20161268 Ver 1_Supplemental DEIS Report Info_20120228

A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
YW REGION 4
o Q ATLANTA FEDERAL CENTER
Z�F 02 61 FORSYTH STREET
+l, 4 PROIec� ATLANTA GEORGIA 30303 8960
Date February 28, 2012
Dr Gregory J Thorpe, PhD, Manager
Project Development and Environmental Analysis Branch
North Carolina Department of Transportation
1548 Mail Service Center
Raleigh North Carolina 27699 -1548
SUBJECT Supplemental DEIS Report Information Evaluation of Impacts to Public Water
Supply Groundwater Wells US 17 Hampstead Bypass /Military Cut off Road Extension, Pender
and New Hanover Counties North Carolina CEQ No 20110322 TIP Project Nos R 3300 and
U -4751
Dear Dr Thorpe
The U S Environmental Protection Agency (EPA) Region 4 Office has received and
reviewed the subject document and is commenting in accordance with Section 309 of the Clean
Air Act (CAA) and Section 102(2)(C) of the National Environmental Policy Act (NEPA) This
supplemental report was prepared to address EPA s Draft Environmental Impact Statement
(DEIS) comments dated November 15 2011 regarding potential impacts to public water
supplies
EPA has attached specific NEPA/Section 404 Merger technical assistance comments for
consideration by the North Carolina Department of Transportation (NCDOT) the U S Army
Corps of Engineers (USACE), the N C Division of Water Quality (NCDWQ) and other Merger
team agencies (See Attachment A)
EPA recognizes the post DEIS efforts to try to avoid direct impacts to public water
supply wellheads involving the M1 and M2 Alternatives by moving the roadway alignment
Nevertheless, EPA continues to have substantial environmental concerns regarding the potential
groundwater impacts resulting from Alternatives M1 and M2 In addition EPA is also
requesting additional information regarding the 100 foot buffers and the distance to the proposed
NCDOT's right of way and other data that the report did not fully address By shifting the
alignment for Alternatives M1 and M2, natural and human resource impacts may have also
changed from the DEIS This additional requested information for EPA s review would be
Internet Address (URL) http Hwww spa gov
Recycled/Recyclable Printed with Vegetable 08 Based Inks on Recycled Paper (Minimum 30 / Posiconsumer)

ATTACHMENT A
Supplemental Report dated 2/8/12 on Public Water Supply Impacts
US 17 Hampstead Bypass/Military Cut -off Road Extension
Pender and New Hanover Counties, N C
TIP Protect Nos R -3300 and U4751
Merger Technical Assistance Comments
Introduction
1 EPA acknowledges the further evaluation of potential impacts to groundwater and public
water supply wells that were conducted by NCDOT, USACE and NCDWQ following the
December 15, 2011, Merger team informational meeting
Project Description
2 EPA notes the project description provided in the report
3 EPA notes the two proposed typical sections for Military Cut off Road Extension (MCRE)
The 0 9 mile 6 lane section is proposed as curb and gutter with a 30 -foot median and a wider
outside lane (14 -foot) to accommodate bicycles The second section from north of Torchwood
Boulevard is 6lanes with 14 -foot shoulder section and 46 -foot median
4 EPA notes that the right of way width is variable from 150 feet to 350 feet EPA requests that
the variable right of way width be depicted on preliminary designs for MCRE's M 1 and M2
Alternatives at the next Merger meeting
Public Water Sunvly
5 EPA notes that the Cape Fear Public Utility Authority ( CFPUA) provides drinking water for
New Hanover County (Page 2 " total demand represented 28 percent of the total available
water supply (all sources) in 2010 ) The 2009 nanofiltration Water Treatment Plant (WTP) is
located adjacent to the proposed MCRE Alternatives Ml and M2 CPFUA anticipates additional
public water supply needs in the future from this wellhead protection area
6 The following statement is noted Roads are commonly [Emphasis added] found within
wellhead protection areas across the [S] state EPA requests that recent examples of mayor
roadways that are found within wellhead protection areas be provided to support this vague
claim Wellhead protection areas generally tend to be located in undeveloped areas and not in
areas with existing higher risks (See discussion below)
r
7 The background geological information and detailed aquifer and well water yield information
concerning the Castle Hayne and Peedee Aquifers is noted The CFPUA withdraws groundwater
from both aquifers The Peedee is considered to be a confined aquifer and the Castle Hayne is
considered to be a semi confined aquifer According to EPA sources neither the Peedee or
Castle Hayne aquifers are designated nor protected by EPA as a `sole source aquifer' (i e

