R-5832 Scoping

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October 31, 2018
MEMORANDUM
To: Ran7ie Shaw, NCDOT Division 1 1 Project Manager
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Froni: Dave Wanucha, NC Division of Water Resotn-ces, Winston Salem Regional Offic ��� 10/31/2018
S�ibject: Scopulg comments ou proposed improveii�ents to NC 88 from Smetl�port to Warrensville in Ashe County.
SEPA Project No. 19-0096; Tip Project R-5832.
Reference your correspondence dated October 18, 2018 in wl�icli you requested comments for the refe�renced
project. Preliminary analysis of the project reveals the potential for multiple impacts to streams and jurisdictional
wetlands in the project area. More s�ecifically, impacts to:
Stream Stream Index
Stream Name River Basin 303(d) Listing
Classi�cation(s) Number
Little Buffalo Creek New C; Trout 10-2-20-1 Yes; Benthos
Claybanlc Creek New C; Trout 10-2-20-1-1 No
Buffalo Creek New C; Trout; HQW 10-2-20 No
F��rther investigations at a hiQher resolution should be undertaken to verify the presence of other sri•eams and/or
jtuisdictional wetlands in the area. ln the event that any jurisdictional areas are identified, the Division of Water
Reso�u•ces reqliests that NCDOT consider the following enviromllental issues for the proposed project:
General Project Comments:
Furi�re environmental assessment documents should �rovide a detailed and itemized presentation of the
proposed inlpacts to wetlands and streams witl� corresponding mapping. If mitigation is necessaiy as required
by 15A NCAC 21�.0506(h), it is preferable to present a conceptual (if not iuialized) mitigation plan with the
environmental documentation. Appropriate mitigation plans will be required prior to issuance of a 401 Water
Quality Certification.
All streams within the project area are classi�ie�d as Trout waters of the StaYe. NCDWR recommends that the
most protective sediment and erosion control BMPs be implemented to reduce the risk of turbidity violations
in Trout waters. In addition, all dishubances within trout buffers should be conducted in accordance with NC
Division of Land Resources and NC Wildlife Resources Commission requirements. Post-constniction
stormwater BMPs should be selected and designed to reduce TSS and avoid a sustai��ed increase in the
receivi��g water temp�rature.
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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

Review of the project reveals the presence of siirface waters classified as Hi�h Quality Waters (HQW) of the
State it� the project study arza; one of the highest classifications in the State. NCDWR is extreinely concerned
with any impacts that �nay occur to streams witl� tl�is classification. It is preferred that these resources be
avoided if at all possible. If it is not possible to avoid these resources, the impacts should be miniinized to the
greatest extent possible. Given the potential for impacts to these resources duriilg tl�e project implementation,
NCDWR requests that the NCDOT sh•ictly adhere to North Carolina regulations entitled "Design Standards in
Sensitive Watersheds" (1 SA NCAC 04B .4124) througl�out design and construction of the project.
4. Environmental impact statement alternatives shall consider design criteria that reduce tl�e impacts to sh-eams
and wetlands from storm water nitloff. These alternatives shall inclLide road designs tl�at allow for treatu�ent
of tl�e storm water nmoff through BMPs as detailed in the most recent version of the Nor-th Ccnroli�ia
Depar-tirierzt of'Tr�rnsportatiorr Stor•nTtivater• Best Manager�2e��t Practices Tool box manual, st�cl� as grassed
swales, buffer areas, preformed scour holes, retention basins, ete.
5. In accordance with the Environmental Management Commission's Rules (15A NCAC 2H.OSOC[h]),
mitigation will be required for impacts of greater tl�an 300 linear feet to any perennial sri-eam. I�7 the event
tl�at mirigation is required, the mitigation plan shall be designed to replace appropriate lost functious and
v�lues. The Nortl� Carolina Divisioi� of Mitigation Seivices may be available for assistance with sh-eam
mitigation.
6. FLltl�re documentatioi�, including the 401 Water Quality Certification Application, shall continue to inchide an
itemizecl listing of the proposed wetland and stream impacts with corresponding mapping.
7. The NCDWR is very concerned with sediment and erosion impacts that could result from this project. The
NCDOT shall adciress these concerns by describing Yhe potei�tial impacts that may occur to the ac�uatic
environments and any mitig�ting factors that would reduce the impacts.
8. The NC�DOT is respectfillly ren�inded th�t all impacts, inclL�ding but not liinited to, bridging, fill, excavation
and clEaring, and rip rap to jiu-isdictional wetlands, sneams, and riparian buffe;rs need to be includEd in the
final impact calcl�ilations. These impacts, in �ddition to �ny constniction impacts, t��nporary or otherwise,
also need to be included �s part of the 401 Water Quality Certificaiion Application.
9. Sediment and erosion control measures sho�ilcl not be placed in wetlands or streains.
10. Borrow/waste areas sho�ild avoid wetlands to the maximum extent practical. Impacts to wetlands in
borrow/waste areas will need to be presented ul the 401 Water Quality Certiiication and coulcl precipitate
compensatory mitigation.
11. The 40] Water Qualiry Certificatioi� applicarion will ileed to specihcally address the pro}�osed inethods for
stormwater management. More specifically, stormwater shall not be pern�itted to discharge directly into
sh-eams or surface waters. To meet the requirements of NCDOT's NPDES permit NCS000250, please refer
to the most recent version of the No��th Carolii�a Depcu�tmenl of'Transpo��tcePion Storn��a-ater� Best Mun«genaeflt
Pr•cactices Toolhor manual for approved measures.
12. Basecl on the inforination presented in tl�e document, the magnitude of iin�acts to wetlands and streams inay
require a Nationwide (NW) application to the Corps of Engineers and corresponding 401 Water Quality
Certification. Please be advised that 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
permit authorization will require the submittal of a formal application by the NCDOT and written concun-ence
fi-om the NCDWR. Please be aware that any approval will be contingent on appropriate avoidance and
minimization of wetland and stream impacts to the maximum extent practical, the development of an
acceptable stort�iwater management plan, and the inclusion of appropriate mitigation plans where 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

