U-6033 DWR Comments

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Nove�nber 7, 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 ���1/7/2018
S�ibject: Scopulg comments on proposed improve�nents to tl�e intersection of US 64/NC 18 at SR 1142 (Calico
Road) in Caldwell County; Tip Project R-6033.
Reference your correspondence dated October 26, 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
Classification(s) Number
Lower Creelc Catawba WS-IV 11-39-(6.5) Yes; Benthos
Husband Creelc Catawba WS-IV 1 1-39-7-(2) No
Ftu-ther investigations at a higher resolution should Ue undertaken to verify the presence of other streains and/or
jtuisdictional wetlands in flle area. ln the event that any j«risdictional areas are identified, the Division of Water
Resources requests tliat NCDOT consider the following environmental issltes for the proposed project:
General Project Commcnts:
Environmental impact statement alternatives shall consider design criteria that redllce the impacts to streams
and wetlands from storm water runoff. These alternatives shall include road designs that allow for treatment
of the storm water r�moff through BMPs as detailed in the inost recent version of the Nortl� Ccu-olif�a
Departrrren�t o f Trans�ortation Stor•riawatey Best Mnnagerner�t Practices Too7 box manual, such as grassed
swales, buffer areas, preforined scour holes, retention basins, etc.
In accordance with the Environmental Management Commission's Rules (15A NCAC 2H.0506[h]),
mitigation will be rec�uired for impacts of greater than 300 linear feet to any perennial stream. In tl�e event
that mitigation is required, the mitigation plan shall be designed to replace appropriate lost fimctions and
values. The North Carolina Division of Mitigation Services tnay be available for assistance with strea�n
mitigation.
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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

3. Future ei�vironinental assessment docume»ts should provide a detailed ai�d iteimized presentation of the
proposed impacts to wetlands and streams with corresponding mapping. If mitigation is necessary as required
by 15A NCAC 2H.0506(h), it is preferable to present a conceptual (if not fiilalized) mitigatio�� plan with the
environmental documentation. Appropriate mitigation plans will be required prior to issuance of a 401 Water
Quality Certification.
4. The NCDWR is very concerned with sedi�7lent and erosion impacts that could result from this project The
NCDOT shall address these concerns by describing tl�e potential im��acts that may occur to the aquaric
environmeuts aud any i77itigating factors tl�at would reduee the impacts.
5. The NCDOT is re�spectfully reillinded tl�at all impacts, including but not limited to, bridging, fill, e�xcavation
and clearitlg, and rip rap to jurisdictional wetlailds, streams, and riparian buffers need to be included in the
fina] impact calculations. These ii��pacts, in addition to any cotlsriliction impacts, temporaiy or otl�erwise,
also need to be included as part of the 40l Water Quality Certification Application.
6. Sediment and erosion control measures should not be placed in wetlands or streams.
7. Bon-ow/waste areas should avoid wetlands to the maxiinum extent practical. Impacts to wetlands in
borrow/waste areas will nEed to be preseilted in the 40l Water Quality CErtification and could precipitate
compensatory mitigation.
8. The 401 Water Quality Certification application will need to specifically address the proposed methods for
stormwater managen7ent. More specifically, stormwater sha(1 ilot be permitted to discharge directly into
streams or surface waters. To meet the reqL�icements of NCDOT's NPD�S permit NCS000250, please refer
to tl�e ulost recent version of the North Carolirza De�artrr�e�it of �Transportntion Storn�water Best Managenzey�t
Practice,r Toolbox manual for approved measures.
9. Based on the inforn�ation present�d in the document, the magnitude of impacts to wetlands and streains m�y
require a Nationwide (NW) application to tl�e Coips of Engineers and con•esponding 401 Water Quality
Certification. Ple�se be advised th�t a 40l Water Quality Certific�tion requires satisfactory protection of
water quality to ensLire that water quality standards are met and no wetland or stream uses are lost. Final
perilut authorization will require the slibmittal of a formal application by the NCDOT ancl written concurrence
fronl the NCDWR. Please be aware that any approval will be contingent on appropriate avoidance and
minimization of wetland and sTream impacts to the maximunl extent practical, the development of ai�
acceptable stormwater management plan, and the inclusion of appropriate mitibation plans where appropriate.
10. If concrete is used during construetion, a dry work area shall be maintained to prevent direct contact between
curing concrete and strea�r� water. Water that inadvertently contacts uncLired concrete sha11 i�ot be discharged
to surface waters due to the �otential for elevated pH and possible aquatic life a��d fish lcills. Concrete shall
be handled in accordance with the NPDES Consn�ctio�l General Pern�it NCGO10000.
11. If temporary access roads or detours are constructed, the site shall be �-aded to its preconstniction contours
and elevations. Disturbed areas 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 the area witli chain saws, mowers, bush-l�oas, or other mechanized equipment and leaving the
st�mlps and root mat intact allows the area to re-vegetate nat�ually and mininuzes soil disturbance.
12. Unless otherwise a�ithorized, placement of culverts and other structures in waters and streams shall be placed
below the elevation of the streambed 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, to �Ilow low tlow
passage of water and aquatic life. Design and placement ofi culverts and other structLu-es including temporary
erosion control measures shall not be conducted in a manner that may result in dis-equiliUri�un of wetlands or
sri-eambeds or banl<s, adjacent to or upstream and downstream of the above st�l�ctures. The applicant is
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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

