U-4753_Scoping

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October 2, 2018
MEMORANDUM
To: Matt Clarke, P�, NCDOT Division 4 Project Develop�nent Engineer
Prom: Rob Ridings, NC Division of Water Resources, Ti•ansportation Peri��itting Branch
Sttbject: Scoping comments on proposed widening of SR 1556 from US 70 Bypass to SR 1003 in Wayne County,
TIP No. U-4753..
Reference your correspondence received October 1, 2018 in which you requested cornrnents for tl�e referenced
project. Preliiminary analysis of the project reveals tl�e potential for impacts to streams, tributaries, buffers and/or
jurisdictional wetlands in tl�e project area. More specifically, impacts to:
Stream Name River Basin Stream Classifications Stream index 303(d) Listing?
Numbec
UT Reedy Creek Neuse C; NSW 27-62-2 No
UT Stoney Creelc Neuse C; NSW 27-62 No
Further investigations at a higlier resolution should be undertaken to verify the presence of other streams and/or
jurisdictional wetlands in the area. Tn the event that any jtn�isdictional areas are identified, the Division of Water
Resot�rces requests tliat NCDOT consider the following environmental issues for the pro}�osed project:
Project Specific Comments:
1. Reedy Creek, Stoney Creek, and their tributaries are class C; NSW waters of the State. The NCDWR is very
conccrned with sediment and erosion impacts that could result fiom this project The NCDWR recouvnends
that highly protective sediment �nd erosion control BMPs be in7plemented to reduce the risk of nutrient r�moff
to these siu•face waters. Post-construction stormwater BMPs sho��ld, to tlle MEP, be selecte�d and designed to
reduce nuhients
2. This project is within the Neuse River Basin. Riparian buffer impacts shall be avoided and minimized to the
greatest extent possible pursuant to 1 SA NCAC 2B.0233. New development activities located i�� the protected
50-foot wide riparian areas within the basin sl�all be limited to "uses'° identified within and consrilicted in
accordance with 15A NCAC .02B .0295. Buffer mitigation may be required for buffer impacts resulting from
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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

activities classifiied as "allowable with mitigation" within the "Table of Uses" section of the Buffer Rules or
require a variance under the BufFer Rules. A buffer mitigation plan, includin� use of tl�e North Carolina
Division of Mitigation Services, must be provided to the NCDWR prior to approval of tlle Water Quality
Certificarion. Buffer initigation i11ay be required for buffer impacts resulting from acrivities classified as
"allowable with rnitigation" within the "Table of Uses" section of the Buffer Rules or require a variance under
the Buffer Rules. A buffer mitigation plan, coordinated with the North Carolina Division of Mitigation
Services, must be provided to the NCDWR prior to approval of the Water Quality Certification.
General Project Comments:
The environmental docu�nent should provide a detailed and itemizEd presentatioi� of the proposed impacts to
wetlands and streams with corresponding mapping. If mitigation is necessary as required by 15A NCAC
2H.0506(h), it is preferable to present a concept�ial (if i�ot finalized) mitigatioil plai7 with the environmental
documeutation. Appropriate mitigation plans will be required prior to issuance of a 401 Water Q�iality
Certification.
Enviromnental impact statement alternatives shall consider design criteria that reduce t11e in�pacts to streains
and wetlands from storm water runoff. These alternatives shall include road designs that allow for treamient
of the storm water i2inoff through BMPs as detailEd ii1 the ��7ost recent version of the North Cai�olina
De}�crrtment of Trcz��s�ortatiora Sto�•n���,vater• Best Mnnagement Practices Tool box manual, sLich as grassed
swales, buffer areas, preformed scour holes, retention basins, etc.
After tl�e selection of the preferred alternative and prior to au issuance of the 401 Water Quality Certiiication,
the NCDOT is respectfully reminded that they will need to demoilstrate the avoidance and miniinization of
impacts to wetlands (and streams) to the maximum extent practical. In accordance with the Enviroml7ental
Management Commission's Rllles (15A NCAC 2II.0506[l�]), nutigation will be requ�ued for impacts of
greater than 1 acce to wetlands. ln fl1e event that mitigatioil is required, the nutigation plan shall be designed
to replace appropriate lost functioils and values. North Carolina Division of Mitigation Services may be
availaUle for assistance with wetland mitigation.
In accordance with the Envirommental Management Co��m�nission's Rules (15A NCAC 2H.0506[h]),
mitigation will be required for impacts of greater than 300 linear feet to any perennial stream. li1 the event
that mirigation is rec�uired, the mitigation plan shall be designed to replace appropriate lost fimctions and
values. The North Carolina Divisio�l of Mitigation Seivice�s may be available for assistance with stream
mitigation.
Futlu�e documentation, ulcli�ding the 401 Water Ql�ality Certification Application, shall contu7lie to incllide an
itemized listing of tl�e proposed wetland and stream impacts with corresponding mapping.
Tl�e NCDWR is very concerned with sedii��ent and erosion i���pacts that could re�sult from this project. The
NCDOT shall address these concerns by describing the potei�tial impacts that may occur to the aquatic
environments and any mitigating facto�s that would reduce the impacts.
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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