13. If concrete is us�d during construction, a dry work area shall be iroainiained 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 fisl� kills. Concrete shall
be handled in accordance with tl�e NPDES Consh-uction General Permit NCGO 10000.
14. lf temporary access roads or detours are constructed, the site sl�all be graded to its preconstruction contours
and elevations. Dish�rbed areas shall be seeded or mulched to stabilize tl�e soil and appropriate� native woody
species shall be planted. When using tenlporary structures, the area shall be cleared but not grubbed.
Clearing the area with chain saws, n�owers, bush-hogs, or otl�er mecl�a»ized equipmellt aild leaving the
sh�mps and root mat i»tact allows the area to re-vegetate ilaturally and n�inimizes soil disturbauce.
15. Unless otherwise authorized, placement of culverts and other sh�ctures ii� waters and streams shall be placed
below the elevation of the streambed by one foot for all culverts with a diaimeter greater t11an 48 i�lches, and
20 percent of the culvert diameter for culverts having a diameter less thau 48 inches, to allow low tlow
passage of water and aquatic life. Design a�1d placement of culverts and other structtues including t�m�oraiy
erosion control measures shall not Ue conducted in a manner that inay result in dis-equiliUrimn of wetlands or
sh•eambeds or baillcs, adjaceilt to or upsh-eam aild downstream of tl�e above structures. Tl�e applicant is
required to providE evidence that the equilibrinm is bein� maintaii�ed if rec�uested in writing by tl�e NCDWR.
If tl�is condition is unable to be inet due to bedrock or other limiting feahues encountered dm-ing construction,
please contact the NCDWR for guidance on how to proceed and to determine whether or not a perniit
modification will be required.
16. If multiple pipes or barrels are required, they shall be designed to mimic natural stream cross section as
closely as possible includii�g pipes or barrels at flood pLain eLevatiou, floodplain bei�ches, ai�d/or sills may be
required where appropriate. Wideuin� the stream channel should be avoided. Stream chamlel widenina at tl�e
inlet or outlet end of sn•uct�ires typically decreases water velocity causing sediment de�osirion that req�iires
increased m�intenance and disrupts ac�liatic life passage.
17. If foundation test borings arE necessary; it shal l be noted in the document. Geotechnical work is ap�roved
tmder General 40l Certification Nuinber 4085/Nationwide Permit No. 6 for SLuvey Activities.
18. Sediment and erosion control measures sufficient to protect water resources inust be implemented and
maintained in accordance with the most recent version of North Carolina Sediment and Erosion Control
Planning and Design Manual and the most recent version of NCS000250.
19. All work in or adjacent to stream waters shall be condlicted in a dry work area. Approved BMP ineasures
from the most current version of the NCDOT Construction and Mainten�nce Activities inan�ial such as
sandbags, rocic berms, coffei-dams and other diversion shlichues shall be used to �revent excavation in
flowing water.
20. While the use of Natio��al Wetland Inventory (NWI) maps, NC Coastal Region Evaluation of Wetland
Significance (NGCREWS) maps a��d soil survey n�aps are usefiil tools, their inhere��t inaccuracies reqLiire
that qualified personnel perfonn onsite wetland delineations prior to permit approval.
21. Heavy equipment sl�ould be operated froin the banlc rather than in stream channels in order to minimize
sedimentation and red�ice the likelil�ood of innoducing otl�er pollutants into streams. This equipment shall be
inspected daily and maintained to prevent contamination of siu•face waters from leaking fuels, lubricants,
lrydra��lic fluids, or other toxic materials.
22. Riprap shall not be placed in the active thalweg channel or placed in the streambed in a manner that pr-ecludes
ac�uatic life passage. Bioengineering boulders or stiuch�res should be properly design�d, sized and installed.
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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

23. Riparian vegetation (native trees and shiubs) shall be preseived to the maximum extent possible. Riparian
vegetation �nust be reestablished within the constructiou limits of the project by thz end of the growing season
following completion of constructiou.
Thank you for requesting our inp�it at this time. The NCDOT is reiniilded that issuancE of a 401 Water Quality
Certification requires tl�at appropriate measures be instituted to ensure that water quality standards are met and
designated uses are not degraded or lost If you have any questions or require additional informatioi�i, please coiltact
Dave Wanucha at [phone] or dave.wanucl�a cUncdenr.gov.
Electronic copy only distribution:
Steve Kichefsky, US Ariny Coips of Engineers, Asheville Field Office
Lynn Hardison, NCDEQ, SEPA Coordinator
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