20120285_Gaston East-West Corridor Email_20111006

J I FW EPA Comments on Gaston Draft WQA ICE
FW EPA Comments on Gaston Draft WQA ICE
Lespinasse, Polly
Sent Tuesday May 08 2012 3 08 PM
To Carrillo Sonia
Attachments NCTA GastonWQA suppFEIS pdf (227 KB)
Page 1 of 1
From Militscher Chns @epamail epa gov [mailto Militscher Chris @epamail epa gov]
Sent Thursday, October 06, 20118 53 AM
To Harris, Jennifer, kirsten r bass @ncturnpike org
Cc George Hoops, sarah a hair @usace army mil, Lespinasse, Polly, Wrenn, Brian,
monte k matthews @usace army mil, marella_buncick @fws gov, Chambers, Marla J, Gledhill earley, Renee
Subject EPA Comments on Gaston Draft WQA ICE
Jennifer /Karsten Please see attached A signed hard copy will be mailed to you today Thank you
https //mall nc gov /owa/9ae= Item &t =IPM Note &1d= RgAAAADMSzLcd9W2TJHI4 %2bm 5/17/2012

SEO SraTFS UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
K� y2 REGION 4
a Q ATLANTA FEDERAL CENTER
61 FORSYTH STREET
cr'
�Mrq� , .... ATLANTA GEORGIA 30303 8560
October 4 2011
Ms Kif rsten Bass
North Carolina Turnpike Authority
1 South Wilmington Street
1578 Mail Service Center
Raleigh North Carolina 27699 -1578
SUBJFCT Draft Water Quality Analysis Gaston East West Toll Facility ( Garden
Parkway ) Supplemental Information to the Federal Final Environmental
Impact Statement (FEIS) Gaston and Mecklenburg Counties North
Carolina, TIP Project No U 3321 FHW- E40827 -NC CEQ No
20110011
Dear Ms Bass
The North Carolina Turnpike Authority (NCTA) and the Federal Highway
Administration (FHWA) which are proposing to construct a 22 mile toll facility (the
Project) from I -85 west of the Town of Gastonia to 1 485 by the Charlotte Douglas
Airport in Gaston and Mecklenburg Counties have requested comments on the draft
Indirect and Cumulative Effects (ICE) Water Quality Analysis (WQA) for this project
The U S Environmental Protection Agency Region 4 (EPA) has reviewed the WQA for
the Project dated August of 2011 and is providing comments in accordance with Section
309 of the Clean Air Act Section 102(2)(C) of the National Environmental Policy Act
(NEPA) and Sections 401 and 404 of the Cle in Water Act Our general comments are
provided below with the detailed comments in the Attachment
EPA has been involved with this Project as part of the NC Merger Interagency
Team In its review of the Project s DEIS (07/2009) and FEIS (02/2011), EPA identified
environmental concerns due to the substantial direct impacts on water quality from the
proposed Project Based on the review of the WQA the indnect and cumulative effects
from the 2035 Preferred Alternative (Build scenario) will result in further degradation to
watc,r quality throughout most of the project study area Per the WQA five (5) of the
hydrologic units (HUs) are on the 2010 NC 303(d) list of impaired waters and are
expected to be further impaired by indirect and cumulative effects from the proposed
project The project alignment intersects all fitie impaired IfUs Interchanges are also
planned for all five (5) impaired HUs Therefore the proposed mitigation plan should be
strengthened to ensure that it addresses all the substantial impacts to waters of the U S
from the proposed project
Intomat Address (URQ http flwww apa gov
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EPA recommends that the NCTA identify project specific Stormwater Best
Management Practices (BMPs) for direct and indirect impacts that are based upon
predicted development patterns and land use changes The NCTA should coordinate this
effort with NC Division of Water Quality ( NCDWQ) and work closely with local
agencies to implement and enforce these specific BMPs NCTA should also be aware
that all land disturbing activities greater than one acre are subject to coverage under the
North Carolina National Pollutant Discharge Elimination System construction general
permit to address stormwater discharges related to construction activities This permit
requires the development of a stormwater pollution prevention plan that will ensure that
the adequate levels of BMPs necessary to control the discharges of pollutants from these
sites are implemented
EPA believes that the overall direct impacts indirect and cumulative effects of the
proposed Project may jeopardize compliance with the Clean Water Act Therefore EPA
recommends that mitigation for these substantial direct impacts indirect and cumulative
effects of this proposed Project be considered in the context of the Council on
Environmental Quality regulations at 40 C F R Section 1500 1(c) The NEPA process
is intended to help public officials make decisions that are based on understanding of
environmental consequences and take actions that protect, restore and enhance the
environment
EPA requests a copy of the final WQA report when it becomes available
Mr Christopher A Militscher of my staff will continue to be available to work with you
on these outstanding issues Please feel free to contact him at 919 856 4206
Sinceicly,
9 I ) )9," /
Heinz J Mueller, Chief
NEPA Program Office
Attachment A
cc G Hoops, FHWA, w /attachment
S Hair USACE w /attachment
P Lespinasse NCDWQ w /attachment

