NCDWR Scoping Comments_U-6013_Alamance.docx

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MEMORANDUM
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September 6, 20�18
To: Tommy Register, Project Manager, TGS Engineers
From: Apcil Norton, Environinental Senior Specialist, NCDWR Transportation Per�nittina Branch
Subject: Scoping comments for the proposed widening to NC 119 to multiple lanes from SR 1981
(Trollingwood-Hawfields Road) / SR 2126 (Old Hillsborough Road) to Lowes Boulevard in
Mebane, Alamance Counry; STIP Project NumUer U-6013.
A request for cominents was dated and received AugList 24, 2018 for the subject project Prelin�inary
analysis of tl�e project reveals the potential for impacts to streams in the project area. More specifically,
i�npacts to the features identifed in Table l.
Table 1. Streams
Stream Name
Little Haw River
ent to proiect studv area.
River Basin / Stream
Sub Basin Classi�cations
Cape Fear / WS-V; NSW
CPF02
Stream Index 303(d) Listing
Number
1(-20-3 No
Further investigations at a higher resolution sliould be nndertaken to verify the presence of any streams
and/or jurisdictional wetlands in the area. If any jurisdictional feahires are idei�titied, tl�e Division of Water
Resources requests th�t the following envirorunental issues for the proposed project are considered:
Project Specific Comments:
1. Little Haw Creelc is classified as water supply five (WS-V); mitrient sensitive waters (NSW) of the
state. NCDWR is concetned with sediment and erosion impacts that could result fi•om this project.
NCDWR recommends protective sediment and erosion connol BMPs be implemented to reduce fiirther
degradation to Little Haw Creek and tributaries.
Additionally, to meet the requirements of NCDOT's NPDES perm�it NCS0000250, NCDWR requests
that road design plans provide treannent of the storm water runoff tluough best management practices
as detailed in the most recent version of NCDWR Sto�-rmvater� Best Mcanagement P��c�ctices.
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North Carolina Department of Environmental Quality I Division of Water Resources
�12 North Salisbury Street I 1617 Mail Service Center � Raleigh, North Carolina 2 7 699-161 7
919.707.9000

2. Tlus project is within the Jordan River Buffer Basin. Riparian bttffer iinpacts shall be avoided and
nlinimized to the� greatest exte»t possible pursuant to 15A NCAC 2B .0267. New development activities
located in the protected 50-foot wide riparian areas within the basin shall be limited to "uses" identified
wiHlin and constructed in accordance with 15A NCAC .02B .0295. Buffer �1litigation n�ay be required
for buffer impacts res�ilting from activities classified as "allowable with mitigation" within the "Table
of Uses" section of the Buffer Rules ar require a variance under the Buffer Rules. A buffer mitigation
plan, including use of the North Carolina Division of Mitigation Services, must be provided to the
NCDWR prior to approval of the Water Quality Certification. Buffer mitigation may be required for
buffer impacts resulting fr-on� activities classiiied as "allowable with nlitigation" within the "Table of
Uses" section of the Buffer Rliles or require a variance under the B�iffer Rules. A buffer mitigation
plan, coordinated with the North Carolina Division of Mitigation Services, must be provided to the
NCDWR priar to approval of the Water Quality Certification.
General Project Comments:
The eilviromnental docu�nent should provide a detailed and itemized presentation of the proposed
impacts to wetlands and streams with coi�responding inapping. If mitigation is necessary as required
by l5A NCAC 2H.0506(h), it is preferable to present a conceptual (if not finalized) mitigation plan
with the environmental docun�entation. Appropriate lnitigation plans will be required prior to issuance
of a 401 Water Quality Certification.
2. Environmental in�pact statement alternatives shall consider design criteria that reduce the impacts to
streams and wetlands fi-om storm water ninoff. These alternatives sl�all include road designs that allow
for treamlent of the storm water runoff through best manageinent practices as detailed iu the most
recent version of the North Carolina Depurtment of Trarasportation Storinwatet� Best Managerrieizt
Pr•actices Tool box inanual, such as grassed swales, buffer areas, preformed scour holes, rete�ltioi�
basins, etc.
3. 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 sheams) to the n�aximum extent practical. In
acco�-dance with the Environinental Management Commission's Rules (15A NCAC 2H.0506[h]),
initigation will be required for unpacts of greater than 1 acre to wetlands. If iuitigation is required, the
mitigation plan shall be designed to replace appropriate lost functions and values. North Carolina
Division of Mitigation Seivices may be available for assistance witl� wetland mitigation.
4. In accordance with the �nvironnlental Management Conulussion's Rules (15A NCAC 2H.0506[h]),
mitibatio�z will be rec�uired for impacts of �eater than 300 linear feet to any perennial stream. If
mitigation is reqtiired, the mitigation plan shall be designed to replace appropriate lost fimctions and
values. The North Carolina Division of Mitigation Services may be available for assistance with
stream mitigation.
5. Future documentation, including the 401 Water Quality Cet-tification Application, shall continue to
incl�ide an itemized listing of the proposed wetland and stream impacts with corresponding n7apping.
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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, Nor[h Carolina 27699-1617
919.707.9000

