20201594 Ver 1_Scoping Comments BR336 on SR2132 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 336 on SR 2132 (Kinder Road) in Iredell County,
State Project Na 12BP.12.R.79, State Clearingl�ouse Project No. 19-0074.
Reference your con-espondence dated September 26, 2018 in which you requested comments for the referenced
project. Preliminary analysis of the project reveals the poteiitial for nniltiple inlpacts to streams and jurisdictional
wetlands in the project area. More specifically, iinpacts to:
Stream Name River Basin Stream Classifcation(s) Stream Index 303(d) Listing
Numbec
Kinder Geek Yadkin-PeeDee C 12-108-12-1
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 environ���ental issues for the proposed project
Project Specific Comments:
1. Bridge decic drains shall not clischarge directly into the streain. Stormwater shall be directed across the
bridge and pre-treated thro�iffh site-appropriate means (grassed swales, pre-forrned scour holes, vegetated
buffers, etc.) before entering the streain. To meet the reqilirements ofNCDOT's NPDES permit
NCS000250, please refer to the most recent version of tlle North Carolincr Departrnerzt of'Ti�anspoT�tation
Stor•�riwater� Best Mc�nagenzent P��aczices Toolbox 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 the requirements of NCDOT's NPDES pennit NCS000250, the road design plans shall provide
treatmenc 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�spor7ntioy� Stor�rrawater Best Mnnagemerzt Prnctices Toolbax 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�responding mapping. If mitigation is necessary as required by 15A NCAC
2H.0506(h), it is preferable to pt•esent a concepnial (if not finalized) mitigation plan with the environmental
documentation. Appropriate mitigation plans will be required prior to issuance of a 401 Water Qualiry
Certification.
After the selectio�l of the preferred alternative and prior to an issliance of the 401 Water Q�iaLity Certi6cation,
the NCDOT is respectfully reininded that they will need to demonstrate the avoidance and minimizatiotl of
impacts to wetlands (and streams) to tl�e maximum extent praetical. In accordance with the E�lvironmental
Management Commission's Rules (15A NCAC 2H.0506[h]), mitigation will be rec�uu•ed for impacts of
greater tl�an 1 acre to wetlands. I�7 fl�e event that mitigation is required, the mitigation plan si�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 �nitigation plan shall be designed to replace appropriate lost fiinctions and
values. The North Carolina Division of Mitigation Services may be available for assistance with stream
mitigation.
4. Fnture documentation, ulcluding the 401 Water Quality Certification Application, shall continue to inchide an
itemized listing of the proposed wetland aud stream iiupacts with coi�responding inapping.
5. The NCDWR is very concerned with sediment and erosion impacts that could result fi-om this project. The
NCDOT shall address these concerns by describing the potential impacts that rnay occur to the aquatic
environmei�ts and any mitigating factors that would reduce the iir�pacts.
6. The NCDOT is respectfiilly reminded that all impacts, including but not limited to, bridging, fill, excavation
and clearing, and rip rap tojurisdictional wetlands, strelms, �nd riparian buffers need to be included in the
tinal impact calculations. These impacts, in addition to any construction impacts, temporary or ofllerwise,
also need to be included as part of the 401 Water Quality Certification Applicarion.
7. Where streams must be crossed, the NCDWR prefers bridges Ue used in lieu of culverts. However, we realize
tl�at economic considerations often req�ure 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. Wl�ienever possible, the NCDWR prefers spai7ning structures. Spamling structures 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 lluir�an and wildlifE passage beneath tl�e
snucture. Fish passage a�7d navigation by canoeists and boaters sl�all not be blocked. Bridge supports (bents)
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 the maximum 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 p►-oposed metl�ods for
stormwater management. More specitically, stormwater sl�all uot be pennitted to discharge directly into
sn�eams or s�uface waters. To meet the requirements of NCDOT's NPDES l�ennit NCS000250, please refer
to the most recent version of the� North Cnrolina Departme�z! o/'TN����spor-tutioi� Stor�nN�ater Best Mai�agernent
Practices Toolbox n�anual for approved measures.
12. Based on tl�e infoi-mation presented in the docume;nt, the magnihide of impacts to wetlands and st�eams may
rcquirE a Nationwide (NW) application to the Coips of Lngineers and cot��esponding 401 Water Quality
Certification. Please be advised that a 401 Water Qliality Certification requires satisfactory protection of
water quality to ens�u•e that water quality staudards are met and no wetland or stream uses are lost. Fina]
pernut authorization will require the submittal of a formal application by the NCDOT and written concurrence
fi•om the NCDWR. Please be aware fllat any approval wi11 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
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 and possible aquatic life and fish kills. Concrete shall
be handled in accordance with the NPDES Const�uction General Permit NCGOI 0000.
14. If temporary access roads or detours are constructed, the site shall be graded to its preconstruction contotirs
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 srilicriues in w�ters 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. Design and placement of cL�lverts and other structures inchiding temporary
erosion control measures shall not be cond��cYed in a manner that may result in dis-equilibrium of wetlands or
streambeds or ban]<s, adjacent to ar upstream and downstream of Yl�e above structures. The applicant is
required to provide evidence that tl�e equilibrium is being inainYained if req�iested in writin� 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 mult�iple pi�pes or barrels are required, they shall be designed to mimic natural strean� cross section as
closely as possible including pipes or barrels at �I�lood plain elevation, floodplain benel�es, and/or sills �may be
required where appropriate. Widening tl�e streanl channel should be avoided. Sheam cl�annel widening at the
inlet or outlet end of stt�uctures typically decreases water velocity causing sediment deposirion tl�at requires
increased maintenance and disrupts aquaric life passage.
17. If foundation test borings are necessary; it shall be noted in the document. Geotechnical work is approved
�mder General 401 Certificarion Nuinber 40851Nationwide Perinit Na C for Stuvey Acrivities.
18. Sediment and erosion control meas�u•es sufficient to protect water resources inust be impleinented and
maintained in accordance with the most recent version of North Carolina Se�diment ai�d Erosion Control
Plamling and Design Manual and tl�e most recent version of NCS000250.
19. All wark in or adjacent to stream waters sl�all be conclucted in a dry work area. Approved BMP measures
from thE inost c�ul�ent version of the NCDOT Construction and Maintenance Activities manual such as
sai�dbags, rocic bernls, cofferdams and other diversion st�•uctw•Es shall be �ised to prevent excavation in
flowing water.
20. While the use of National Wetland Inventory (NWI) maps, NC Coastal Region Cvaluation of W�tland
Significance (NC-CREWS) �uaps and soil suivey il�aps are useful tools, their inl�erent inaccuracies require
tl�at qualified personnel perform onsite wetland delineations prior to pertnit approval.
21. Heavy 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 into streams. This eq�upment shall be
inspected daily and inaintained to prevent contamination of surface wateis from leaking fuels, lubricants,
hydraulic fluids, or other toxic materials.
22. Riprap shall not be placed in the active thalweg channel or placed in the sn-eambed in a manner that precludes
ac�uatic life passage. Bioengineering boulders or snuchires should be properly designed, sized and installed.
23. Riparian vegetation (native trees and shnibs) shall be preserved to the n�aximum 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.
Tl�ank you for requesting o�ir input at this tiine. The NCDOT is retninded that issuance of a 401 Water Q�iality
Certification requires that �ppropriate measures be instituted to ensure that water quality standards are met and
designated uses are not degraded or lost. If you have a�1y questions or require additional ii�formation, please coi�tact
Doni�a Hood at [phone] or [e-mail].
Electronic copy only distribution:
Nicholle Braspennicicx, US Anny Corps 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