20200174_B-5534 scoping comments Dec 2018_20181217

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L.INDA CULPEPPER
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December 17, 2018
MEMORANllUM
To: Jeff Moore, P.E. Kimley-Horn
From: Joanne Steenhuis, NC Division of Water Resources, Wilmington Regional Office
Subject Scoping comments on proposed replacing Bridge 82 on NCI 1/11 l over Burn Coa[ Creek in Duplin
County, STIP B-5534.
Reference your correspondence dated December 10, 2018 in which you requested comments for the refereuced
project. Preluninary analysis of the project reveals the potential for multiple impacts to streams and jurisdictional
wetlands in the project area. More specifically, impacts to:
Stream Name River Basin Stream Classification(s) Stream Index 303(d) Listing
Number
Bum Coat Creek Ca e Fear C;Sw 15-74-17 N/A
Further investigations at a higher resolution should be undertaken to verify the presence of other streams and/or
jurisdictional wetlands in the area. In the event that any jurisdictional areas are identified, the Division of Water
Kesources requests that NCDOT consider [lie following environmental issues for tlie proposed project:
Yroject Specific Comments:
1. To meet tlte requiremeuts of NCD01's NPDES permit NCS000250, tlie road design plans shall provide
treatment of the storn�water ruuoff through BMPs as detailed in the most recent version of the North Cm•olina
Depm•t�nen� of %Y�una�ortn[ion Stormwater Best Mnnagement Prnc(ices %'oolbox manual.
General Project Comments:
2. 'Clie environmental document should provide a detailed and itemized presen[ation of the proposed impacts to
wetlands and streams with corcesponding mapping. lf mitigation is uecessary as required by I SA NCAC
2H.0506(h), it is preferable to present a conceptual (if not finalized) mitigation plan with [he euvironmen[al
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North Carohna Department of 6wlronmental Qualiry I Drvlsion ot Watei Resources
512 No�lh Salisbmy Stree[ � 1617 Mail Service Cen[er I Raleigh, North Carolina 2769&1R17
919707.9000

documen[ation. Appropriate mitigation plans will be required prior to issuance of a 401 Water Quality
Cer[ification.
3. Environmen[al impact statement altematives shall consider design criteria lhat reduce [he impacts to streams
and wetlands from storm water runoff. These altematives shall include road designs that allow for treatment of
tlie stonn water runoff through BMPs as detailed in the most recent version of the North Curolinn Depnrtment
of7rnnsportation Sta�mwater Best Managenrent Practrces Tool box tnanual, sudi as grassed swales, buffer
areas, prefonned scour holes, retention basins, ero.
4. After the selec[ion of the preferred altemative and prior to an issuance of the 401 Water Qualiry Certification,
the NCDO"1' is respectfully reminded that they will need to demonstrate the avoidance and minimization of
impacts [o wedands (and streams) to the maximum extent practical. In accordance with [he Enviromnental
Management Commission's Rales (15A NCAC 2H.0506�h]), mitigaCion will be required for impacts of greater
than I acre to wetlands. In the event that mitigation is required, the tnitigation plan shall be designed to
replace appropria[e los[ functions and values. North Carolina Division of Mitigation Services may be available
for assistance wi[h wetland mitigation.
5. In accordance with the Environmental Management Commission's Rules (ISA NCAC 2H.0506[h]), mitigation
will be required for impacts of greater than 300 linear feet to any perennial stream. In the event that mitigation
is required, the mitigation plan shall be designed to replace appropriate lost functions and values. "The North
Carolina Division of Mitiga[ion Services may be available for assistance with stream mitigation.
6. Fuwre 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 sedimen[ and erosion impacts that could result from this projec[. The
NCD07' shall address these concerns by describing the potential impacts that may occur to the aquatic
environments and any mitigating factors that would reduce the impacts.
8. An analysis of cumulative and secondary impac[s auticipated as a result of this project is required. The type
and detail of analysis shall conform to the NC Division of Water Resource Policy on the assessment of
secoudary and cumulative impacts da[ed April l0, 2004.
