20201585 Ver 1_Scoping Comments BR254 on SR1512 10152018_20181015

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MEMORANDUM
To: Steve Rackley, PE, NCDOT Division 12 Bridge Engineer
Fcom: Donna Hood, NC Division of Water Resources, Mooresville Office
Subject: Scoping comments on proposed improvements to bridge 254 ou SR 1512 (Woodbridge Road) in Iredell
County, State Pi•oject No. 17BP.12.R.78, State Clearingl�olise Project No. 19-0074.
Reference your correspondence received September 26, 2018 in whicl� you requested comments foe the refet-enced
project. Preliminary analysis of the project reveals the pote�ltial for multiple impacts to st��eams and jurisdictional
wetlands in the project area. More specifically, iinpacts to:
Stream Name River Basin Stream Classifcation(s) Stream Index 303(d) Listing
Numbec
Third Creek Yadkin-PeeDee C 12-108-20-4
Further investigations at a higher resolution should be undertaken to verify the presence of other streams and/or
ju�-isdictior�al wetlands in the area. Tn the event tl�at 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. Bridge decic drains shall not clischarge directly into the stream. Stormwater shall be directed across the
bridge and pre-treated thro�iffh site-appropriate means (b assed swales, pre-formed scotiir holes, vegetated
buffers, etc.) before entering the streain. To meet the requireinents ofNCDOT's NPDES permit
NCS000250, please refer to the most recent version of tlle North Carolincr Depart»�zerzt of'Ti�anspoT�tation
Storn�ti��ater� Best Managen�er�t P��aczices Toolbvx manual for approved measures
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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

2. To meet tl�e req�iirements of NCDOT's NPDES perinit NCS000250, the road design plans shall provide
treatment of the stormwater runoff through BMPs as detailed in the most recent version of the Nor•tl�
Car•oli�aa Depar•tn�ei�t of �Trczi�spor7ntio�� Stoi•i���water• Best Managerr�ent Pr�cictices Toolbn.r manual. Tl�e
BMPs should, to tl�e MEP, be selected and designed to reduce impacts of the target pollutants of concern
(POCs) for thE receiving waters.
General Project Comments:
Tl�e enviro�miental docuu7ent should provide a detailed and itemized presentation of the proposed impacts to
wetlands and streams witl� coi�•esponding mapping. If ��nitigation is necessaiy as required by I SA NCAC
2H.0506(h), it is preferable to pt•esent a concepnial (if not finalized) mitigation plan with the enviromnental
documentation. Appropriate mitigation plans will be required prior to issuance of a 401 Water Quality
Certification.
After the selection of the preferred alternative and prior to an issuance of the 401 Water Quality Certification,
the NCDOT is respectfully reininded that they will need to demonstrate tl�e avoidance and minimization of
impacts to wetlands (and streams) to tl�e maximum extent practicaL In accordanee with tl�e Environmental
Management Commission's Rules (15A NCAC 2H.0506[h]), mitigation will be requu•ed for impacts of
greater tl�an I aere to wetlands. I�7 fl�e event that initigation is required, the mitigation plan sl�all be designed
to replace appropriate lost fuuctions and values. Nortl� Carolina Division of Mitigation Services may be
available for assistance with wetland mitigation.
3. In accordance with the Environmental Manageme�nt Commission's Rules (15A NCAC 2H.0506[l�]),
mitigation will be required for impacts of greater than 300 linear feet to any perennial sn-eam. In tl�e event
that mitigation is required, tl�e mitigation plan shall be designed to replace appropriate lost fiinctions and
values. The North Carolina Division of Mitigation Services may Ue available £or assistance with stream
mitigation.
4. Fnture docltmentation, including the 401 Water Quality Certification Application, shall contin��e to include an
itemized listing of the proposed wetland aud stream impacts with corresponding inapping.
5. The NCDWR is very concerned with sediment and erosion impacts that could resu1t from this project. The
NCDOT shall address these concerns by describing the potential impacts that may occur to the aquatic
environmei�ts and any mitigating facto�s that would reduce the impacts.
6. The NCDOT is respectfillly reminded that all impacts, including but not limited to, br-idging, fill, excavation
and clearing, and rip rap tojurisdictional wetlands, streams, and riparian buffers need to be included in the
tinal 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 Applicarion.
7. Where streams must be crossed, the NCDWR prefers bridges be used in lieu of culverts. However, we realize
tl�at economic considerations often require tl�e use of culverts. Please be advised that culverts should be
countersunl< to allow unimpeded passage by fish and other aquatic organisms. Moreover, in areas where high
quality wetlands or streams are impacted, a bridge may prove preferable. When applicable, the NCDOT
should not install the bridge Uents in the creek, to the maximum extent practicaUle.
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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