7. An analysis of cumulative and secondary impacts anticipated as a result of this project is required. The type
and detail of ailalysis shall cor11'orm to the NC Division of Wat�er Resource Policy on tl�e assessment of
secondary and cumulative impacts dated April 10, 2004.
8. The NCDOT is respectfully reminded that all impacts, including but not limited to, bridging, till, excavariou
and clearing, and rip rap to jurisdicrional wetlands, streams, and riparian buffers need to be included in the
final impact calculatious. These iu�pacts, in addirion to any conshuction impacts, temporary or otherwise,
also i�eed to be included as part of the 401 Water Quality Certification Applicarion.
9. Wl�ere streams must be crossed, the NCDWR prefers Uridges be used in lieu of culverts. However, we realize
that economic considerations often require the use of culverts. Please be advised that culverts sl�ould be
countersunl< to allow uni�npeded passage by fish and other aquatic organisms. Moreover, in areas where l�igh
quality wetlands or streams are impacted, a Uridge may prove preferable. When applicable, the NCDOT
should not install the bridge be�nts in the creek, to the maximum extent practicable.
10. Whenever possible, the NCDWR prefers spanning structures. Spanning structures usually do not require
worlc within the stream or b Libbing of the streamban]<s and do not require stt-eam cl�annel realib ment The
horizontal and vertical clearauces provided by bridges sllall allow for l�uman and wildlife passage beneatll the
snucture. Fish passage and navigation by canoeists and boaters shall not be blocked. Bridge supports (bents)
should not be placed in the stream when possible.
11. Bridge deck drains shall not discliarge directly into the stream. Stormwater shall be directed across the bridge
and pre-treated througl� site-appropriate means (�rassed swales, pre-formed scour }loles, vegetated buffers, ete.)
before entering the stream. To meet the requirements of NCDOT's NPDES permit NCS000250 please refer to
the most recent version of the North Carolina Departrr�ent of Traras�ortatior� Storrntivater Best Mnnngerr�errt
Praetices Toolbox manual for approved measures.
12. Sediment and erosion control measures sliould not be placed ii� wetlands or sh-eams.
13. Borrow/waste areas should avoid wetlands to the maximum extent practicaL Impacts to wetlands in
borrow/waste areas will need to be presented in the 401 Water Qualiry Certification and could precipitate
compensatory mitigation.
14. The 401 Water Quality Certification application will need to speciflcally address the proposed methods for
stormwater manageinent. More specitically, starmwater shall not be permitted to discharge directly into
streams or surface waters. To meet the requuements of NCDOT's NPDES permit NCS0002�0 , please refer
to the most recent version of the North Carolina Depczrtn�e«t of �Trans�a�tcrtiorz Storrnwcrter� Best Management
Pr•actices Too/l�o.�� mamial for approved measures.
15. Based on the information presented in the document, the magnitude of impacts to wetlands and sh�eams inay
require a Nationwide Per���it application to the Corps of Engineers and corresponding 401 Water Quality
Certification. Please be advised that a 401 Water Quality Ceetification requires satisfactory protection of
water quality to ens�ue that water quality standards are met aud no wetland or sheain uses are lost. Final
pernut authorization will require the submittal of a formal application by the NCDOT and written concurrence
fi•om the NCDWR. Please be aware that any approval will be contingent on appropriate avoidance and
minimization of w�tland and stream impacts to the maximum extent practical, the development of an
accel�table stormwater management plan, and the inclusion of appropriate mitigation plans wl��re appropriate.
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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

