requested comments for the referenced project.
Preliminary analysis of the project reveals the potential for multiple iiupacts to sh-eams and jurisdictionaL wetlands ii1 the
project area. More specifically, in�pacts 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
Blaelcs Creelc Yadlcin Pee Dee WS-IV 12-R7-1-1 No
Further investigations at a higher resolution sl7oiild be �mdertaken to verify the presence of other streams and/or
j«risdictional wetlands in the area. lf anyjurisdictional areas are identified, the Division of Water Resources requests that
l�imley-Horn, as consultant for NC Department oFTransportation, consider the Followinb 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. lf nutigation is necessary as required by 15A NCAC
2H.0506(h), it is preferabte to present a concephial (if not iinalized) mitigation plan with the enviroiimental
documentation. Appropriate mitigation plans will be required priar to issuance of a 401 Water Quality Certification.
Environmental in�pact statement alternatives shall consider design criteria that redliee the impacts to streams and
wetlands from storm water runoff. These alternatives shall include road designs tl�at allow for t�-eatment of the storm
water runoff tl�rough BMPs as detailed in the most recei�t version of the North Carolina Depnrzrnent of
Transportatiori Stor��r�tivater• Best Managenzerat Pr•uctices 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 I Division of Water Resources
512 North Salisbury Street I 1617 Mail Service Center � Raleigh, North Carolina 27699-1617
919.707.9000

3. Ii� accordai�ce with the Environmental Management Commission's Rules (1 SA NCAC 2H.0506[h]), mitigation will
be required for ii��pacts of greater than 300 linear feet to any perennial stream. In tl�e eveut tl�at �nitigation is
required, the mitigation plail sl�all bE designed to replace appropriate lost functions and values. The Nortl� Carolina
Division of Mitigatioi� Services may be available for assistance with sn•eai1� mirigation.
4. Future documentarion, including the 401 Water Quality Certificarion Applicarion, shall conrinue to include an
itemized listing of the proposed wetland aild sn•eam impacts with corresponding mapping.
5. The NCDWR is veiy conceri�ed with sediment and erosion ii77pacts that could result fi-om this project. Tl�e NCDOT
shall address these concerns by describing the potential iinpacts that may occur to tl�e aquatic ei�virouments and any
miti�ating factors that would reduce tl�e impacts.
6. The NCDOT is re�spectfully reillinded tl�at all impacts, including but not liil�ited to, bridging, fill, excavation a11d
cleari�7g, and rip rap to jurisdictional wetlands, stre�ams, and riparia» buffers ileed to be included in the final impact
calciilations. ThEse ilnpacts, in addirion to any consh-uction iinpacts, temporaiy or otherwise, also need to be
included as part of the 401 Water Quality Certification Applicatioil.
7. Sedimeilt and erosioi� control n�easLues sholild not be placed in wetlands or sh-eams.
8. Bon-ow/waste areas should avoid wetlands to tl�e maximum extent practical. Impacts to wetlands in bon-ow/waste
areas will need to be presented in tl�e 401 Water Quality Certification and could precipitate compensatory mitigation.
9. The 401 Water Quality Certiiication appLication will need to specifically address the proposed methods for
stormwater managemeilt. More specifically, stormwater shaLl not be perulitted to discharge directly into streams or
surface waters. To meet the requiremei�ts of NCDOT's NPDES permit NCS000250, please refer to the most recent
ve;rsion of the No�°t/r Ccr�•olina Depar�h��ent of�TNar�spor�tation Stor��itivater Best Mai�agernerat Pr°actices Toolbox
manual for approved meas�ires.
10. Based on the information presented in tl�e document, the inagnitude of impacts to wetlands and streams �nay require a
Nationwide (NW) application to tl�e Coips of Engineers and con-espondiilg 401 Water Quality Certificatio��. Please
be advised tllat a 401 Water Quality Certitication requires satisfactory protection of water quality to ensm-e that water
quality standards are met and no wetland or st�eam iises are lost Final �ermit authorization will req�lire the submittal
of � formal application by the NCDOT and written concun•ence from the NCDWR. Please Ue aware that any
approval will Ue contingent on appropriate avoidance and minimization of wetland and stream impacts to the
maxii11tu17 extent practical, the development of an accepYable stormwater management plan, and the inclusion of
appropriate nutigation plans where appropriate.
11. If concrete is used dtu�ing constniction, a dry work area shall be maintained to prevent direct contact between curing
concrete and sri-eam water. Water tl�at inadvertently contacts uncured concrete sliall i�ot be discharged to surface
waters due to the potential for elevated pH and possible aquatic life �i1d fisl� kills. Concrete sl�all be handled in
accordance with the NPDES Conshliction General Permit NCGO10000.
