20181249 Ver 1_Attachment 13 - 2017-08-16 E-mail from Christopher Murray to Kiersten Bass_20181217

From: Murray, Christopher A [[e-mail]]
Sent: Wednesday, August 16, 2017 7:47 AM
To: Kiersten Bass
CC: [e-mail]; Michael Wood; Tharrington, Emmette B; Hopkins, Joey; Jernigan, Dennis W;
Tharrington, Emmette B; Hopkins, Joey; Jernigan, Dennis W
Subject: RE: Comp540 - Revised Draft BA----Comments from NCDOT Division 5
Attachment(s): "Comp540 Draft BA 080817.pdf"
Kiersten,
I have had an opportunity to review the this updated document and can provide information on issues that affect Division 5. Note the
following specific information contained in the report and suggestions for revisions or corrections in RED.
4.1.1.2 Bridge Deck Drainage
-NCDOT makes every attempt to eliminate direct drainage into crossed waterbodies whenever protected species are present. The
design for all bridges in the Swift Creek Watershed will eliminate deck drains into water bodies they cross.
No comment, as this appears to be a structure design issue and hydraulics review issue.
4.1.1.3 Agency Coordination
-NCDOT will invite representatives from USFWS and NCWRC (as well as other agencies) to the pre-construction meeting projects
as well as to all subsequent field inspections prior to construction to ensure compliance with all special project commitments.
Division 5 has concerns over the wording of this commitment and proposes the following: NCDOT will invite representatives from
USFWS and NCWRC (as well as other agencies) to the pre-construction meeting for the Complete 540 project as well as to pre-
construction meetings associated with installation of structures at Stream Sites SDF, Swift Creek (SDH) and SDJ in the Swift Creek
Watershed.
4.1.1.4 Construction Practices
-NCDOT will strongly discourage the contractor from choosing borrow site locations, staging areas, equipment storage areas, and
refueling areas within the Swift Creek and Lower Middle Creek watersheds in association with this project. Such a decision should
be substantiated with documentation as to why there are no other reasonable options. As such, the likelihood of the contractor
choosing such a site is remote. However, if it is decided that such a site is ultimately the best way to move the project forward, the
DEO will coordinate with the NCTA, USFWS and the contractor to develop BMPs for each site to avoid/minimize the potential for
adverse impacts.
Division 5 cannot agree with this commitment as it is written in the document. We propose the following: NCDOT will discourage the
contractor from choosing borrow or waste locations in the vicinity of Sites SDF, Swift Creek (SDH) and SDJ in the Swift Creek
Watershed. However, if it is decided that the contractor will pursue borrow or waste sites in these locations, the NCDOT Division
Environmental Officer will coordinate with the NCTA and the USFWS during the approval process of any borrow or waste sites.
Note that the contractor must follow provisions in the Standard Specifications for Roads and Structures (January 2012) for borrow
excavation (Section 230) and disposal of waste and debris (Section 802).
4.1.2.1 Stream Crossing Review
-During the development of the alternatives for the project, an interagency field review was held to review stream crossings and
determine if the minimum required structure type should be altered to avoid/minimize environmental impacts. Within Swift Creek
Watershed, three crossings (Figure 10) were identified as particularly high-value that warranted larger structures (Table 9) to
minimize direct effects.
No comment, as this appears to be a structure design issue and hydraulics review issue.
4.1.2.2 Bridging of Swift Creek
-The bridge that crosses Swift Creek will not have any part of the structure in the stream channel or on the banks. Further, no
permanent structures or temporary structures required to build the bridge will be placed within Swift Creek. All permanent and
temporary structures will be positioned such that they will not result in any bank instability or cause sediment to runoff into Swift
Creek.
Division 5 has no comment regarding the permanent or temporary structures required to construct the bridge within Swift Creek.
However, the last sentence indicating that the structures will be positioned in a way that will not result in any bank stability or cause
sediment to runoff into Swift Creek is problematic. This actually cannot be guaranteed as there could be unforeseen bank failure
during installation of drilled shafts nearby (i.e. 10 feet) the top of bank. Additionally, extreme weather events could possibly overtop
erosion control devices at the bridge crossing resulting in loss of sediment into Swift Creek. We suggest the following revision to the
last sentence: All permanent and temporary structures will be designed and installed such that they should not result in bank
instability or cause sediment to runoff into Swift Creek.
4.1.2.3 Hazardous Spill Basin
-NCDOT will require construction of hazardous spill basin(s) on the crossing of Swift Creek. The basin(s) will be designed to contain
a spill from a typical tanker truck that may otherwise flowed directly into Swift Creek. NCDOT will implement their standard protocols
for upkeep and use of these basins.
No comment, as this appears to be a roadway design issue and hydraulics review issue. The Division supports installation of the
hazardous spill basins at the crossing of Swift Creek.
4.2 Direct Effects
-The report indicates that the NCDOT has committed to avoiding any permanent or temporary impacts at the Swift Creek bridge
crossing.
Division 5 suggests that this comment be re-written to indicate no permanent or temporaryin-stream impacts at the Swift Creek
bridge crossing.

