14040_Union Carbide_Letter Additional Information Regarding On-Site Stream_20110420

AMEC Earth & Environmental, Inc. Tel – [phone]
2200 Gateway Centre Boulevard, Suite 205 Fax – [phone]
Morrisville, NC 27560 www.amec.com

April 20, 2011

Mr. Joe Ghiold
Project Manager
NCDENR-Brownfields Program
1601 Mail Service Center
Raleigh, North Carolina 27699-1601

RE: ADDITIONAL INFORMATION REGARDING ON-SITE STREAM
FORMER UNION CARBIDE CORPORATION PROPERTY
5400 HOVIS ROAD
CHARLOTTE, MECKLENBURG COUNTY, NORTH CAROLINA
AMEC PROJECT #: 643008041
BROWNFIELD'S PROJECT #: 14040-10-60

Dear Mr. Ghiold:

On behalf of CSX Transportation, Inc. (CSXT), AMEC Earth & Environmental, Inc. (AMEC) is
submitting additional information regarding the on-site stream and adjacent potential wetland
area for the above referenced Brownfields Project. It is our understanding that the North
Carolina Department of Environment and Natural Resources, Division of Waste Management,
Brownfields Section (Brownfields Section) requires additional information regarding potential
disposition of the stream and potential wetland during site development.

Site Stream

The stream is located on the eastern side of the property and drains to the south. It is currently
culverted along at least a portion of its trace on the site (see attached Figure) and drains into a
culvert on the adjacent CSXT parcel. Based on historical topographic maps, the stream drains
to the south, into what is now a residential area. AMEC attempted to map the stream off-site,
and was unable to locate the feature. It is our belief that the stream is culverted for
approximately 1,500 feet, through the nearby residential area.

The stream bisects the property and runs along the edge of the battery waste disposal area
(BWDA). Battery casings have been observed in the stream channel, as well as discharge pipes
which could be linked to the former manufacturing facility on the property. The flow appears to
be 12 to 18 inches wide and intermittent. Based on the measured groundwater elevations, the
feature is likely a discharging stream. Photographs of the stream on the parcel are attached.

Additional Site Information
Former Union Carbide Corporation Property
April 20, 2011
Page 2

AMEC Earth & Environmental, Inc. Tel – [phone]
2200 Gateway Centre Boulevard, Suite 205 Fax – [phone]
Morrisville, NC 27560 www.amec.com

For the proposed future use, the entire parcel will need to be at the same topographic elevation
as the adjacent CSXT Intermodal Facility. CSXT plans to culvert the stream across its entire
extent and place several feet of fill material over the top. CSXT will obtain the necessary permits
to do so, prior to the start of development activities. Therefore, the stream will not be a potential
receptor.

As can be seen by the attached photographs, the adjacent BWDA has negatively impacted the
surface water body. Culverting the stream on the site, and isolating it from the battery waste
material, should have a positive impact on the overall surface water quality. Based on the
positive impact to water quality anticipated, CSXT should be able to obtain the necessary
permits for development.

Potential Wetland Area

No potential wetland areas were identified on the subject site. However, during the site
reconnaissance in 2010, a potential wetland area was discovered on the adjacent CSXT
property, near the southwestern property boundary of the subject site. When checked in
December 2010, the area was not identified on National Wetland Inventory or the State Wetland
Inventory.

This entire area will be redeveloped and used as part of the CSXT Intermodal facility. If present,
CSXT will obtain the necessary permits and submit the information required to the United States
Army Corps of Engineers (USACE) and North Carolina Division of Water Quality’s (NCDWQ) to
develop the area and complete the necessary mitigation.

Prior to site development, the following activities will be conducted:

• A wetlands specialist will be mobilized to the site to conduct a field delineation and
document and verify the wetland boundaries, if present;
• If the area is suspected of being a wetland, the jurisdictional boundaries will be
confirmed with USACE and the NCDWQ personnel;
• If the jurisdictional boundaries are indeed confirmed, a metes-and-bounds survey by a
registered land surveyor will be conducted to accurately determine the extent of the
jurisdictional wetlands/streams on the project site;
• Established databases will be reviewed to determine potential impacts to rare species,
historic/architectural resources, and archaeological resources; and,
• Depending upon the extent of impacts, CSXT will submit information required for
obtaining the Section 404 Permit and the associated Section 401 Water Quality
Certification for the proposed project. The impacts map requires either an Individual
Permit application or a Nationwide Permit application. Permit applications will be jointly
submitted to USACE and NC DWQ, as required.

Additional Site Information
Former Union Carbide Corporation Property
April 20, 2011
Page 3

AMEC Earth & Environmental, Inc. Tel – [phone]
2200 Gateway Centre Boulevard, Suite 205 Fax – [phone]
Morrisville, NC 27560 www.amec.com

Please contact Ms. Kathleen Roush at [phone] (ext. 138) if you have any questions.

Sincerely,
AMEC Earth & Environmental, Inc.

Christina McClelland Kathleen Roush, P.G., RSM
Wetlands Specialist NC Environmental Group Manager

P:\ProjectFiles\CSX Hovis Road\643008041_CSX Hovis Road\BFAgreement|Letter Addressing Stream Wetland Issue.docx

Additional Site Information
Former Union Carbide Corporation Property
April 20, 2011
Page 4

AMEC Earth & Environmental, Inc. Tel – [phone]
2200 Gateway Centre Boulevard, Suite 205 Fax – [phone]
Morrisville, NC 27560 www.amec.com

Stream on-site adjacent to battery waste disposal area. Battery casings are visible.

Stream on-site adjacent to battery waste disposal area. Battery casings are visible.

Additional Site Information
Former Union Carbide Corporation Property
April 20, 2011
Page 5

AMEC Earth & Environmental, Inc. Tel – [phone]
2200 Gateway Centre Boulevard, Suite 205 Fax – [phone]
Morrisville, NC 27560 www.amec.com

View looking northward of discharge of stream from on-site culvert.

View looking south of stream area.
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Figure
DR: W. Blaylock CHK: K. WatkinsDATE: 03/17/2011
RECEPTOR SURVEY MAP 5CLIENT:
PROJ.: 643008041
TITLE:
SCALE: 1" = 700'SITE:FORMER UNION CARBIDE PROPERTYBROWNFIELDS PROJECT NUMBER: 14040-10-605400 HOVIS ROADCHARLOTTE, NORTH CAROLINA
AMEC Earth & Environmental2200 Gateway Centre Blvd., Suite 205Morrisville, NC 27560(919) 447-2750
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