6. The NCDWR is very concerned with sediment and erosion impacts tl�at could resL�ilt from this project.
The NCDOT shall address tl�ese conceri�s by describing tl�e potential impacts tl�at may occur to the
aquatic environments and any mitigating factors that would reduce the impacts.
7. An analysis of any anticipated c�tinulative and secondary impacts dLie to this project is required. The
type and detail of analysis shall conform to the NC Division of Water Resource Policy on the
assessment of secondary and cumulative impacts dated April 10, 2004.
8. The NCDOT is respectfully re�ninded that all impacts, inchiding but not limited to, bridging, fill,
excavation and clearing, and rip rap to jurisdictional wetlands, streams, and riparian Uuffers need to be
included in the final itnpact calculations. Tllese impacts, in addition to any construction iinpacts,
telnporary or otherwise, also need to be included as part of the 401 Water Quality Certification
Application.
9. Where sn-eams must be crossed, the NCDWR prefers that bridges are used in lieu of culverts.
However, we realize that economic considerations often require the use of culverts. Please be advised
that culverts shoLild be countersunk to allow �mimpeded passage by fsh and other aqLiatic o�-ganisms.
Moi-eover, in areas where high quality wetlands or st�-eams are impacted, a bridge may prove to be
preferable. When applicable, the NCDOT should ��ot install the bridge bents in tl�e creek, to fl1e
maximum extent pr�cticable.
10. Whenever possible, th� NCDWR prefers spanuing sntiictures. Spanning snuchires usually do not
require work within the streanl ar gnibbing of the streambai�lcs and do not require stream channel
realignment. The horizontal and vertical clearances provided by bridges shall allow for hu�nan ai�d
wildlife passage beneath the strucnire. Fish passage and navigation by canoeists and boaters shall not
be bloc]<ed. Bridge supports (be�lts) should not be placed it� the stream when possible.
11. Bridge deck drains shal1 not dischar�e directly into the stream. Stonnwater shall be directed across
the bridge aud pre-treated through site-appropriate means (grassed swales, pre-formed scour holes,
vegetated buffers, etc.) before entering the stream. To meet the requirements of NCDOT's NPDES
pennit NCS0000250, please refer to the most i-ecent version of the North Cm-oliraa Depart�nei�t of
Tr�rnsportatiot7 Stormwater Best Mar�agerr�ent Prc�ctices Toolbox manual for appi-oved measures.
12. Sediment and erosion control measures should not be placed in wetlands or streams.
13. Bonow/waste areas should avoid wetlands to the maximtml extent practicaL Impacts to wetlands iu
borrow/waste areas will need to be presented in the 401 Water Quality Certification and could
precipitate compensatory mitigation.
14. The 401 Water QL►ality Certification application will need to specifically address the proposed inethods
for stormwater ma�lagement. More specifically, stormwater shall not bE perinittEd to discharge
directly into streams or surface waters.
15. Based on the information presented in the doc�ument, fl1e magnitude of impacts to wetlands and streams
may require an application to the Co►-ps of Engineers and corresponding 401 Water Quality
Certification. Please be advised tl�at a 401 Water Quality Certificarion requires satisfact�ory protection
of water quality to ensure that water quality standards are inet, and no wetland or streain uses are lost.
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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, Nor[h Carolina 27699-1617
919.707.9000