9. Tlte NCDOT is respectfully reminded that all impacts, including but not limited to, bridging fill, excavation
and clearing, and rip rap tojurisdictional wetlands, streams, and riparian buffers need to be included in the
final impact calculatious. These impacts, in addition to any construction impacts, temporary or otherwise, also
need to be included as part of Che 401 Water Quality Certification Application.
10. Where streams mus[ be crossed, the NCDWR prefers bridges be used in Iieu of culverts. However, we realize
that economic considerations often require the use of culverts. Please be advised that culverts should be
countersunk to allow unimpeded passage by fish and other aquatic organisms. Moreover, iu areas where high
quality wetlands or streams are impacted, a bridge may prove preferable. When applicable, the NCDOT
should not install Che bridge bents in the creek, to the maximum extent practicable.
I I. Whenever possible, Ihe NCDWR prefers spanning structures. Spanning slructures usually do no[ require work
within N�e stream or grubbiug of the streambanks and do not require stream channel realignment. The
horizontal and vertical clearances provided by bridges shall allow for human and wildlife passage beneath the
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Nor[h Carolina Depaitnient ot 6ivironmen[al Quality � Division of Water Resources
512 Noith Salisbury 5[reat I 1617 Mail Service Center I Raleigh, North Carolina 276991617
919 707.9000

s[ructure. Fish passage and navigation by canoeists and boaters shall not be blocked. Bridge supports (bents)
should not be placed in the stream when possible.
12. Bridge deck drains shall no[ discharge direc[ly into [he stream. Stormwater shall be directed across tlie bridge
and pre-Ireated through site-appropriate means (grassed swales, pre-formed scour holes, vegetated buffers, e[c.)
before entering the stream. To meet die requiremen[s of NCDOT's NPllES pennit NCS000250, please refer to
Ihe most recent version of the Na�th Cnr•olinn Depnrhr7en[ of Transpa�tntron Starrnwuter Best Munugement
Pracdces Toolbox manual for approved measures.
13. Sediment and erosion control measures should not be placed in wetlands or streams.
14. Borrow/waste areas sltould avoid wetlands to the ntaximum extent practicaL Impacts to wedands in
borrow/waste areas will need ro be presented in the 401 Water Quality Certification and could precipitate
compensatory mitigation.
I5. The 401 Wa[er Quality Certification application will need to specifically address the proposed methods for
stormwater management. More speci6cally, stonnwater shall not be permitted to discharge directly into
streams or surface waters. To meet the requirements of NCDOT's NPDES permit NCS000250, please refer
to Ihe most recent version of the North Carolrnn Departrnent ofTransporta[ion S[armwater Bes( Management
Practrces Toolbox manual for approved measures.
16. The DWR cannot comment on permit requirements wi[h the limited information provided. Detailed field
delineation is required to determine the presence or absence ofjurisdictional resouroes within the project
IimiCs. In addition, NCDOT must provide an estimate to any resources located within the construction limits
of the project area before we can specifically comment on NCDWR pennit eligibility. Final pennit
authorization will require [he submittal of a formal applica[ion by the NCDOT and written concurrence from
the NCDWR. Please be aware that any approval will be contingent on appropriate avoidance and
minimization of wetland and s[ream impacts to the maximum extent practical, [he development of an
acceptable stormwa[er managemen[ plan, and the inclusion of appropriate mitigation plans where appropriate.
17. If concrete is used during construction, a dry work area shall be maintained ro prevent direct contact between
curing concre[e and stream water. Water that inadvertently contacts uncured concre[e shall not be discharged
to surface wa[ers due to tlie potential for elevated pH and possible aquatic life and tish kills. Concrete shall
be handled in accordance wi[h the NPDES Construction General Permit NCGO10000.
18. If temporary access roads or detours are constructed, the site shall be graded to its preconstruction conrours
and elevations. Disturbed areas shall be seeded or ntulched to stabilize the soil and appropria[e native woody
species shall be planted. When using [emporary structures the area shall be cleared but no[ grubbed. Clearing
the area with chain saws, mowers, bush-hogs, or other mechanized equipment and leaving the stumps and
root mat intact allows [he area [o re-vege[ate naturally and minimizes soil disturbance.