required io provide evidence that the equilibrium is being maintained if requested in writing by the NCDWR.
If tl�is condition is unable to be met due to bedrock or other limiting feahu-es encountered during construction,
please contact the NCDWR for guidance on how to proceed and to determine whetl��er or not a permit
modification will be required.
13. lf i�nultiple pipes or ban�els are required, they shall be designed to i��imic natural strea�n cross sectioil as
closely as possiblE including pipes or barrels at flood plain elevation, floodplain benches, and/or sills may be
requirEd where appropriate. Widening the sh-eanl cl�annel should be avoided. Sheain cl�annel widening at the
inlet or outlet end of snti�ctures typically decreases water velocity causing sediment deposition that requires
i»creased mait�tenauce and disiupts aquatic life passage.
14. Sediulent and erosion control n7easures sufficient to protect water resources must be implemented and
maintaiiled 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.
15. All work in or adjacent to stream waters shall be conducted in a dry work area. Approved BMP measures
from t11e inost current versioi� of th� NCDOT ConstrLiction and Maintei�a�lce Activiries manual sucll as
sandUags, rock bernis, cofferdams and other diversion structures shall Ue used to prevent excavation in
flowing water.
16. While the use of National Wetland Inventory (NWI) maps, NC Coastal Regioi7 Evaluatioi� of Wetland
Significance (NC-CREWS) maps and soil survey maps are useful tools, theic inherent inaccuracies require
that qualified personnel perform onsite wetland delineations prior to permit approval.
17. Heavy equipment sl�ould be operated fi•om fl�e bai�lc rather thail in stream channels in order to minimize
sedimEntation and reduce the lil<e;lihood of introducing other pollutants into sn•eams. This equipment shall be
inspected daily and maintained to prevent contamination of stu�facE waters from le�king fuels, lubricants,
hydraulic fluids, or other toxic materials.
18. Riprap shall not be placed in the �ctive thalweg channel or placed in the sh•eambed in � manner that precludes
aquatic life passage. Bioengineering boulders or stiuchires should be properly designed, sized and installed.
19. Riparian vegetation (native trees and shrtil�s) shall be preserved to the maxiinum extent possible. Riparian
vegetation must be reestablished witlun the construction limits of the project by the end of the growing season
following completion of constr�iction.
Thanlc you for requesting o�ir input at this time. The NCDOT is reminded that isstiance of a 401 Water Quality
Certification requires that appropriate measures be instituted to e�lsure that water quality standards are met and
designated uses are not degraded or lost. If you 11ave any questions or require additional information, please contact
Dave Wanucha at [phone] ot- [e-mail].
Electronic copy only distribution:
Steve Kichefslcy, US Ariny Corps of Engineers, Asheville Field Office
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