Final pei7iut authorization will require the submittal of a formal application by the NCDOT and written
concurrence from the NCDWR. Please be aware that any approval will be contingent on appropriate
avoidance and ininiinization of wetland and stream iinpacts to the inaximum extent practical, the
developinent of an acceptable stor�nwater mauagenlent plan, and tl�e inclusio�7 of appropriate
rnirigation plans where appropriate.
16. If concrete is used during constructioi�, a dry work area shall be maintained to prevent direct contact
between curing concrete and streain water. Water that inadvertently contacts uncured concrete sl�all
not be discharged to surface waters due to the potential for elevated pH and possible aquat�ic life and
fish kills.
17. If temporary access roads or detours are constilicted, the site shall be graded to its preconstruction
contours and elevations. Disturbed areas shall be seeded or mulcl�ed to stabilize the soil and
appropriate native woody species shall be pla�lted. Wl�en using temporaiy sn-uchires, tl�e area sliall be
cleared but not gnibbed. Cleai-ing the area with chain saws, nlowers, bush-hogs, or other mechanized
equipillent and leaving the stun�ps and root mat intact allows the area to re-vegetate naturally ai�d
minimizes soil disturbance.
18. Unless otherwise authorized, placement of culverts and other structures in waters and streams shall be
placed below the elevation of the streanlbed by one foot for all culverts wifll 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
stilictures including temporary erosion control measures shall not be conducted in a inanner that inay
i-esult in dis-eqLiilibrium of wetlands or streambeds or banks, adjace�lt to or upsn-eam and downstream
of tl�e above struchires. The applicant is reqaired to provide evidence that the equilibrium is being
maintained if requested in writing by the NCDWR. If this condition is unable to be met due to Uedrock
or other limiting fe�tures encountered during construction, please contact the NCDWR for guidance
on how to proceed and to determine whether a permit modification will be required.
19. Lf inultiple pipes or barrels are required, they shall be designed to nunuc natural streain cross section
as closely as possible ii�cluding pipes or barrels at flood plain elevatiot�, 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 stiuctures typically decreases water velocity callsing
sediinent deposition that requires increased maintenance and disnlpts aqLiatic life passage.
20. Lf foundation test borings are necessary; it shall be noted in the docuinent. Geotechnical work is
approved under General 401 Certiiication NLmlber 3883/Nationwide Permit No. 6 for St�rvey
Activities.
21. Sediment and erosion control measures suff cient to protect water resources must be implemented and
maintained in accorda��ce with the n�ost recent version of North Carolina Sediment and Erosion
Control Planning and Design Manual and the most recent version of NCS000250.
22. All work in or adjacent to stream waters shall be conducted in a dry worlc area. Approved BMP
measures from the most current version of the NCDOT Construction and Maintena��ce Activities
man�ial such as sandbags, rock berms, cofferdams and other diversion structures shall be used to
prevent excavation in flowing water.
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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, Nor[h Carolina 27699-1617
919.707.9000

23. While the use of National Wetland Iuventoiy (NWI) maps, NC Coastal Region Evaluation of Wetla»d
Significance (NC-CREWS) maps and soil survey maps are �iseful tools, their inherent inaccuracies
require that qualified personnel perfonn onsite wetland delineations prior to pet7nit approval.
24. Heavy eqLiipment sl�ould be operated from the banlc ratl�er than in stream channels to minimize
sedimentation and reduce the likelihood of introducing otl�er pollutants into streams. This equipment
shall be iilspected daily and maintained to prevent contamination of surface waters fiom lealcii�g fuels,
lubricants, hydraulic fluids, or otl�er toxic illaterials.
25. Riprap shall not be placed in the active thalweg channel or placed in the sh�eambed in a manner tllat
precludes aquatic life passage. Bioengineering boulders or structures should be properly designed,
sized and installed.
26. Riparian vegetation (native trees and sl�rubs) shall be preserved to the maximum extent possible.
Riparian vegetation must be reestablisl�ed witl�in the construction lii�iits of tl�e project by the end of
the gf-owing season following completion of construction.
Thank you for requesting our input The issuance of a 401 Water Quality Cei-tification requires that
appropriate ineasures be instiriited 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 April
Norton at april.norton a,ncde»r.�.
Sincerely,
DocuSigned by:
�4p,,.�;C n/��,
03BAC6376A6340D...
9/6/2018
Electronic copy only distribution:
David Bailey, US Army Coips of Engineers, Raleigh Field Office
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

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NCDWR Project No.: Comrty:
Applicant:
Project Name:
Date of Issuance of 401 Water Qualitv Certification:
Certificate of Completion
Upon completion of all wa-1< approved within the 401 Water Quality Certification or applicable Buffer Rules, and any subsequent
modifications, tl�e applicant is required to rettirn this certificate to tl�e 401 Transportation Permitting Unit, Nortl� Carolina Division
of Water Resow�ces, 1617 Mail Service Center, Raleigh, NC, 27699-1617. This form may be returned to NCDWR by the applicant,
the applicant's authorized agent, or tlle project engineer. It is not necessary to send cerrificates fi-om all of these.
App7icmrt's Certiftcation
I, , l�ereby state that, to the best of my abilities, due care and diligence was used in
the observation of tlie construction such that Yhe construction was observed to be built within substantial compliance and intent of
the 401 Water Qtitality Certification and Buffer Rules, tl�e approved plans aud specifications, aud otl�er supportii�g materials.
Signahirc: Date:
Age�rt'.s Certificatzon
I, , hercby statc tbat, to the best of iny abilities, due care and diligence was used in
the observation of the construction such that the construction was observed to be built within substantial compliance and intent of
the 401 Water Quality Cerrification and Buffer Rules, tl�e approved plans and specifications, and otl�er supporting rnaterials.
Signature: Date:
Engineer'.s Certificrrtio�a
Partial Final
I, , as a d�ily re�istered ProYessional Enginecr in the State of North Carolina,
having been authorized to observe (periodically, weel<ly, full time) the construction of the project for the Permittee hereby state
that, to the best of my abilities, due care ai�d diligence was used in the observation of the consn-uction such that the constr�iction
was observed to be built within substantial compliance and intent of the 401 Water Quality Certification and Buffer Rules, tl�e
approved plans and specific�tions, and other slippo�tii�g materials.
Si�nature
Datc
Registration No.
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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