19. Unless otherwise authorized, placemen[ of culverts and o[her structures in wa[ers and s[reams 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 culvett diameter for culverts having a diameter less than 48 inches, to allow low flow
passage of water and aquatic life. Design and placement of culverts and other structures including temporary
erosion control measures shall not be conducted in a manner that may result in dis-equilibrium of weClands or
streambeds or banks, adjacent to or upstream and downstream of the above swcmres. The applicant is
required [o provide evidence that the equilibrimn is being maintained if requested in writing by the NCDW R.
lf this condition is unable to be met due to bedrock or other limiting features encoun[ered during construction,
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North Carolina Department of Environmen[al Quality I Divismn of Water Resources
512 North SalisUury Street � 1617 Mail Service Center � Raleigh, North Caiolina 2 7 699 16 1 7
919 707.9000

please contact Uie NCDWR for guidance on how [o proceed and to determine whether or no[ a permit
modifica[ion will be required.
20. If multiple pipes or barrels are required, they shall be designed to mimic na[ural stream cross section as
closely as possible including pipes or barrels at flood plain eleva[ion, floodplain benches, and/or sills may be
required where appropriate. W idening the stream cliannel should be avoided. Stream channel widening a[
the iulet or ou[let end of structures typically decreases water velocity causing sediment deposi[ion that
requires increased maintenance aitd disrupts aquatic life passage.
21. lf foundation test borings are necessary; it shall be noted in the document. Geotechnical work is approved
under General 401 Certifica[ion Number 4085/Na[ionwide Pennit No. 6 for Survey Activities.
22. Sediment and erosion control measures sufficient to protect water resowces must be implemented and
maintained in accordance with the most recent version of NoRh Carolina Sediment and Erosion Coutrol
Planning and Design Manual and [he mos[ recent version of NCS000250.
23. All work in or adjacent to stream waters shall be conducted in a dry work area. Approved BMP measures
from the most current version of Nte NCDOT Construction and Maintenance Activities manual such as
sandbags, rock benns, cofferdams and other diversion s[ructures shall be used to prevent excavation in
flowing water.
24. While the use of National Wetland Inventory (N WI) maps, NC Coastal Kegion Evaluation of Wetland
Significance (NGCREWS) maps and soil survey maps are useful tools, their inherent inaccuracies require
that qualified personnel perform onsite wetland delineations prior to permit approval.
25. Heavy equipmen[ should be operated from the bank rather tlian in stream channels in order to minimize
sedimentation and reduce the likelihood of introducing other pollutants into streams. This equipmen[ shall be
inspected daily and maintained to prevent contamina[ion of surface waters Gom leaking fuels, lubricants,
hydraulic fluids, or other toxic materials.
26. Riprap shall not be placed in the active [halweg channel or placed in the streambed in a mam�er that precludes
aquatic life passage. Bioengineering boulders or s[ructures should be properly designed, sized and installed.
27. Riparian vegetation (native Irees and shrubs) shall be preserved [o the maximum extent possible. Riparian
vegetation mus[ be reestablished within Ihe construction limits of the project by the end of the growing season
following wmpletion of coustruction.
Thank you for requesting our input at this time. The NCDOT is reminded that issuance of a 401 Water Quality
Certifica[ion requires that appropriate measures be instituted to ensure Ihat water quality standards are met and
designa[ed uses are no[ degraded or lost. If you have any questions or require additional information, please
contact Joanne Steenhuis at [phone] or [e-mail].
Electronic copy only dish�ibation:
Mason Hemdon, GnvironmenCal Supervisor NC DOT Division 3
Brad Shaver, US Arn�y Corps of Engineers, Wi6nington Field Oftice
Kristi l.ynn Carpenter, NCDWR
File Copy
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Nor[h Curolina Depar[nienl o( Environrnental Quality � Division of Water Resources
512 North Salisbury Street I 1617 Mail Service Cen[er I Raleigh, North Carolina 2769916P
97.9707.9000