U-4403 SOS October 2018

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MICI IAEL S. REGAN
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October 16,2018
MEMOItANUUM
To: Craig Freeman, NCDOT Projec[ Management Team
From: Joanne Steenhuis, NC Division of Water Resources, Wilmingron Regional Office
Subject Scoping comments on proposed 'unprovements [o Ramsey Street from NC 24/Grove Stree[ to 2.3 miles
north of I-295 north of Slocomb Road in Cumberland County, STIP U-4403.
Reference your corcespondence dated October 4, 2018 in which you requested comments for the referenced project.
Preliminary analysis of the project reveals the po[en[ial for multiple impac[s [o streams and jurisdictional wetlands
in the project area. More specifically, impacts ro:
Stream Name River Basin Stream Classification(s) Stream Index 303(d) Listing
Number
E3i Cross Creek Ca e Fear C 18-27- 3 No
McPherson Creek Ca e Fear WS-IV,B IS-24-3- 2 No
Greens Creek Cape Fear WS-IV,B 18-24-3-3 No
Holmes Pond
Carvers Creek Cape Fear WS-IV,B I 5-24 No
C ress Lake
Eurther inves[igations at a higher resolution should be undertaken to verify the presence of other slreams and/or
jurisdictional wetlands in the area. In the event that anyjurisdictional areas are identified, the Division of Water
Resources requests that NCDOT consider the following environmental issues for [he proposed projec[:
Project Specific Comments:
I. "Co meet the requu�ements of NCDO'I"s NPD6S permi[ NCS000250, die road design plans shall provide
heatment of the stormwater rmioff through BMPs as detailed in the most recent version of the Na4h Cnrolinn
Uepru��ment q/�Ti�nnspa�tniion Stavnrntei� l3es! Ma�vugei�ie�a! f'rne�icea• 7'oolbos manual. "I'he BMPs should, to
the MEP, be selected and designed [o reduce impacts of the target pollutants of concem (POCs) for [he
receiving waters.
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North Carollna DeUartment of Environmenlal Qualiry I Drvlsion of Watei Resomces
512 Noilh Salisbury Stree� I 1677 Matl Servlr,e Ceirtei I Raleigh, North Carolinn 27699 16'll
919.707 9000

General Project Comments:
1. The env'vonmental document should provide a detailed and itemized presentation of the proposed impacts to
wetlands and streams with corzesponding mapping. 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 envirorunental
dowmentation. Appropriate mitigation plans witl be required prior to issuance of a 401 Water Qualiry
Certification.
2. Environmental impact statement altematives shall consider design criteria that reduce the impacts to streams
and wetlands �om storm water runoff. These altematives shall include road designs that allow for treahnent
of the storm water runoff througlt BMPs as detailed in the most recent version of the North Carolina
Department ofTransportatron Stormwater Best Management Practices Tool box manual, such as grassed
swales, buffer azeas, preformed scour holes, retention 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 streams) to the maximum extent practical. In accordance with the Environmental
Management Commission's Rules (15A NCAC 2H.0506[h]), mitigation will be requ'ved for impacts of
greater than 1 acre to wetlanda In the event that mitigation is required, the mitigation plan shall be designed
to replace appropriate lost functions and values. North Cazolina Division of Mitigation Services may be
available for assistance with wetland mitigation.
4. In accordance with the Environmental Management Commission's Rules (ISA NCAC 2H.0506[h]),
mitigation will be required for impacts of greater than 3001inear feet to any perennial stream. In the event
[hat 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 available for assistance with sheam
mitigation.
5. Future documentation, including the 401 Water Quality Certification Application, shall continue to include an
itemized listing of the proposed wetland and stream impacts with corresponding mapping.
6. The NCDWR is very concerned with sediment and erosion impacts that could result from this project. The
NCDOT shall address these concerns by describing the potential impacts that may occur to the aquatic
environments and any mitigating factors that would reduce the impacts.
7. 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 Policy on the 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, fill, excavation
and clearing, and rip rap to jurisdictional wetlands, streams, and riparian buffers need ro be included in the
final impact calculations. These impacts, in addition to any construction impacts, temporary or otherwise,
also need to be included as part of the 401 Water Quality Certification Application.
9. Where streams must be crossed, the NCDWR prefers bridges be used in lieu of culverts. However, we realize
that economic considerations often requ've the use of culver[s. Please be advised that culverts should be
countersunk to allow unimpeded passage by fish and other aquatic organisms. Moreover, in areas where high
North Carolina Department of Environmental Quality � Division of Water Resources
512 North Salisbury Street I 1617 Mail ServiCe Center � Raleigh, North Carolina 276991617
919.707.9000

