DWR Comments

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MEMORANDUM
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Septen�ber 5, 2018
To: Kevin S. Rose, Environmental Coinpliance SpEcialist, Federal Highway Administratiou
DocuSigned by:
From: Dave Wanucha, NC Division of Water Resources, Winston Salem Offic �� ��
9/5/2018
89736FD146FE4AD...
Subject Scoping comments for Blue Ridge Parkway Projects 2D17 and 2A16, Ashe and Alleghany Counties;
Bridges l, 3, and 6 in Alleghany Cotmty, and Bridge 159 in Asl�e County.
Reference your written correspondeuce dated August 17, 20l 8 in which yo�i requested comments for the referenced
projects. Preliminary analysis of the project reveals the poteutial for multiple impacts to streams and jurisdictional
wetlands in the project area. More specifically, impacts to:
Stream Name
CranUen-y Creek
Big Pine Creek
� Brush Creek
Notes: C - fiasic �a�ater
pr•esent dorrnsh•eai�1.
River Basin Stream Stream Index
Classification(s) Number
B and Tr+ 10-1-37
New C and Tr 10-9-10-4
10-9-10
�rds Jo�• all_fi�esh tivaters; B- recreahona! use; Tr is Troeit waters; + is O�rtstm
303(d) Listing
No
Resourre Yi'a�ters (ORYV)
Further investigations at a higher resolutioi� should be lindertal<en to verify the presence of other sn-eams and/or
jtuisdictional wetlands in the area. If any jurisdictional areas are identified, the Division of Water Resources
requests that the National Park Service (NPS) and the Federal Highway Administration (FHWA) consider thE
following environmental issues for the proposed project.
General Project Comments:
Further 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 rec�uired by 15A NCAC
2H.0506(h), it is preferable to present a conceptual (ifnot finalized) mitigation plan with the enviroi�mental
documentation. Appropriate mitigation plans will be rec�uired prior to issuance of a 401 Water Quality
Certification.
2. The NCDWR reconunends that the most protective sediment and erosion control BMPs be implemented to
reduce the risk of turbidity violations in Trout waters. In addition, all distiu•bances within trout buffers should
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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

be conducted in accordance with NC Division of Land Resources and NC Wildlife Resourezs Commission
requiremeuts.
3. ln accordance witl� the Enviroilmental Management Commission's Rules (15A NCAC 2H.0506[h]),
mitigation will be required for impacts of greater than 300 linear feet to any perennial sn•ean1. In the event
tl�at inirigation is rec�uired, tl�e mitigation plan shall be designed to replace appropriate lost fuilctions and
values. The Nortl� Carolina Division of Mitigation Services may be available for assistance with sh•eam
mitigation.
4. Future documentation, including the 40l Water Quality Certificatioi2 Application, shall continue to include an
itemized listing of the proposed wetland and stream impacts witl� correspoilding mappiug.
5. The NCDWR is veiy co��cerned with sediinent and erosiou iiY7pacts that could result fi•om this project. The
NPS and FHWA shall address these� concerns by describing tl�e potential impacts that inay occur to the
aquatic enviromnents and any mitigating factors that would reduce the iinpacts.
6. All impacts, inclttding but not limited to, bridging, fill, excavation and clearing, and rip rap to jLu�isdictional
wetlailds, streains, and ri}�arian buffErs nEed to be inclttded ii1 the tinal impact calculations. These iinpacts, in
addition to any construction impacts, temporary or otl�erwise, also need to be incllided as part of the 401
Water Quality Certification Ap}�lication.
7. Whenever possiUle, the NCDWR prefers sp�nning structures. Spamling structures usually do not require
work withii� the stream or grubbii7b of the streambanlcs and do not require stream chaimel realignmei�t. The
horizontal ancl vertical clearances provided by bridges shall allow for human and wildlife passage beneath the
structure. Fish passage and navigation Uy canoeists and boateis shall not Ue blocked. Bridge supports (Uents)
should not be placed in thE sheain when possible.
8. Sediment and erosion control measures should not be �laced in wetlands or stre�ms.
9. Borrow/waste areas should avoid wetlands to the m�ximum extent practical. Impacts to wetlands in
borrow/waste are�s wil] need to be �resented in the 401 Water Quality Certification and could precipitate
compensatory mitigation.
10. The 401 Water Quality Certification application will need to specifically address th� proposed n7ethods for
stormwater management. More speciFcally, stormwater shall not be penlutted to discharge directly into
streams or surface waters. Please refer to the most recent version of the Nor•td� Cc�r�olir�a DepartiT�e»t of
Tr�ansportntion Storn�tivater Best Mni7agerne��t Practices Toolboa: manual for approved measttres.
11. Based on the information presented in the document, the ir�agnih�de of impacts to wetla»ds and streams �1�ay
require a Natio»wide (NW) a}�plication to the Corps of Engi�ieers and con-es�o�lding 401 Water Qualiry
Certification. Please be advised that a 401 Water Qualiry Certification requires satisfactory protection of
water qLiality to e��sure that water qLialiry stai�dards are met and no wetland or sh-eam L�ses are lost. Final
periuit authorization will require the slibmittal of a formal application by the NCDOT and written concun�ence
from the NCDWR. Please be aware that any approval will be contingent on appropriate avoidance and
minimizaYion of wetLand and stream impacts to Yhe maximum extent practical, the development of an
acceptable stormwater management plan, and the inclusion of appropriate miYigation plans wl�ere appropriate.
12. If concrete is used d�iring construction, a dry work area shall be maintained to prevent direct contact between
c�u-ing concrete and stream water. Water that inadvertently contacts tmcured concrete shall not Ue discharged
to surfiace waters due to the potential for elevated pH and possible aquatic life and fish kills.
13. If tempora�y 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
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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

