20201515_R-2561 scoping comments_20180928

Carpenter,Kristi
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Steenhuis, Joanne
Friday, September 28, 2018 5:26 PM
Hackler, Nicole M; Rerko, James J; Hair, Sarah E SAW ([e-mail]);
Carpenter,Kristi
R-2561 scoping comments
R-2561.pdf
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Environmental Senior Specialist
Transportation Permitting Branch
Department of Environmental Quality
(910) 796�7306 (office)
(910) 30��4021 (rnobile)
[e-mail]
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September 28, 2018
MEMORANDUM _
Ta: Nicole M. Hackler, PE, Project Manager, NGDOT Project Management Unit
From: loanne Steenhuis, NC Division of Water Resources, Wilmington Regional Officc�--�►�� ( �
Subject: Scoping comments on proposed roadway improvements to NC 87 from Elizabethtown Bypass to US 74-
76 in Bladen and Columbus Counties, STIP R-2561.
Reference your correspondence dated September 25, 2018 in which you requested comments for the referenced
project. Preliminary analysis of the project reveals the potential for multiple impacts to streams and jurisdictional
wetlands in the project area. More speciiically, impacts to:
Stream Name
Broad Branch
UT to Broad Branch
UT to Hammond Creek
� Hammond Creek
!UT to Whites Cr�k
Cameron Branch
Whites Creek
Drunken Run � �1orth)
Donoho Creek
Carvers Creek
Plummers Run
Steep Run_
UT to Beaverdam Creek
Wevman Creek
Double Branch
UT to Pret t v Creek
_ Livin�ston Creek
Lindscomb Branch
UT to Lindscomb Branch
iJT to Turner Branch _
L1T to HaD Branch
River Basin
Ca�e Fear
Cape Fear
Cape Fear
Ca ep Fear
Ca �e� Fear
Ca��e Fear
Ca�re Fear
Ca��e Fear
Ca�e Fear
Ca�Fear
C��c Fear
Ca�c Fear
Ca�e Fear
Ca�re Fear
Ca�4 Fear
Ca�,e Fear
Ca�e Fear
Cape Fear
Ca��e Fear
Ca�e Fear
Caoc� Fear
Stream
C
e
C
C
C
C
C
C
WS-N
ws-iv
ws-rv
WS-IV
WS-IV; Sw
WS-IV,Sw
WS-IV; Sw
C; Sw
C; Sw
WS-IV;'
C; Sw
Stream Index
Number �
1&50-4
1s-saa
18-50
1&50
18-50-5
1&50-5-1
18-50-5
18-53�
1$-54
�1&5b-(.0.7j
�g-s�
18-58�
18-61-4
1&-61
18-62
1&64-13
18-64
1&64-14
_ 1&64-14
18-61-3
18-64-9
�!� ���
. .�
303(d) Listing
c N!A
N/A
N!A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N!A
NfA
N/A
N/A
T N/A
� N/A
N/A
N/A
` N/A �
N/A
North Carolina Department of Environmental Quality � Division of Water Resources
512 North Salisbury Street � 1617 Mail Service Center � Raleigh, North Carolina 27699-1617
919.707.9000

Further investigations at a higher resolution should be undertaken to verify the presence of other streams and/or
jurisdictional wetlands in the azea. In tlie event that any jurisdicrional areas are identified, the Division of Water
Resources requests that NCD�T consider the following environmental issues for the proposed project:
Project Specific Comments:
Ta meet the requirements of NCDOT's NPDES permit NCS000250, the road design plans shall provide
treatment of the stormwater runoff through BMPs as detailed in the most recent version of the North Carolina
Department of Transportation Stormwater Best Management Practices Toolbox manual. The BMPs should, to
the MEP, be selected and designed to reduce impacts of the target pollutants of concern (POCs) for the
receiving waters.
Gener�l Project Comments:
2. The environmental document should provide a detailed and itemized presentatian of the proposed impacts to
wetlands and streams with corresponding mappina. If mitigation is necessary as required by 15A NCAC
2H.0506(h}, it is preferable to present a conceptuai (if not finalized} mirigation plan with the environmental
documentarion. Appropriate mirigation plans will be required prior to issuance of a 401 Water Quality
Certification.