8. Whenever possible, the NCDWR prefers spanning struchires. Spanning stiucYures usually do not require
worlc within the streain or grubbin� of tl�e streambanlcs aud do not require stream channel realignment. The
horizontal and vertical clearancEs provided by bridges shall allow for huir�an and wildlifE passage beueatl� the
snucture. Fish passage and navigation by canoeists and boatcrs shall not be blocked. Bridge supports (beuts)
should not be placed in the strEam whe�� possible.
Sediinent and erosion conh-ol measures should not be placed ii� wetlands or sh•eams.
10. Borrow/waste areas should avoid wetlands to tlle maxi�num extent practicaL Impacts to wetlands in
borrow/waste areas will need to be presented in tl�e 401 Water Qualiry Certification and could precipitate
compensatory mitigation.
1 L The 40l Water Quality Certification application will need to specifically address the proposed methods for
stormwater management. More specitically, stormwater shall not be pennitted to discharge directly into
sn�eams or s�uface waters. To �neet the requirements of NCDOT's NPDCS �ern�it NCS000250, please refer
to the most recent version of t�he� North Cnrolina Departme�z! o/'TN����sportution Stor�nN�ater Best Mai�agernent
Practices Toolbox n�anual for approved measures.
12. Based on tl�e information presented in the docume;nt, the magnihide of impacts to wetlands and st�eams ulay
rcquirE a Nationwide (NW) application to the Coips of Lngineers and con•esponding 401 Water Quality
Certification. Please be advise�d tl�at a 401 Water Quality Certification requires satisfactory protection of
water quality to ensure that water quality standards are met and no wetland or stream uses are lost. Final
pernut authorization will require the submittal o�f a formal application by the NCDOT and written conctu7•ence
from the NCDWR. Please be aware that any approval will be contingent on appropriate avoidance and
minimization of wetland and streain impacts to flle maximum extent practical, the development of an
acceptable stormwater management plan, and the inchision of appropriate mitigation plans where appropriate.
13. If concrete is used during construction, a d�y work area shall be maintained to prevent direct contact between
cur-ing concrete and stream water. Water that 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 accordance with the NPDES Constiuction General Permit NCGOI 0000.
14. If temporary access roads or detours are constructed, the site shall be graded to its preconstruction contours
and elevations. Disturbed aseas s11a11 be seeded or mulcl�ed to stabilize the soil and appropriate native woody
species shall be planted. When using temporary structures the area shall be cleared but not grubbed. Clearing
tl�e area with chain saws, mowers, bush-hogs, or other mechanized eq�iipment and leaving the stiunps and root
mat intact allows the area to re-vegetate naturally and nliniinizes soil dist��rbance.
15. Unless otherwise authorized, placement of culverts and other srilicriu-es in waters and streams shall be placed
below tl�e elevation of the streainbed by one foot for all culverts with a dia�r�eter greater than 48 inches, ai�d
20 percent of the culvert diameter for culverts having a dia��eter less than 48 inches, to allow low tlow
passage of water and aquatic life. Desigi� and placement of culverts and other structures inchiding temporary
erosion control measures shall not be cond��cYed in a manner that may result in dis-equilibri�un of wetlands or
streambeds or ban]<s, adjacent to ar upstream and downsYream of Yhe above structures. The applicant is
required to provide evidence that tl�e equilibrium is being maintained if requested in writing by the NCDWR.
If this condition is unable to be met d��e to bedrocl< or other limiting features encountered duru�g construction,
please contact tl�c NCDWR for g�iidancc on how to procccd and to deternline whether or not a permit
modification will bc rcquircd.
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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 foundation test borings are necessary; it shall be noted in the document. Geotechnical work is approved
under General 40l CertiCcation Number 4085/Nationwide Permit No. 6 for Suivey Activities.
17. Sediment and erosion control ineasures sufficient to protect water resources must be implemented and
maintained in accordance with tl�e most recent version of North Carolina Se�diment and Erosion Control
Plaivling and Design Manual and the most recent version of NCS000250.
18. All work in or adjacent to stream waters shall be cond�icted in a dry work area. Approved BMP measures
from the most current version of tl�e NCDOT Construction and Maintenance Activities iman�lal such as
sandbags, rock berms, cofferdams and other diversion structures shall be used to prevent excavation in
flowing water.
19. While the use of National Wetland Inventory (NWI) maps, NC Coastal Region Evaluation of Wetland
Significance (NGCREWS) illaps and soil survey inaps are useful tools, their �inher�nt inaccuracies require
that qualified personnel perform onsitE wetland delineations prior to permit approval.
20. Heavy equipment sl�ould bE operated fron� the banlc rather than in sh-ea�n channels in order to minimize
sediinentation and reduce; the likclihood of introducing other pollutants into sn•eams. This equipinent shall be
inspected daily and maintained to prevent contamination of surfacc waters from leaking fi►Els, lubricants,
hydraulic fluids, or other toxic materials.
21. 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 sl�otild be properly designed, sized and installed.
22. Riparian vegetation (native trees and shrubs) shall be preserved to the maximum extent possible. Riparian
vegetation rnust be reestablished within the construction limits of the project by the end of the growing season
following completion of consnuction.
Thank you for requesting our input at this time. The NCDOT is renii��ded that issuance of a 401 Water QL�aliry
Certification requires that appropriate n�easures be instituted to ensure that water quality standards are met and
designated uses are not degraded or lost lf you have any qtiestions or requue additional information, please contact
Donna Hood at [phone] or donna.hood cr�ncdem•.gov.
Electronic copy only distribl►tion:
Nicholle BraspennicicY, US Army Coips of Engineers, Charlotte Field Office
Kristi Lynn Carpenter, NCDWR
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