Section 1424(e) of the Safe Drinking Water Act of 1974) Both aquifers show an existing issue
of inland salt water intrusion from the figures provided on Page 3
Wellhead Protection Area
8 M 1 and M2 Alternative's are located within the wellhead protection area established for the
public water supply wells operated by CFPUA (Page 4) A portion of the Hampstead Bypass
Alternative U is also located in the wellhead protection area The 100 -foot buffer requirement
around each well is noted (15A NCAC 18C 0203) The 100 -foot buffer around the wellhead is
required to be owned or controlled by the person [entity] supplying the water
9 Table 1 provides the CFPUA wells in the vicinity of MCRE and relevant data (Well Site /IS #
Aquifer WHPP radius, yield, MCRE Alternative distance from wellhead to MCRE slope stakes
etc ) Well Site B (Wells ID's 22 and B -CH) are estimated to be both located 126 feet from slope
stakes Slope stakes are construction limits for the proposed multi -lane MCRE The NCDOT
right of way would potentially be closer to the wellheads Slope stakes information would not
appear to meet the criteria required to determine the 100 foot buffer per State regulations
10 Well ID #22 is 170 feet deep to the Peedee aquifer Well ID #B -CH is 80 feet deep to the
Castle Hayne aquifer EPA also requests information of the distance of the right of way with
Well Site H (Well ID s H CH and H PD) Both wellheads are identified as being less than 200
feet from the slope stakes
11 The comments regarding the future well sites depicted by an X on Figure 5 are noted
MCRE Alternative M2 would cross existing and proposed water lines associated with the
proposed expansion area CFPUA future wellhead site criteria are provided including the
criterion because the area is undeveloped which protects the wellheads from contamination"
Wellhead Protection Plan
12 The information regarding the Wellhead Protection Plan (WHPP) is noted and that the
CFPUA plan was finalized in December of 2009
13 The CFPUA Risk Criteria lists Major Road in the higher risk category under likelihood of
occurrence The sources of pesticides herbicides, metals and solvents of sufficient quantity that
are less than 750 feet from a well are considered higher risk with the Mayor Road Considering
industries and regional commerce in the project study area and that US 17 and MCRE are
proposed for regional through traffic EPA would expect a great percentage of truck traffic and
hazardous materials through the Wellhead Protection Area (WPA1 = 7,712 acres)
14 The following statement is confusing No existing or proposed roads were included an the
last of identified potential contaminant sources an the WHPP " CFPUA may have been unaware
of the scope, location and timing of the proposed MCRE as some concept of this proposed
project has been around since a NCDOT feasibility study from the early 1990's NCDOT did not
identify the potentially impacted wellhead sites for MCRE alternatives M 1 and M2 earlier in the
NEPA/Section 404 Merger team process during the development of reasonable corridors

15 The NCDOT did not identify existing truck traffic percentages in this report or the potential
number of hazardous materials shipments that currently utilize US 17 Wilmington Bypass or
other project study area roadways that are less than 750 feet from the existing wellheads Based
upon a general knowledge of the industries in the region, including the Port of Wilmington, the
current WPA1 is probably already at a higher risk of contamination from spills Pulp and paper
mills, chemical plants, nuclear fuel rod assembly, oil and gasoline distribution facilities, marine
construction and repair, etc, are current industries all located in the region that utilize the US 17
corridor Water soluble chemicals could reach the water supply aquifer in a relatively short time
Precipitation events could greatly acerbate spill cleanup efforts and allow contaminants to spread
at a significant distance from the source
Evaluation of Potential Impacts
16 Without the additional information from NCDOT concerning truck traffic percentages,
potential volumes of hazardous materials, and the types of hazardous materials currently utilizing
US 17 Wilmington Bypass Market Street/US 17 Corridor, the evaluation of potential impacts is
not believed to be an accurate characterization of the risk to public water supplies in the project
study area
17 EPA understands the general assessment concerning impervious surfaces However, the long-
term increase in pollutant loadings from mayor roads is a significant threat to public water supply
recharge areas Toxic heavy metals (e g, Lead, cadmium, etc) and other pollutants accumulate
near the ground surface but can eventually migrate over time through the soil and geological
strata into deeper aquifers Depending upon rainfall, pH and other environmental factors (e g ,
Bioaccumulation from woody plant species), the soil types, etc this leaching can be a source of
groundwater contamination The wells at the greatest risk based upon proximity are also
relatively shallow (e g, Well B CH is 80 -feet deep and that is not generally considered to be a
`deep well )
18 The comment, "Other potential impacts to groundwater quality are accidental spills and
wrecks on the proposed roadway [multi lane expressway]" One of the project purposes as stated
on Page 1 of the report is to improve safety The NCDOT and USACE are promoting multi
lane high speed freeway and expressway facilities in the project study area that still maintains
significant rural and suburban land uses FHWA has conducted numerous safety studies
concerning high -speed facilities and these studies should be evaluated with respect to the
increased risks associated with new multi lane facilities in a WPA
The proposed interchange along US 17 Wilmington Bypass /I -140 connects the proposed
US 17/Hampstead Bypass freeway with the MCRE 6 -lane expressway Truck drivers including
those hauling hazardous materials are under time pressure to make deliveries Providing multi
lane, high speed facilities does not potentially reduce the number of accidents but does
potentially increase the seventy and environmental consequences from accidents
19 The statement is noted "If the contributing area for the well is identified and management
strategies are set in place to manage certain activities the possibility that the well might become
contaminated can be substantially reduced' Please identify these specific management