Environmental impact statement alternatives shall consider design criteria that reduce the impacts to streams
and wetlands from storm water runoff. These alternatives shall include road designs that allow for treatment of
the storm water runoff through BMPs as detailed in the most recent version of the North Carolina Department
of Transportation Stormwater Best Management Practices Tool box manual, such as grassed swales, buffer
areas, preformed scour holes, retention basins, etc.
4. After the selection of the preferred altemarive and prior to an issuance of the 401 Water Quality Certification,
the AICDOT 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 Comraission's Rules {15A NCAC 2H.0506[h]), mitigation will be required for impacts of
greater than 1 acre to wetlands. In the event that mitigation is required, the mitigatidn plan shall be designed
to replace appropriate lost functions and valnes. North Carolina Division of Mitigation Services may be
available for assistance with wetland mitigation.
5. In accordance with the Environmental Management Commission's Rules (15A NCAC 2H.0506[h]),
mitigation will be required for impacts of greater than 300 lineaz feet to any perennial stream. In the event
that mitiga.tion is required, the mitigation plan shall be designed to replace agpropriate lost functions and
values. The North Carolina Division of Mitigarion Services may be available for assistance with stream
mitigation.
6. 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.
7. The NCDWR is very concerned with sediment and erosion impacts that could result from this project. The
NCDOT shall address these concerns by descn`bing the potential impacts that may occur to the aquatic
environments and any mitigating factors that would reduce the impa�ts.
512 North Safisbury Street � 161�r :arolina 27699-1617
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8. 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 Divisian of Water Resource Policy on the assessment of
secondary and cumulative impacts dated April 10, 2004.
9. The NCDOT is respectFully reminded that all impacts, including but not limited to, bridging, fill, excavarion
and clearing, and rip rap to jurisdicrional wetlands, streams, and riparian buffers need to be included in the
final impact calculations. T'hese impacts, in addition to any construction impacts, temporary or otherwise,
also need to be included as part of the 401 Water Quality Certification Application.
10. Where streams must be crossed, the NCDWR prefers bridges be used in lieu of culverts. However, we realize
that economic considerations oi3en require the use of culverts. Please be advised that culverts should be
countersunk to allaw unimpeded passage by fish and other aquatic organisms. Moreover, in areas where high
qaality wetlands or streams are impacted, a bridge may prove preferable. When applicable, the NCDOT
should not install the bridge bents in tlie creel�, to the maximum extent practicable.
11. Whenever possible, the NCDWR prefers spanning structures. Spanning struciures usually do not require
work within the stream or grubbing of the streambanks and do not require stream channel realignmen� The
horizontal and vertical clearances provided by bridges shall allow for human and wildlife passage beneath the
structure. Fish passage and navigation by canoeists and bnaters sha11 not be blocked. Bridge supports (bents)
should not be placed in the stream when possible.
12. Bridge deck drains shall not discharge directly into the stream. Stormwater shall be directed across the bridge
and pre-treated through site-appropriate means (grassed swales, pre-formed scour holes, vegetated buffers, etc.)
before entering the stream. To meet the requirements of NCDOT's NPDES permit NCSOOU250, please refer
to the most recent version of the North Carolina Department of Transportation Stormwater Best Managemeni
Practices 1"'oolbox manual for approved measures.
13. Sediment and erosion control measures should not be piaced in wetlands or streams.
I4. Borrow/waste areas should avoid wetlands to the maximum eatent practical_ Impacts to wetlands in
borrow/waste areas will need to be presented in the 401 Water Quality CeRification and could precipitate
compensatory mitigation.
15. The 401 Water Quality Certification application will need to specifically address the proposed methods for
stormwater management. More specifically, stormwater shall nat be permitted to discharge directly into
streams or surface waters. To meet the requirements of NCDOT's NPDES permit NC5000250, please refer
to the most recent version of the North Carolina Departme�at of 7'ransportaTion Stormwater Best Management
Practices Toolboz� manual for approved measures.