4.2.1 5tream Fill {5uhstrate {Hahitat] aisturhancelLoss]
-The repart indicates that temparary fill within hahitat accupied hy dwarf wedgemussel and yellaw lance may alsa result in the
permanent lass af hahitat as the impacts may he lang-li�ed ar essentially permanent.
❑i�isian 5 nates that a pre�iaus sectian af the repart indicates that na temparary ar permanent impacts are allawed at the Swift
Creek crassing {which likely is the anly area that has hahitat accupied hy the dwarf wedgemussel ar yellaw lance}.
4.2.2 Erosionl5edimentation from Construction
-The repart states: "The cantractar may use areas within the Swift Creek and Middle Creek watersheds far staging starage, refueling,
harraw pits ar spail areas."
❑i�isian 5 nates that this statement {i.e. use af staging starage, refueling, harraw pits ar spail areas in Swift Creek and Middle Creek
watersheds} cantradicts infarmatian in 4.1.1.4 Canstructian Practices af the repart.
4.3.4 aisruption of Fish Host Migration
-The repart states: "Hawe�er, disruptians ta the narmal migratian af indi�iduals af same fish species may accur while temparary
causeways are canstructed and in place in same ather crassings within the watershed."
❑i�isian 5 suggests that disruptian af same fish species cauld alsa accur during stream dewatering aperatians used ta install pipe
and cul�ert structures at ather crassings in the watershed.
4.5.1 airect EfFects
-The repart states: "The cul�erting af Stream SaF will result in a maximum af 433 linear feet af permanent impact ta the channel."
❑i�isian 5 nates that Figure 10 indicateshridging af Stream SaF and installatian af a cul�ert at Stream SaJ. Please re�iew the
camment in yaur repart regarding cul�erting af Stream SaF as it actually indicates hridging af Stream SaF.
-The repart states: "Additianally, temparary lasses af stream channels in Streams SaF and SaJ will accur as a result af fill
assaciated with the use af temparary causeways during canstructian, the final amaunt which will he determined during final design."
❑i�isian 5 nates that temparary lasses af stream channel may accur at Stream SaF during installatian af the temparary causeway as
it is heing crassed with a hridge structure. Hawe�er, Stream SQJ in�al�es canstructian af a hax cul�ert which will nat require
installatian af a temparary causeway.
-The repart states: "At this time, the lacatians af patential harrawlspail sites, staging areas, equipment starage areas, and refueling
areas ha�e nat heen chasen. If any af these selected sites are within Swift Creek ar Middle Creek watersheds, existing regulatians
excluding stream huffer areas fram heing used far these purpases, and the cammitment af NCa�T ta adapt measures ta
a�aidlminimize the patential far ad�erse effects in nan-regulated areas within the respecti�e watersheds, make it extremely unlikely
{discauntahle} that these types af praject-related direct effects will accur.
❑i�isian 5 nates that the statement {use af harrawlspail sites, staging areas, equipment starage areas, refueling areas in Swift Creek
and Middle Creek watersheds} cantradicts infarmatian in 4.1.1.4 Canstructian Practices af the repart.
Please ad�ise if yau need ta discuss these camments and my prapased respanses.
Thanks,
Chris Murray
Christopher A. Murray, PWS
❑i�ision En�ironmental Super�isor
❑i�isian 5
[919} 220�633 aff ce
cmurravCa7ncdotoo�
NC��T-�i�isian 5
2612 N. �uke Street
Caurier: 17-27-03
❑urham, NC 27704
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From: Kiersten 8ass [mailta:[e-mail]]
5ent: Tuesday, August 15, 2017 9:20 AM
To: Murray, Christapher A �[e-mail]��
5uhject: Camp540 - Re�ised ❑raft 8A
fCiersten R. Sass
Planning Ser�ices Manager
HNTB North Carolina, P.C.
343 E. Six Farks Raad, Suite 200
Raleigh, NC 27609

Direct 919.424.0457
Mobile [phone]
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