20211018 Ver 1_I-5972_Scoping_20181009

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October 9, 2018
MEMORANDUM
To: John Williams, P�, Project Manager, RK&K
Prom: Rob Ridings, NC Division of Water Resources, Transportation Permitting Branch
Subject: Scoping comments on proposed NCDOT improvements to interchange of I-95 and Business 70 in
Jollnston County, TIP No. I-5972.
Reference your correspondence dated OctoUer 8, 2018 in which you requested comments for the referenced project.
Preliminary analysis of the project reveals the potential for impacts to streams, tributaries, Uuffers and/or
jurisdictional wetlands in the project area. More specifically, impacts to:
Stream Name River Basin Stream Classifications Stream index 303(d) Listing?
Numbec
UT Polecat Branch Neuse C; NSW 27-46 No
Further investigations at a higher resolutioi� sl�ould bz undertaken to verify the presence of other streams and/or
jm-isdictional wetlands in the area. Tn d�e event tl�at any jurisdicrional areas are identified, the Division of Water
Resoiirces reqiiests that NCDOT consider the following environmental issues for the proposed project:
Project Specific Comments:
1. Polecat Branch and its t�ibtttaries are class C; NSW waters of the State. The NCDWR is very concerned with
sediment and erosion impacts dlat could reslilt fi-om this project. The NCDWR recommends that highly
protective sediment and erosion control BMPs be implemented to reduce the rislc oinutrient runoff to Polecat
Branch. Post-coilsh•uction storinwater BMI's sl�ould, to the MEP, be selected and designed to reduce n�itrients.
This project is within the Neuse River Basi��. Riparian bLlffer impacts shall be avoided and minii��ized to the
greatest extent possible pursuant to 15A NCAC 2B.0233. New develo}�ment activities located in the protected
50-foot wide riparian areas within tl�e basin shall be limited to "uses" identified withiil ai�d constnicted in
accordai�ce with 15A NCAC .02B .0295. Buffer mitigation may be required for bLiffer impacts resultii�g from
activities classified as "allowable with mitigation" within the "Tab'le of Uses" section of tlle Buffer Rules or
require a variance under the Buffer Rules. A buffer mitigation plan, including use of tl�e North Carolina
Division of MitigaYion Services, must be provided to tl�e NCDWR prior to approval of the Water Quality
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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

Certification. Buffer mitigation ir�ay be required for buffier impacts resulting fi-om activities classified as
"allowable with nlitigation" within the "Table of Uses" section o�f the Buffer Rules or require a variai�ce under
the Buffer Rules. A buffer mitigation plan, coordinated with the North Carolina Division of Mitigation Seivices,
must be provided to the NCDWR prior to approval of the Water Qual�ity Certification.
General Project Comments:
The environmental document sl�ould provide a detailed and iteinizEd presentatioi� of the proposed impacts to
wetlands and sh•eams witl� coiT�sponding mapping. If mitigation is necessary as required by 15A NCAC
2H.0506(h), it is �n-eferablE to presei�t a conceptual (if not finalized) n�itigation plan with the environn�ental
documentarion. Appropriate initigation pla�ls will be required prior to issuance of a 401 Water Quality
Certification.
Enviromnental impact statement alternatives shall consider desibn criteria that reduce the impacts to streams
and wetlands fron� storm water runoff. These alternatives shall iuclude road designs that allow for treatment
of the stor�n water nirloff through BMPs as detailed in tt�e most recent version of the Nor�t12 Carolina
De�U�� trnent of �Tr•anspo�•tatiori Stor•n�ativater• Best ManUgeirTei�t Practices Tool box manttal, sttch as grassed
swales, buffer areas, preformed scour lloles, retei�tion basins, etc.
After the selection of the preferred alternative and piior to an issuance of the 401 Water Quality Certification,
tl�e NCDOT is respectfully reminded that they will need to deil�onstrate the avoidance and minimization of
impacts to wetlands (and streams) to thF �1�aximum extent practical. In accordance with the Environmental
Management Comil�ission's Rules (15A NCAC 2H.0506[h]), mitigation will be rec�uired for impacts of
greater than 1 acre to wetlands. In tl�e event that n�itigation is required, the imitigatioi� plan shall be desib �ed
to replace appropriate lost functioils and values. North Carolina Division of Mitigation Seivices may be
available for assistauce witl� wetla»d mitigation.