strategies that will be set in place to manage certain activities that will substantially reduce the
well from being contaminated that is located 126 feet from the slope stakes of the new MCRE
expressway CFPUA has developed management strategies in a WHPP NCDOT needs to
identify how the higher risk to the WPA will be minimized as the CFPUA did not identify an
existing Mayor' roadway in their finalized WHPP NCDOT should identify what spill response
capabilities that the CPFUA possess, including the equipment, personal protective gear,
monitoring and sampling instrumentation, etc NCDOT should identify if there will be access
issues for CFPUA personnel and equipment in the NCDOT s right of way in order to clean up a
chemical spill that is threatening one of the adjacent wellheads It should be noted that
hazardous material transporters do not always have local spill cleanup contractors available and
that it typically takes hours (and even days) for cleanup personnel and equipment to arrive on-
scene
20 The statement on Page 7 concerning the Peedee and Castle Hayne aquifers is contradictory to
the characterization on Page 3
Water SuUUIv
21 EPA notes that the alignments for Alternatives M1 and M2 have been shifted since issuance
of the DEIS to avoid existing and future wellhead sites (2 and 4 +1, respectively) Both M1 and
M2 impact existing potable and raw water lines and would be relocated as part of the proposed
project and returned to service Please provide additional details on these temporary impacts
22 EPA can only locate the two wellhead buffers on the figures and maps (Preliminary designs
"before' and after') provided in the report that was avoided from the alignment shift for M1
and M2 EPA requests copies each of the preliminary designs in a readable scale for Ml and M2
and the original locations of the impacted existing wellheads and the future wellhead sites
23 From the preliminary designs before and after" depicting two 100 -foot wellhead buffer
circles the alignment was shifted into a neighborhood Please quantify all changed human and
natural environmental impacts from what was presented in the DEIS for Alternative M 1 and M2
A noise wall was also proposed along the subdivision that was previously not being directly
impacted From the alignment shift to avoid the wellheads and 100 -foot buffers, please identify
the new location of the noise wall that was determined to be needed for noise abatement adjacent
to the subdivision
24 Comments concerning aquifer recharge on Pages 7 and 8 are noted
Water Quality
25 Regarding the section on Accidental Spills EPA does not concur with the assessment
provided The assessment is not supported by any actual data or analysis and includes the
following phrases probably represents" is probably not greater , and "likely could be
contained and removed before reaching the aquifers the wells are drawingfrom' EPA requests
a copy of the WHPP Contingency Plan for review as the NCDOT is relying on the CFPUA s