12. If temporary access roads or detours are constructed, the site shall Ue graded to its preconstniction contours and
elevations. Disturbed are2s shall be seeded or nlulched to stabilize the soil and appropriate native woody species
shall be plailted. When using temporary structtiires the area shall be cleared but not gnibbed. Cle2ring thc area with
chain saws, mowers, bush-hogs, or other mechanized equipment and leaving the stumps and root mat int�ct allows
tl�e area to re-vegetate nat�u•ally ai�d mii�imizes soil dist�ubance.
13. Unless otherwise alithorized, placement of clilverts and other sh-uchires in waters and streams shall be placed below
the elzvation of the streambed by one foot for all culverts with a diameter gre�ter 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 w�ter �nd
ac�uatic life. Design and placement of culverts and other struchires including temporary erosion control me�sures
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North Carolina Department of Environmental Qualiry I Division of Water Resources
512 North Salisbury Street I 1617 Mail Service Center � Raleigh, North Carolina 27699-169_ r
919.707.9000

shall not be coi�ducted in a manner that may result in dis-equilibrium of wetlands or streambeds or banks, adjacei�t to
or upstreail� and downstream of the above structures. The applicant is required to provide evidence that the
equilibrium is being maintained if requested in wciring by the NCDWR. If this condition is unable to be met due to
bedrock or otl�er liiviting features encountered during construction, please contact the NCDWR for guidance on how
to proceed and to determine whether or not a permit modificarion will be required.
14. lf ��nultiple pipes or ban•els are required, t11ey shall be desigued to mimic natural sh•ea�n cross section as closely as
possible includin� pipes or barrels at flood plain elevation, floodplain benches, and/or sills may be required where
appropriate. Widening tl�e stream channel should be avoided. Stream channel wideuing at the inlet or outlet end of
structures typically decreases water velocity causin; sediment deposition that requires iucreased maintenance and
disiupts aquatic life passage.
15. If fotmdation test borin�s are necessary; it shall be noted in the document. Geotechnical work is approved under
General 401 Certif cation Number 4085/Nationwide Permit No. 6�Por Survey Activities.
16. Sediment and erosion control measures sufficient to pcotect water resources must be implemented and u�aintained in
accordance with tl�e most recent version of North Carolina Sediment and Erosion Control Pl�nning and Desi��
Man�ial and the most recent veision of NCS000250.
17. All work in or adjacent to strea��n waters shall be conducted in a dry work area. Approved BMP measures from the
most clirrent version of tl�e NCDOT Coi�struction and Maintenance Activities manual sucl� as sandbags, rock berms,
cofferdams and other diveision structiires sl�all be used to prevent excavatiou in flowing water.
18. While the use of National Wetlancl Inventory (NWI) maps, NC Coastal Region Evaluation of Wetland Significance
(NGCREWS) maps and soil slirvey maps are useful tools, tlieir inllerent ivaccuracies require that qualified personnel
perform onsite wetland delineatione prior to permit approval.
19. Heavy equipment sl�ould be operated fi-om tl�e ban]< rather thail in strean� cl�annEls in order to minimize
sedimentation and reduce the likelihood of introducing other pollutants into streams. This equipment shall be
inspe�cted daily and i��aintaine�d to prevent contamination of sm-face waters from leaking fuels, lubricants, hydraulic
fluids, or other toxic materials.
20. Riprap shall not be placed in the active thalweg chaimel or placed in the streambed in a i�lanner that precludes aquatic
life passage. Bioenaineering boulders or structures should be properly designed, sized and installed.
2L Riparian vegetation (native trees and shrubs) shall be preserved to the maxiinum extent possible. Riparian vegetation
must be reestablished within the construction limits of the project by the end of flie growing seasoi2 following
completion of constniction.
Tllanlc you for requesting our input at this time. The NCDOT is ren�inded that issuance of a 401 Water Quality
Certification requires that appropriate nleasures be instihrted to ensure that water qliality standards are met and designated
uses are not degraded or lost. If you have any c�uestions or require additional information, please contact Dave Wanucha at
[phone] or dave.wanucha�ncdem•.gov.
Elech•onic copy only distribution:
File Copy
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North Carolina Department of Environmental Qualiry I Division of Water Resources
512 North Salisbury Street I 1617 Mail Service Center � Raleigh, North Carolina 27699-169_ r
919.707.9000