species shall be planted. When using temporary struchires, the area shall Ue cleared but not gruUbed.
Clearing the are� with cl�ain saws, i7�owers, busl�-hobs, or othei- �1�echanized equipment and leaving tl�e
stumps and root nlat intact allows tl�e area to re-vegetate natw-ally and �ninimizes soil disturbance�.
14. Unless otherwise autl�o�ized, placeinent of culverts and other sn-uctures in watErs and streams shall be placed
below the elevation of the streambed by one� foot for all culverts with a diameter breater than 48 iilches, and
20 percent of the culvert diaineter for culverts having a diameter less than 48 inches, to allow low flow
passage of water aild aquaric life. Design ai�d placei�nent of culverts and other structw-es including temporary
erosion control me�asures sllall not be conducted in a manner tl�at ir�ay result in dis-e�quilibriun� of wetlands or
streai��beds or banks, adjacetlt to or upstream and downstream of the above structures. The applicant is
required to provide evidence that tl�e equilibriun� is being maintained if requested in writing by the NCDWR.
lf tl�is coudition is Lmable to be inet due to bedrock or othe�r limiting feahu-es encoui�tered during consh•uction,
please contact tl�e NCDWR for guidance on l�ow to proceed and to determine wllether or not a pern�it
modification will be required.
15. If multiple pipes or banels are required, they shall be desi`�ned to mimic natural stream cross section as
closely as possible iucludiug pipes or barrels at flood �lain elevation, floodplain benches, aild/or sills inay be
required where appropriate. Wide��ing the st�-eam cl�annel should be avoided. Sh-eam channel widening at the
inlEt or outlet end of shlichires typically decreases water velocity causing sediment depositioil tl�at requires
increased maint�nance and disrupts aqliaric life passage.
16. If foLmdation test borings are necessary; it shall be noted in the docliment. Geotecln7ical work is approved
under Genera1401 Certification Number 4085/Nationwide Permit No. 6 for Survey Activities.
17. Sedimeilt and ecosion control meas�ires s�ifficient to protect water resources must be implen7ented and
maintained in accordance with tl�e most recent version of North C�rolina Sediinent and Erosion Control
Planning and Design Manual.
18. All worlc in or adjacent to stream waters shall be conducted in a dry work area. Approved BMP meas�ires
from the most current version of the NG Deparhnent of Transportation Consh-uction and Maintenance
Activities mam�al sLich as sandbags, rocic berms, cofferdams and other diversion structw-es shall be used to
prevent excavation in ilowing water.
19. Heavy equipment should be operated from the banlc rather than in stream channels to minimize sedimentation
and recluce the likelihood of introduculg other pollutants into streains. This equipment shall be inspected
daily and ulaintained to pr�vent containination of surface waters from leakinb fiiels, lubricants, hydraulic
fluids, or other toxic materials.
20. Riprap shall not be placed in the active thalweg channel or placed in the sn-eambed in a manner that precludes
ac�uatic life passage. Bioengineering boulders or sh-uctures should be properly designed, sized and installed.
2]. Riparian vegetation (native trees and shnibs) shall be preserved to the maximLim extent possible. Riparian
vegetation must be reestablished within the construction limits of the project by the end of tl�ie growing se�ason
following completion of construction.
Thank you for requesting o�ir inpiit at this tiilie. The NPS and FHWA is reminded that iss�iance 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. lf you have any questions or require �dditional information, please
coiltact Dave Wanucha at [phone] or dave.wanucl�[e-mail].
Electronic copy only distribution:
File Copy
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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