contingency planning efforts to address the higher nsk of contamination created by the revised
alignment location for the M 1 and M2 Alternatives
26 Regarding the section on Stormwater Runoff, the comment concerning the higher -nsk
potential as a contaminant source from stormwater discharges is noted Literature indicates that
highway stormwater does occasionally contaminate groundwater with minor amounts ( ?) of
metals and petroleum compound These chemicals are typically present at extremely low
concentrations and tend to be localized around the right of way" Please identify the literature
sources and how these `minor amounts' relate to North Carolina's potable water standards
Reference studies should include `fate and transport' models conducted for similar soils and
geology, pH regimes, contaminants, depth to aquifer and other relevant factors to support this
postulated assessment on nsk
27 Comments concerning road salt applications noted
28 EPA does not concur with the assessment concerning the impacts to existing, permitted
stormwater basins located within CFPUA s WPA NCDOT estimates 0 75 acres of permitted
Pond BPE is expected to be impacted NCDOT estimates 0 41 acres of permitted Pond BPF is
expected to be impacted Both of these permitted stormwater ponds were required so as to help
to reduce stormwater runoff and pollutants from residential developments NCDOT will likely
be required to replace any stormwater storage capacity lost due to project impacts to permitted
ponds EPA concurs with this `likely environmental commitment
29 EPA is unable to concur with the last sentence of this section on Page 9 NCDOT has not
conducted an aquifer recharge assessment based upon runoff in the project study area or the
WPA
Avoidance and Minimization of Potential Impacts
30 The Merger team has not yet evaluated the impacts and concurred on a Least
Environmentally Damaging Practicable Alternative (LEDPA — Concurrence Point 3) for R-
3300/U 4751 Avoidance and minimization measures (CP 4A) have not been performed for
impacts from other Detailed Study Alternatives currently under consideration
31 NCDOT is essentially requiring CFPUA to perform avoidance and minimization measures to
protect the WPA using the emergency contingency plan NCDOT is not proposing any hazardous
spill catch basins in vulnerable areas of the WPA to potentially catch contaminated stormwater
or accidental chemical spills NCDOT is not proposing any special storm water basins for
collecting typical roadway runoff and pollutants
32 EPA does not support a ` NCDOT Spill Response Dial 911 sign To report chemical spills,
hazardous materials transporters and other responders are required to call the 24 -hour National
Response Center at 1 800 424 -8802 for reportable spills NCDENR also maintains a spill
reporting number at 919 -733 4984

33 `Appropriate measures' to avoid spillage of construction materials and control runoff on Page
10 are not identified The appropriate measures' cited in the following sentence is required on
every NCDOT construction protect Very specific contract/contractor requirements regarding re
fueling equipment (e g, Diesel and gasoline powered equipment) in the WPA during
construction is one possible measure that should be considered The location or siting of re-
fueling saddle tanks and trucks is another possible measure Please note the following estimation
It is generally accepted that one gallon of motor oil pollutes 1,000 000 gallons of water One source
of this info is the North Carolina Clean Water Education Partnership
See http / /www nccwep org /help /did you know php for the citation
Summary and Conclusion
34 The Summary and Conclusion comments on Page 10 are noted EPA does not concur that
the 100 foot buffer requirement between wellheads and the proposed right of way limits is being
met and that construction slope stake distances are instead being proposed Future lanes are
essentially being planned using the proposed 30 -foot and 46 foot median widths which will
increase the impervious surfaces and stormwater runoff in a WPA There will be potentially less
stormwater treatment using median depression and shoulder stormwater treatment designs once
new lanes are added in the future EPA does not believe that the current plans as proposed in this
report address the long term water quality concerns for the CFPUA s WPA There appears to be
complete reliance on the CPFUA's Contingency Plan for any chemical spills or pollutant runoff
from the new, multi lane high speed expressway and the details of that contingency plan are not
provided in this report Impacts to existing permitted stormwater ponds will also reduce the
capacity to capture and treat stormwater runoff before it permeates into the groundwater table
and ultimately the shallow semi confined Castle Hayne aquifer Replacing existing capacity is
not believed to be adequate mitigation' for the increases in pollutant loadings that will result
from the proposed multi lane highway project CFPUA's WPA and associated infrastructure
currently supplies approximately one third of the Wilmington and surrounding area public water
needs CFPUA has indicated that this WPA will be used to meet increased future demand for the
public water supply needs

helpful prior to the next scheduled Merger team meeting Mr Christopher Militscher of my staff
will continue to work with you as part of the NEPA/Section 404 Merger Team process Should
you have any questions concerning these comments, please feel free to contact him at
Militscher chns(u,epa gov or [phone] or (404) 562 -9512 Thank you
Sincerely,
Heinz J Mueller
Chief, NEPA Program Office
w /Attachment
Cc S McClendon USACE
B Wrenn, NCDWQ