4. l�i accordance witl� the Envu•onmental Management Con�ussion's Rules (15A NCAC 2H.0506[h]),
mitigation will be required for impacts of greater than 3001inear feet to any perennial streani. ln the event
tl�at mitigation is reqllired, the mitigation plan shall be designed to replace appropriate lost functions and
values. The North Carolina Division of Mitigation Services may be available for assistance with streai��
mitigation.
5. Future documentation, includiilg the 401 Water Quality Certification Ap�lication, sl�all continue to include an
itemized listin; of the proposed wetland and sh-eam impacts wid� corresponding mapping.
6. The NCDWR is very concerned with sediiuent and erosion impacts that could result fi•om this project. The
NCDOT shall address these concerns by describing the potential impacts tl�at may occur to the aquatic
enviromnents and any mitigating factors that would reduce tlie iinpacts.
7. An analysis of cumulative and secondary impacts anticipated as a result of this project is required. The type
and detail of analysis shall confortn 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 reminded that all iinpacts, includii�g but ��ot limited to, bridging, fill, excavation
and clearing, and rip rap to jurisdictional wetlands, streams, and riparian buffers need to be included in the
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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

final impact calculations. These impacts, in additio�� to any consh-uction impacts, temporary or otllerwise,
also need to be included as part of the 401 Water Q�ia'lity Certif cation Application.
Where st�•eams must be crossed, the NCDWR prefers bridges be Lised in lieu of culverts. However, we realize
tl�at econoimic coi�siderations often require the use of culverts. Please be advised that culverts should be
couute�sunl< to allow unimpeded passage by fish and other aquatic organisms. Moreover, in areas where high
qLiality wetlands or sh•eams are impacted, a bridge tnay prove preferable. When applicable, tl�e NCDOT
should not install the bridge bents in the creek, to the maxiiuum extent practicable.
10. Whenever possible, the NCDWR prefers spanning struchires. Spanning structures usually do not require
worlc within the streain or grubbing of tl�e streambanks and do ��ot require sTream cllannel realigilme��t. The
horizontal and vertical clearances provided Uy bridges shall allow for human and wildlife passage beneath the
structure. Fish passage and navigation by canoeists and boaters s11a11 not be blocked. Bridge supports (bents)
should not be placed in the stream wheu possible.
11. Bridge deck clrains s11a11 not discharge directly into the stream. Stormwater shall be directed across the bridge
aud pre-n•eated tl�rough site-a�ppropriate meai�s (grassed swales, pre-formed scour holes, vegetated buffers, etc.)
before entering tl�e stream. To tneet the requirements of NCDOT's NPDES pernlit NCS000250, please refer
to the most recent version of the Nor-tJ� Caroliy�a Departr���er�t of Trara,sportation Storrrnvater• Best Mar�agen�e��t
Pr•aetices Toolbox inanual for approved measures.
12. Sediment and erosion control measures should not be placed in wetlands or streaius.
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 Qliality Certification and could precipitate
compensatory mitigation.
14. The 40] Water Qualiry Certification application will need to specifically address the proposed methods for
stormwater management. More specifically, stormwater shall not be pe�7��itted to discharge directly into
sh-eams or sw-face waters. To meet the requirements of NCDOT's NPDES l�ermit NCS000250 [delete if'
non-DOT project], please refer to the most recent version of the Nor•th Carolina Depurtrne��t of �
Ti•nnsportntion Stor•n�itivater Best Managerriei�t Practrces ToolFiox manaal for approved measttres.
15. Based on the information presented in the doc�tment, the magnitude of impacts to wetlands and streams may
require an Nationwide Permit application to the Coips of Engineers and corresponding 401 Water Quality
Certiiication. Please be advised that a 401 Water Quality Certification requues s�tisfactory protection of
water quality to ens�ue that water quality standards are met and no wetland or stream �ises are lost. Final
pen��it authoi-izatioi� will require the submittal of a formal applicatioil by the NCDOT and written concurrence
from the NCDWR. Please be aware that any approval will be contingent on appropriate avoidance and
minir��ization of wetland and stream impacts to the nlaximum extent practica1, the development of an
acceptable stormwater management plan, and the inchision of appropriate mitigation �lans where appropriate.