16. The DWR cannot comment on pemut requirements with the limited information provided. De#ailed field
delineatian is required to determine the presence or absence of jurisdictional resources within the project
limits. In addition, NCDOT must provide an estimate to any resources located within the construcrion limits
of the project area before we can specifically comment on NCD WR permit eligibility. Final permit
authoriza�ion 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
minimi7ation of wetland and stream impacts to tha maximum extent pracrical, the development of an
acceptable stormwater management plan, and the inclusion of appropriate mitigarion plans where appropriate.
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512 North Salisbury Street � 1617 Mail Sei i, North Carolina 27699-161?
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17. If concrete is used during construction, a dry work area shall be maintained t4 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 aquaric life and fish kills. Concrete shall
be handled in accordance with the NPDES Construction General Permit NCGO10000.
18, If temporary access roads or detours are constructed, the site shall be graded to its preconstruction contours
and elevations. Disturbed areas shall be seeded or mulched to stabilize the soil and appropriate native woody
species shall be planted. When usutg temporary structures the area shall be cleared but not grubbed. Clearing
the area 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 disturbance.
19. Unless otherwise authorized, placement of culverts and other structures in waters and streams shall be placed
below the elevation of the streambed by one foot fm all culverts with a diameter greater than 48 inches, and
20 percent of the culvert diameter far culverts having a diameter less than 48 inches, to allow low flow
passage of water and aquati� life_ Design and plaeement 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 if requested in writing by the NCDWR.
If this condition is unable to be met due to bedrock or other limiting features encountered during construction,
please contact the NCDWR for guidance on how to proceed and to determine whether or noi a petmit
modification will be required.
20. If multiple pipes or barrels are required, they shali be designed to mimic natural stream 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 streaua channel should be avoided. Stream channel widening at the
inlet or outlet end of structures typically decreases water velociry causing sediment deposition that requires
increased maintenance and disrupts aquatic life passage.
21. If foundarion test borings are necessary; it shall be noted in the document. Geotechnical work is approved
under General 401 Certification Number 4085/Nationwide Permit No. 6 for Survey Acrivities.
22. Sediment and erosion control measures sufficient to protect water resources must 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.
23. All work in or adjacent to stream waters shail be conducted in a dry work area. Approved BMP measures
from the most current version of the NCDOT Construction and Maintenance Activities manual such as
sandbags, rock berms, cofferdams and other diversion structures shall be used to prevent excavation in
flowing water.
24. While the use of Narional Wetland Inventory (N Wn maps, NC Coastal Region Evaluation of Wetland
Significance (NGCREWS) maps and soil survey maps are useful tools, their inhereat inaccuracies require
that qualified personnel perform onsite wetland delinearions prior to permit approval.
25. Heavy equipment should be operated from the bank rather than in stream channels in order to minimize
sedimentation aad reduce the likelihood of introducing other pollutants into streams. This equipment shall be
inspected daily and maintained to prevent contamination of surface waters from leaking fuels, lubricants,
hydraulic fluids, or other toxic materials.
512 North ,__. . _ _,. ... _
5a6sbury Str�et � 1617 Mail Se ;�, North Carolina 27699-1617
919.7�; .':,w��

26. 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 properly designed, sized and installed.
27. Riparian vegetation {native trees and shrubs) shall be preserved to the maximum e�ent possible. Riparian
vegetation must be reestablished within the construcrion limits of the project by the end of the grawing season
following completion of construction.
Thank you for requesting our input at this time. The NCDOT is reminded that issuance of a 401 Waier Quality
Ceriification requires that appropriate measures be insrituted to ensure that water quality standards are met and
designated uses aze not de�raded or lost. If you have any questions or require additional information, please contact
Joanne Steenhuis at [phone] or [e-mail].
Electronic copy only distriburion:
Jim Rerko, NC DOT Division 6 Division Environmental Officer
Liz Hair, US Army Corps of Engineers, WiLnington Field Office
Kristi Lynn Carpenter, NCDWR
File Cogy
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