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C�tI�F1AE'L S. RE�AN
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September 28, 2018
MEMORANDUM
To: Crazg A. Freeman, NCDOT Division 6 Division Project Engineer
From: Joanne Steenhuis, NC Division of Water Resources, Wilmington Regional Office ���f Y"�
Subject: Scoping commeuts on proposed roadway widening ofNC 210 (Murchison Road) from I-295 (Fayetkeville
Outer Loop) to south of US 401 Bypass in Cumberland County, TTP U-4900.
Reference your correspondence dated September 25, 2018 in which you requested comments for the referenced
project. Preliminary analysis of the project reveals the potential for multiple impacts to streams and jurisdictional
wetlands in the project area. More specifically, impacts to:
Strearo Name
Little Cross Creek (Bounie Doone I.ake,
Kombow Lake, Mintz Pond1
Cross Creek (Big Cross Creek) (Texas
Pond, Smith Lake. Rose Lake 1
Little Cross Creek t Glenvi]Ie Lake}
Cross Creek i, � i� Cross Creek I
Cross Creek l E3i�. Cross Creekl
River Basin Stream
Classificati�
Cape Fear � WS•N
Cape Fear WS-IV
Fear � WS-IV;CA
Fear WS-IV;CA
Fear C
Stream Index
Number
18-27-4-(1)
18-27-(1)
18-27-4-(1.51
18-27-f 2.5 )
303{d) Listing
N/A
Yes
N/A
N/A
N/A
Further investigarions at a higher resolurion should be undertaken to verify the presence of other streams aadlor
jurisdictional wetlands in the area. In the event that any jurisdictional areas are identified, the Division of Water
Resources requests that NCDOT consider the following environmental issues for the proposed project:
Project Specific Comments:
1. To meet the requirements of NCDOT's NPDES permit NCSQOo250, the road design plans shall provide
treatment of the stormwater runofFthrough BMPs as detailed in the most recent version of the North
Carolina Deparnnent o,f Transportation Stormwater Best Management Practtces Toolbox manual. The
BMPs should, to the MEP, be selected and designed to reduce impacts of the target pollutants of concem
(POCs) far the receiving waters_
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2. Cross Creek (Big Cross Creek) is class WS-N; 303(d) waters ofthe State. Cross Creek is on the 303{d)
list for impaired use for aquatic life due to exceeding criteria. The NCDWR is very concerned with
sediment and erosion impacts that coutd result from this project. The NCDWR recommends that the most
protective sediment and erosion control BMPs be implemented in accordance with Design Standards in
Sensitive Watersheds (15A NCAC 04B .0124) or comparable BMPs to reduce the risk of further
impairtnent to Cross Creek. Post-consriuction stormwater BMI's should, to the MEP, be selected and
designed to reduce target POCs in the 303(d) list for the receiving waters.
3. Review of the pmject reveals the presence of surface waters classified as VVater Supply Critical Area in
the project study area. Given the potential for impacts to these resources during the project
implementation, the NCDVVR requests that NCDOT strictly adhere to North Carolina regulations entitled
Design Standards in Sensitive A'atersheds (15A NCAC 04B .0124) throughout dasign and construction
of the project. This would apply for any area that drains to streams having WS CA (Water Suppiy
Critical Area) classifications.
Should the bridge project be located within the Critical Area of a Water Supply, the NCDOT may be
required to design, canstruct, and maintain hazardous spill catch basins in the project area. T'he number
of catch basins installed should be determined by the design of the bridge, so that runoff would enter said
basin(s) rathee than flowing directly into the stream, and in consultation with the NCDWR.
General Project Comments:
4. The environmental document should provide a detailed and itemized presentation of the proposed
impacts to wetlands and streams with corresponding mapping. If mitigarion is necessary as required by
15A NCAC 2H.0506(h), it is preferable to presenl 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.
5. Environmental impact statement alternatives shall consider design criteria that reduce the impacts to
streams and wetlands from storm water runoff. These alternatives shall include road designs that allow
for treatment of the stvrm water runoff through BMPs as detailed in the most recent version of the North
Carolina Department of Transportation Slormwater Best Management Practices Tool box manuai, such
as grassed swales, buffer areas, preformed scour holes, retention basins, etc.
6. After the selection of the preferred altemative and prior to an issuance of the 401 Water Quality
Cerkification, the NCDOT is respectfully reminded that they will need to demonstrate the avoidance and
minimization of impacts to wetlands (and streams) to the maacimum extent practical. In accordance
with the Environmentai Management Commission's Rules (15A NCAC 2H.0506[h]), mitigarion will be
required for impacts of greater than 1 acre to wetlands. In the event that mirigation is required, the
mitigation plan shall be designed to replace appropriate lost functions and values. North Carolina
Division of Mitigation Services may be available for assistance with wetland mitiga#ion.
7. In accordance with the Environmental Management Commission's Rules (15A NCAC 2H.0506[h]),
mirigation will be required for impacts of greater than 3001inear feet to �ny perennial stream. In the
event that mitigation is required, the mitigation plan shall be designed to replace appropriate lost
functions and values. The North Carolina Division of Mitigation Services may be avaiiable for
assistance with stream mitigation.
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8. Future documentation, including the 401 Water Quality Certification Applicarion, shall continue to
include an itemized listing oFthe proposed wetland and stream impacts with corresponding mapping.
9. The NCDWR is very concerned with sediment and erosion impacts that could result from this project.
The NCDOT shail address these concerns by describing the potential impacts that may occur to the
aquatic environments and any mirigating factors that would reduce the impacts.
10. An analysis of cumulative and secondary impacts anticipated as a result of this project is required. The
type and detail of analysis shall conform to the NC Division of Water Resource Poiicy on the
assessment of secondary and cumulative impacts dated Apri110, 2004.