16. lf concrete is used during construction, a dry work area shall be maintained to prevent direct contact between
curing concrete and stream water. Water tl�at inadvertently contacts uncured concrete shall not be discharged
to surface waters due to the potential for elevated pH and possible aquatic life and fish kills. Concrete shall
be handled in accordauce witl� the NPDES Construction General Permit NCGO10000.
17. If temporary access roads or deto�u•s are constructed, tl�e site shall be gradecl 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 tempoc•a�y structures the area shall be cleared but not grubbed. Clearing
the area with chain saws, mowers, bush-ho�s, or other mechanized equipment and leaving the stumps and root
mat intact allows the area to re-vegetate ��ahu•ally and tninimizes soil distw�bance.
18. Unless otherwise authorized, placement of culverts and other sh�uch�res in waters and strearns shall be placed
below the elevation of the sh-eainbed by one foot for all culverts with a diameter greater tl�an 48 inches, and
20 percent of the culvert diameter for culverts having a diameter less than 48 inclles, to allow low flow
passage of water and aquaric life. Design and placement of culverts and other sh�uctures including temporary
erosion control measures shall not Ue conducted in a manner that may result in dis-equilibrium of wetlands or
streambeds or banl<s, adjacent to or upstrealn and downstream of tl�e above structures. The applicant is
required to provide evidence that the equilibrium is being maintained if requested in writing by the NCDWR.
If tl�is conditioil is unable to be ulet due to bedroek or other IimiCi��g feahu-es encountered during construction,
please contact tl�e NCDWR for guidance on how to proceed and to determine whether or not a permit
modification will be required.
19. If multiple pipes or banels are required, they shall be designe�d to mimic nahiral sh•eam cross section as
closely as possible inchiding pipes or barrels at flood plain elevation, floodplain bencl�es, and/or sills may be
required where appropriate. Widening tl�e sn-eam channel should be avoided. Shearn channel wideiling at the
inlet or outlet end of stnictLu-es typically decreases water velociry causing sediment deposition that requires
increased maintenance and disrupts aquaric life passage.
20. If foundation test borings are necessary; it sl�all be noted in the document. Geoteclu�ical woi•k is approved
tznder Geueral 401 Certification Nnmber 4085/Nationwide Permit No. 6 for Sutvey Activities.
21. 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 Conh�ol
Planning and Design Manual and the most recent versiou of NCS000250.
22. All work in or adjacent to stream waters shall be conducted in a dry work area. Approved BMP measures
from the most cw7�ent version of the NCDOT Construction and Maintenance Activities manu�l such as
sandbags, rock berms, cofferdams and other diversion stt-uctures shall be used to prevent excavation in
flowing water.
23. While the use of National Wetland lnventory (NWl) maps, NC Coastal Region Evahiation of Wetland
Signif7cance (NC-CREWS) inaps and soil s�uvey maps are �isefiil tools, their inherent inacc«racies reqtiire
that qualified personnel perfoi7n onsite wetland delineations prior to permit approval.
24. Heavy equipment should be operated fro�1� the banl< rather than in sn-eam channels in order to minimize
sedimentatioi� and reduce the likelihood of i��troducing other pollutants into streams. This equipi��ent shall be
inspected daily and maii�tained to prevent contamination of surface waters from le�l<ing fiiels, lubricants,
hydraulic fluids, or other toxic materials.
25. Riprap shall not be placed in the active thalweg channel or placed in the st�eainbed in a manner that precludes
aquatic life passage. Bioengineering boulders or structures should be properly designed, sized and installed.
26. Riparian vegetation (native trees and shr�ibs) shall be preserved to the maximum extent possible. Riparia�n
vegetation must be reestablished witlun the construction limits of the project by the end of the growing season
following completion of construction.
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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

Tllanlc you for requesting o�u� input at this time. The NCDOT is renlinded tl�at issuance of a 401 Water Quality
Certification requires tl�at appropriate measures be instihited to ensure that water quality standards are met and
designated uses are not degraded or lost If you have any questions or require additional infonnation, 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