16. If concrete is used dliring coi�stnlction, a dry work area shall be �naintained to prevent direct contact between
curinb concrete and streanl water. Water thaY inadvertently contacYs uncured concrete shall not be dischar�ed
to sLirFace waters dlie to the pote��tial for elevated pH and possible aqiiatic life and fish kills. Concrete s11a11
be handled in accordance with the NPDES Constructio�� General Permit NCGO10000.
17. If temporary access roads or detours are constructed, the site shall be b�aded to its preconstruction contours
and elevations. Disturbed areas sllall be seeded or ululcl�ed to stabilize the soil and appropriate native woody
species shall be planted. When using temporary sri•uchires the area sl�all 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 naturaily and minimizes soil disturbance.
18. Unless otherwise autl�orized, placemeut of culverts and other stiuctures in waters and streams shall be placed
below tl�e elevation of the streambed by one foot for all culverts with a diameter greater tl�an 48 incl�es, aud
20 percent of the culvert dian�eter for culverts having a diameter less than 48 i��ches, to allow low flow
passage of water and aquatic life. Design and placement of ciilverts and other structures including tempora�y
erosion control measures shall not be conducte�d in a manner that n�ay result in dis-equilibrium of wetlands or
sneambeds or banlcs, adjacent to or upstream and downstream of the above sh•uctures. The applicant is
required to provide evidence that the equilibrium is being maintained if requested in writing by the NCDWR.
If tliis condition is unable to be met due to bedrock or other limiting feah�res encountered during consti•uction,
please contact the NCDWR for guidance on how to pt-oceed and to detennine whether or not a pennit
modification will be rec�uired.
19. If multiple pipes or barrels are required, they shall be designed to m�imic natural stream cross section as
closely as possiUle including pipes or barrels at flood plain elevation, floodplain benches, and/or sills may be
required where appropriate. Widening tl�e stream channel sllould be avoided. Stream channel widening at the
inlet or outlet end of sh�ctures typically decreases water velocity causing sediment deposition that requires
increased maintenance and disrupts aquatic life passage.
20. If foundation test borings are necessary; it shall be iloted in the document. Geotechnical worlc is approved
under General 401 Certificarion Number 4085/Nationwide Permit No. 6 for Survey Activities.
21. Sediment and erosion conh•ol measures sufficient to protect water resources inust be iinplemented and
maintained in accordance with tl�e most recent version of North Carolina Sediment and Erosion Control
Plaiuiing and Design Manual aud the most recent version of NCS000250.
22. All work in or adjacent to streain waters shall be conducted in a dry work area. Approved BMP measares
fi-om the most clirrent version of the NCDOT Construction and Maintenance Activities inanual such as
sandbags, rocic berms, cofferdams and other diversion struchlres shall be used to prevent excavation in
flowing water.
23. While the use of National Wetland Inventory (NWi) maps, NC Coastal Region Evaluation of Wetlanc�
Significance (NGCREWS) maps and soil survey maps are useful tools, their inherent inaccin-acies require
tl�at qualified personnel perform onsite wetland delineations prior to permit approval.
24. Heavy equipment should be operaYed from the bank rather than in stream channels in order to ininimize
sedim�ntation and reduce the lilcelihood of inh�oducing other pollutants into sh•eams. This equipinent shall be
inspected daily and maintained to prevent contamination of s�u•face waters from leaking fuels, lubricants,
hydraulic fluids, ar other toxic materials.
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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

25. Riprap sl�all not be placed in the active thalweg channel or placed in tl�e streambed in a manner that prechzdes
aquatic life passage. Bioengineering boulders or sn-uctures should be properly designed, sized and installed.
26. Riparian vegetation (native trees and shnibs) shall be preserved to the maximum extent possible. Riparian
vegetation must be reestablished within the consh•uction limits of the project by the end of the growiug season
following completion of consnucrion.
Thanl< you for requesting olir iuput at this time. The NCDOT is reminded that issuance of a 401 Water Quality
Certificatiou requires that appropriate measures be instihited to ensure tl�at water quality standards are �net and
desiguated uses are not degraded or lost. If you have any questions or require additional information, please contact
Rob Ridings at 919-707-8786.
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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