11. 'The 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 unpact calculations. These impacts, in addition to any construction impacts,
temporary or otherwise, also need to be included as part of the 4Q 1 Water Quality Certification
Application.
12. Where streams must be crossed, the NCDWR prefers bridges be used in lieu of culverts. However, we
realize that economic considerations often require the use of culverts. Please be advised that cuiverts
should be countersunk to allow ununpeded passage by fish and other aquatic organisms. Moreover, in
areas where high quality wetlands or strearns are impacted, a bridge may prove preferable. When
applicable, the NCDOT should not install tlie bridge bents in the creek, to the maximum extent
practicable.
13. Whenever possible, tUe NCDWR prefers spanning structures. Spanning structures usually do not
require work within the streaxn or grubbing of the streambanks and do not require stream channel
realigoment. The harizontal and vertical clearances provided by bridges shalt allow for human and
wildlife passage beneath the structure. Fish passage and navigation by canoeists and boaters shall not be
blocked. Bridge supports (bents) shouId not be placed in the stream when passible.
14. Bridge deck drains shall not discharge directly into the stream. Stormwater shall be directed across the
bridge and pre-treated throngh site-appropriate means (grassed swales, pre-formed scour holes, vegetated
buffers, etc.) before entering the stream. To meet the requirements of NCDOT's NPDES permit
NCS00025Q, please refer to the most recent version of the North Carolina Department of Transportation
Stormwater Best Management Practices Taolbox manual for approved measures.
15. Sediment and erdsion control measures should not be placed in wetlands or streams.
16. Borrow/waste areas should avoid wetlands to ti�e 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.
17. The 401 Water Quality Certification application will need to specifically address the proposed methods
for stormwater management. More specificafly, stormwater shall not be permitted to discharge directly
into streams or surface waters. To meet the requirements of NCDOT's NPDES pemut NCS000250,
please refer to the most recent version of the North Carolina Department of Transportation Stormwater
Best Management Practices Toalbox manual for approved measures.
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18. The DWR cannot comment on permit requirements with the limited information provided. Detailed field
delineativn is required to determine the presence or absence of jurisdictional resources within the project
limits. In addition, NCDOT must provide an estimate to any resources located within the construction
limits of the project area before we can specifically comment on NCDWR permit eligibility. Final
permit authorization will require the submittal of a formal applicatian by the NCDOT and written
concurrence from the NCDWR. Please be aware that any approval will be contiugeut on appropriate
avoidance and minimization of wetland and strearn impacts to the maximum eactent pracrical, the
davelopment of an acceptable stermwater management plan, and the inclusion of appropriate mitigation
plans where apprapriate.
19. If concrete is used during construction, a dry work area shall be maintained to prevent direct contact
between curing concrete and stream water. Water that inadvertently contacts uncured concrete shall not
be discharged to surface waters due to the potential for elevated pH aud possible aquatic life and fish
kills. Concrete shall be handled in accordance with the NPDES Construction General Permit
NCGO10000.
20. If temporary access roads or detours are constructed, the site shall be graded to its preconstruction
contours and elevarions. Disturbed areas shall be seeded or mulched to stabilize the soil and appropriate
narive woody species shall be planted. When using temporary st�uctures the area shall 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.
21. Unless otherwise authorized, placement of culverts and other structures in waters and streams shall 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 piacement of culverts and other struciures
including temporary erosion control measures shall not be conducted in a manner that may result in dis-
ec{uilibrium of wetlands or streambeds or banks, adjacent to or upstream and downstream of the above
structures. The applicant is required to provide evidence that the equilibrium is being maintained if
requested in writing by the NCDWR. If this condirion is unable to be met due to bedrock or other
limiting features encountered during construction, please contact the NCDWR for guidance on how to
proceed and to determine whether or not a permit modification will be required.
22. If multiple pipes or barrels are required, they shall 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. Wideni.ng 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.
23. If foundation test borings are necessary; it shall be noted in the documen� Geotechnical work is
approved under General4U 1 Certification Number 4085/Nationwide Permit No. 6 for Survey Activities.
24. 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.
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25. All work in or adjacent to stream waters shall be conducted in a dry work area. Approved BMP
measures from the most current version of the NCD�T Construction and Maintenance Activities manual
such as sandbags, rock berms, cofferdams and other diversion structures shall be used to prevent
excavation in flowing water.
26. While the use of National Wetland Inventory (NWI) maps, NC Coastal Region Evaluation of Wettand
Significance (NC-CREWS) maps and soil survey maps are useful tools, their inherent inaccuracies
require that qualified personnel perform onsite wetlaQd delinearions prior to permit approval.
27. Heavy equipment should be operated from the bank rather than in stream channels in order to minimize
sedimentation and reduce the likeiihood of introducing other pollutants into streams. This equipment
shall be inspected daily and maintained to prevent contamination of surface waters from leaking fizels,
lubri.cants, hydraulic fluids, or other toxic materials.
28. Riprap shall 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,
29. Riparian vegetation (narive trees and shrubs) shall be preserved to the maximum extent possible.
IZiparian vegetation must be reestablished within the construction lunits of the project by the end of the
growing season following completion of construction.
Thank yon for requesting our input at this time. The NCDOT is reminded that issuance of a 401 Water Quality
Certificafion requires that appropriate measures be instituted to enswe that water quality standards are met and
designated u5es are not degraded or lost. If you have any yuestions ar reqnire additional information, please contact
Joanne Steenh.uis at [phone] or [e-mail].
Electranic copy only distribution:
Jim Rerko, NC DOT Division 6 Division Envitonmental Officer
Li� Hair, US Army Corps of Engineers, Wilmington Field Office
Kristi Lynn Carpenter, NCDWR
File Copy
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