HomeMy WebLinkAboutJohnson St-Sandy Ridge Road from I-40 to Skeet Club RoadBeverly Eaves Perdue
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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Charles Wakild, P.E
Diredor
June 14, 2012
MEMORANDUM
To:
From:
Melba McGee, Environmental Coordinator; NCDENR
Amy Euliss, NC Division of Water Quality, Winston Salem Regional Office
Subject: Scoping comments on proposed improvements [o Johnson St-Sandy Ridge Road from 1-40 to
Skeet Club Road in High Point, Guilford County, TIP U-4758 State Clearinghouse Project No.
12-0321.
Dee Freeman
Secretary
Reference your correspondence dated June I, 2012 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 specifically, impacts to:
Stream Name River Stream Stream Index 303(d) Listing-2012
Basin/Buffers Classification s) Number Draft List
West Fork Deep River Cape Fear/ WSIV 17-3-(03) Turbidity and
and unnamed tributaries Randleman Impaired Biological
Lake Buffers Inte ri
West Fork Deep River Cape Fear/ WSN;CA 17-3-(03)a Turbidity
(Oak Hollow Lake) and Randleman
unnamed tributaries Lake Buffers
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 anyjurisdictional areas are identified, the
Division of Water Quality requests that NCDOT and the City of High Point consider the following
environmental issues for the proposed project:
Project Specific Comments:
1. The scopina request says that the project is not a candidate for the merger process. This project
should be screened for the NEPA/Section 404 Merger Process.
2. Both sections of West Fork Deep River and their unnamed [ributaries are class WSIV; 303(d) waters
of the State. West Fork Deep River and its unnamed tributaries are on the 303(d) list for impaired use
for aquatic life due to turbidity, and West Fork Deep River (Oak Hollow Lake) and its unnamed
[ributaries are on the 303(d) list for impaired use for aquatic life due to turbidiCy. NCDWQ is very
concerned with sedimen[ and erosion impacts that could result from this project. NCDWQ
recommends that the most protective sediment and erosion control BMPs be implemented in
accordance with Design Standards in Sensitive Watersheds (15A NCAC 04B .0124) To reduce the risk
Transportation and Permitting Unit
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of further impairment to both sections of West Fork Deep River and their unnamed tributaries.
NCDWQ requests that road design plans provide treatment of the storm water runoff through best
management practices as detailed in the most recent version of NCDWQ Stormwater Best
Management Practices.
3. Review of the project reveals the presence of surface waters classified as Water Supply Critical Area
in the project study area. Given the potential for impacts to these resouxces during the project
implementation, NCDWQ requests that NCDOT strictly adhere to North Carolina regulations entitled
Design Standards in Sensitive Watersheds (15A NCAC 04B .0124) throughout design and
construction of the project. This would apply for any area that drains to streams having WS
CA(Water Supply Critical Area) classifications.
4. Should the bridge or culvert project be located within the Critical Area of a Water Supply,
NCDOT will be required to design, construct, and maintain hazardous spill catch basins in
the project area. The number of catch basins installed should be determined by the design of
the bridge and culverts, so that runoff would enter said basin(s) rather than flowing directly
into the stream, and in consultation with NCDWQ.
This project is within the Randleman Lake Basin. Riparian buffer impacts shall be avoided
and minimized to the greatest extent possible pursuant to 15A NCAC 2B .0250. New
development activities located in the protected 50-foot wide riparian areas within the basin
shall be limited to "uses" identified within and constructed in accordance with 15A NCAC
2B .0250. Buffer mitigation may be required for buffer impacts resulting from activities
classified as "allowable with mitigation" within the "Table of Uses" section of the Buffer
Rules or require a variance under the Buffer Rules. A buffer mitigation plan, including use of
the NC Ecosystem Enhancement Program, must be provided to NCDWQ prior to approval of
the Water Quality Certification. Buffer mitigation may be required for buffer impacts
resulting from activities classified as "allowable with mitigation" within the "Table of Uses"
section of the Buffer Rules or require a variance under the Buffer Rules. A buffer mitigation
plan, including use of the NC Ecosystem Enhancement Program, must be provided to
NCDWQ prior to approval of the Water Quality Certification.
6. Please note in the Randleman watershed, all intermittent and perennial streams are buffered,
as well as first order ditches if they are delivering untreated stormwater directly to a stream.
General Project Comments:
1. The environmental document should provide a detailed and itemized 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 finalized)
mitigation plan with the environmental documentation. Appropriate mitigation plans will be
reguired prior to issuance of a 401 Water Quality Certification.