quality wetlands or sheams are impacted, a bridge may prove preferable. When applicable, the NCDOT
should not install the bridge bents in the creek, to the maximum extent practicable.
10. Whenever possible, the NCD WR prefers spanning structures. Spanning structures usually do not require
work within the stream or grubbing of the streambanks and do not require sheam channel realignment. The
horizontal and vertical clearances provided by bridges shall allow for human and wildlife passage beneath the
shucture. Fish passage and navigation by canoeists and boaters shall not be blocked. Bridge supports (bents)
should not be placed in the stream when possible.
1 l. Bridge deck drains shall not discharge directly into the sheam. Stormwater shall be directed across the bridge
and pre-treated through site-appropriate means (grassed swales, pre-formed scour holes, vegetated buffers, etc J
before entering the stream. To meet the requ'vements of NCDOT's NPDES permit NCS000250, please refer
to the most recent version of the North Caro[ina Department of Transportation Stormwater Best Management
Practrces Toolbox manual for approved measures.
12. Sediment and erosion control measures should not be placed in wetlands or sheams.
13. Borrow/waste azeas should avoid wetlands to the maacimum extent practical. Impacts to wetlands in
borrow/waste azeas will need to be presented in the 401 Water Quality Certification and could precipitate
compensatory mitigation.
14. The 401 Water Quality Certification application will need to specifically address the proposed methods for
stormwater management. More specifically, stormwater shall not be permitted to dischazge directly into
streams or surface waters. To meet the requirements of NCDOT's NPDES permit NCS000250, please refer
to the most recent version of the North Carolrna Deparhnent of Transportation Smrmwater Best Management
Practices Toolbox manual for approved measures.
15. The DWR cannot comment on permit requ'vements with the lunited information provided. Detailed field
delineation is requ'ved to determine the presence or absence ofjurisdictional resources within the project
limits. In addition, NCDOT must provide an estimate to any resources bcated within the construction limits
of the project azea before we can specifically comment on NCDWR permit eligibility. Final permit
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
minimization of wetland and sfream impacts to the maximum extent practical, the development of an
acceptable stormwater management plan, and the inclusion oFappropriate mitigation plans where appropriate.
16. If concrete is used during construction, a dry work azea shall be maintained to prevent direct contact between
curing concrete and stream watec Water that inadver[ently 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 accordance with the NPDES Construction General Permit NCGO10000.
l7. If temporary access roads or detours aze conshucted, the site shall be graded to its preconshuction contours
and elevations. Disturbed azeas shall be seeded or mulched to stabilize [he soil and appropriate native woody
species shali be planted. When using temporary structures the area shall be cleared but not grubbed. Clearing
the azea 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 dis[urbance.
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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 2 7 699 1617
919.707.9000

l8. Unless otherwise authorized, placement of culverts and other structures in waters and streams shall be placed
below the elevation of the sheambed 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, ro allow low flow
passage of water and aquatic life. Design and placement of culverts and other structures including temporary
erosion control measures shall not be conducted in a manner that may result in dis-equilibrium 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 iFrequested in writing by the NCDWR.
If this condition is unable to be met due to bedrock or other limiting features encountered during conshuction,
please contact the NCDWR for guidance on how to proceed and to determine whether or not a permit
modification will be requ'ved.
l9. If multiple pipes or barrels are required, they shall be designed to mimic natural s[ream cross section as
closely as possible including pipes or barrels at flood plain elevation, floodplain benches, and/or sills may be
required where appropriate. Widening the sheam charmel should be avoided. Stream charmel widening at the
inlet or ouUet end of structures 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 noted in the document. Geotechnical work is approved
under General 401 Cer[ification Number 4085/Nationwide Permit No. 6 for Survey Activities.
21. Sediment and erosion conhol measures suf�'icient to protect water resources must be implemented and
maintained in accordance with the most recent version oFNorth Cazolina Sediment and Erosion Conuol
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 work area. Approved BMP measures
&om the most current version of the NCDOT Conshvction and Maintenance Activities manual such as
sandbags, rock berms, cofferdams and other diversion shvctures shall be used to prevent excavation in
flowing water.
23. While the use of National Wetland Inventory (N WI) maps, NC Coastal Region Evaluation of Wetland
Significance (NGCREWS) maps and soil survey maps are useful tools, their inherent inaccuracies require
that qualified personnel perform onsite wetland delineations prior to permit approval.
24. Heary equipment should be operated from the bank rather than in stream channels in order to minimize
sedimentation and reduce the likelihood of introducing other pollutants inro sheams. This equipment shall be
inspected daily and maintained to prevent contamination of surface waters from leaking fuels, lubricants,
hydraulic fluids, or other toxic materials.
25. 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 properiy designed, sized and installed.
26. Riparian vegetation (native trees and shrubs) shall be preserved to the maximum extent possible. Riparian
vegetation must be reestablished within the construction limits of the project by the end of the growing season
Following completion of construction.
North Carolina Department of Environmental Qualiry � Division of Water Resources
512 North Salisbury Street � 1617 Mail Service Center � Raleigh, North Carolina 27699d617
sis.�o�.s000

Thank you for requesting our input at this time. The NCDOT is reminded that issuance of a 401 Water Quality
Certification requires that appropria[e measures be instituted to ensure that water quality standards aze met and
designated uses are not degraded or lost. If you have any questions or require additional information, please contact
Joanne S[eenhuis at [phone] [e-mail].
Elechonic copy only dishibution:
John Williams, PE, RK&K
Jim Rerko, Division 3 DEO
Liz Hair, US Army Corps of Engineers, Wilmington Field Office
Kristi Lynn Carpenter, NCDWR
File Copy
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North Carolina Department of Environmental QualiTy � Division of Water Resources
512 North Salisbury S[reet � 1617 Mail Service Center � Raleigh, North Carolina 27699-1617
919.707.9000