ATTACHMENT A
Detailed Technical Comments
Draft Water Quality Analysis (WQA)
Gaston East -West Toll Facility
TIP No U -3321
Specific Comments
We recommend that the environmental issues identified below should be further
evaluated and addressed in a final WQA report Per this draft report, the indirect and
cumulative effects from the 2035 Preferred Alternative (Build scenario), will result in
:further degradation to water quality throughout most of the project study area
1- The draft WQA report does not identify the rationale for using the year 2006 as
the Baseline Condition (Page i) The North Carolina Division of Water Quality
(NCDWQ) updated the 2008 Impaired Waters List and received EPA approval on
March 10 2010 The draft report failed to use the most recent approved stream
classification data of impaired waters as the baseline condition within the project
study area
2- Under Section 2 2 1 of the draft WQA report existing water conditions such as
303(d) impaired waters are shown from the year 2000 to 2010 Under Section 2 2
of the draft report the headwaters of 26 streams (out of 36 total named streams)
occur within the study area Under Table 5 it should be noted that 14 of 17
stream and stream segments in North Carolina are listed as impaired under the
2010 Section 303(d) impaired list Under the year 2000 Section 303(d) impaired
list, only 12 of 17 stream and stream segments in North Carolina are listed as
impaired
Under Section 4 2, page 27, the 2035 No build condition is generally described
as Development is predicted to increase throughout the Study Area The socio
economic factors that contribute to the anticipated development in the Study Area
are not quantified in this draft report Under Section 4 3 for the 2035 Preferred
Alternative (i a Build Scenario) the ICE predicted that there would be
approximately 1,100 additional acres of residential development and 100 fewer
acres of commerciaUindustrialtoffice development compared to the 2035 No build
Scenario The increase in development is expected to produce 3 300 additional
households There will also be approximately 1,500 acres (2 3 square miles) of
direct impacts resulting from the proposed Gaston East West Connector
4 Five (5) of the 9 Study Area HUs add impervious surface cover in the 2035
Preferred Alternative (PA) build scenario There will be increases in Annual
Runoff Total Nitrogen (TN) Total Phosphorus (TP) and Annual Total
Suspended Solids (TSS) predicted in the 2035 PA build scenario versus the 2035
No -build scenario in numerous HUs Some of these increase stormwater and
pollutant loads are significant including 8 73% of Annual Runoff in the

Beaverdam Creek Catawba River HU 5 3% of TN in the Lake Wylie Catawba
River HU and the Catawba Creek HU 7 0% of TP in the Catawba Creek HU and
2 4% of TSS in the Catawba Creek HU Analyzing Tables 17 to 20 to the draft
report further comparing the 2035 No Build vs Build 8 out of 9 HUs indicate an
increase in Annual Runoff 7 out of 9 HUs indicate an increase in TN 7 out of 9
HUs indicate an increase in TP and 6 out of 9 HUs indicate an increase in TSS
From Section 5 0 no site specific BMPs such as bio retention stormwater ponds
grass swales are recommended in the draft report due to a lack of information
regarding future development The report also does not identify specific and
appropriate BMPs for water quality protection from the project s significant and
direct impacts to impaired waters