2. 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 best management practices as detailed in the
most recent version of NCDWQ's Stormwater Best Management Practices Manual, July 2007, such
as grassed swales, buffer areas, preformed scour holes, retention basins, etc.
3. After the selection of the preferred alternative and prior to an issuance of the 401 Water Quality
Certification, the NCDOT 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 Commission'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 mitigation plan shall be designed to replace appropriate lost functions and
values. The NC Ecosystem Enhancement Program may be available for use as wetland mitigation.
4. In accordance with the Environmental Management Commission's'Rules { 15A NCAC
2H.0506(h)}, mitigation will be required for impacts of greater than 1501inear feet to any single
stream. In the event that mitigation is required, the mitigation plan shall be designed to replace
appropriate lost functions and values. The NC Ecosystem Enhancement Program may be available
for use as stream mitigation.
5. 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
mappmg.
6. NCDWQ is very concerned with sediment and erosion impacts that could result from this project.
NCDOT 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.
7. 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 Division of Water Quality Policy on tlie
assessment of secondary and cumulative impacts dated April 10, 2004.
8. NCDOT is respectfully reminded that all impacts, including but not limited to, bridging, fill,
excavation and clearing, and rip rap to jurisdictional wetlands, streams, and riparian buffers need to
be included in the final impact calculations. These impacts, in addition to any construction impacts,
temporary or otherwise, also need to be included as part of the 401 Water Quality Certification
Application.
9. Where streams must be crossed, NCDWQ prefers bridges be used in lieu 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, in areas where high quality wetlands or streams are impacted, a bridge may prove
� preferable. When applicable, NCDOT should not install the bridge bents in the creek, to the
maximum extent practicable.
10. Whenever possible, NCDWQ prefers spanning structures. Spanning structures usually do not
require work within the stream or grubbing 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 structure. Fish passage and navigation by canoeists and boaters shall
not be blocked. Bridge supports (bents) should not be placed in the stream when possible.
11. 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. Please refer to the most current version of
NCDWQ's Stormwater Best Management Practices.
12. Sediment and erosion control measures should not be placed in wetlands or streams.
13. Borrow/waste areas should avoid wetlands to the maximum extent practical. Impacts to wetlands in
borrow/waste areas will need to be presented in the 401 Water Quality Certification and could
precipitate compensatory mitigation.
14. The 401 Water Quality Certification application will need to specifically address the proposed
methods for stormwater management. More specifically, stormwater shall not be permitted to
discharge directly into streams or surface waters.
15. Based on the information presented in the document, the magnitude of impacts to wetlands and
streams may require an Individual Permit (IP) or Nationwide (NW) permit 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 concurrence from
NCDWQ. 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 stormwater management plan, and the inclusion of appropriate mitigation plans where
appropriate.
16. If concrete is used during construction, a dry work area shall be maintained 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
fish kills.
17. 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 using 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.
1 S. 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 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 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 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 NCDWQ. If this condition is unable to
be met due to bedrock or other limiting features encountered during construction, please contact -
NCDWQ for guidance on how to proceed and to determine whether or not a permit modification
will be required.
19. If multiple pipes or barrels are required, they shall 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 stream channel should be avoided. Stream
channel widening at the inlet or outlet end of structures typically decreases water velocity causing
sediment deposition that requires increased maintenance and disrupts aquatic life passage.
20. If foundation test borings are necessary; it shall be noted in the document. Geotechnical work is
approved under Genera1401 Certification Number 3883/Nationwide Permit No. 6 for Survey
Activities.
21. 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 arid Design Manual and the most recent version of NCS000250.
22. 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 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.
23. While the use of 1Vational Wetland Inventory (NWI) maps, NC Coastal Region 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.
24. Heavy equipment should be operated from the bank rather than in stream channels in order to
minimize sedimentation and 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.
25. 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.
26. Riparian vegetation (native trees and shrubs) shall be preserved to the maximum extent possible.
Riparian vegetation must be reestablished within the construction limits of the project by the end of
the growing season following completion of construction.
Thank you for requesting our input at this time. NCDOT is reminded that issuance of a 401 Water
Quality Certification requires that 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 information, please contact Amy Euliss at (336) 771-4959.
cc: Andy Williams, US Army Corps of Engineers, Raleigh Field Office (electronic copy only)
Federal Highway Administration
Chris Militscher, Environmental Protection Agency (electronic copy only)
Travis Wilson, NC Wildlife Resources Commission (electronic copy only)
Wetlands/401 Transportation Permitting Unit
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