20161268_Alternatives Report_20120517

LEAST ENVIRONMENTALLY DAMAGING
PRACTICABLE ALTERNATIVE
PROPOSED SR 1 409 (MILITARY CUTOFF ROAD) EXTENSION
AND PROPOSED US 1 7 HAMPSTEAD BYPASS
NEW HANOVER AND PENDER COUNTIES
STATE PROJECT 401 91 1 2
NCDOT TIP PROJECTS U 4751 AND R 3300
CORPS ACTION ID 2007 1 3B6
MAY 17, 2012AT900AM
NORTH CAROLINA DEPARTMENT OF TRANSPORTATION
STRUCTURES CONFERENCE ROOM, NCDOT CENTURY CENTER BUILDING A
1 000 BIRCH RIDGE DRIVE, RALEIGH, NC 2761 0
Prepared 13}
MulkeS Engineers and Consultants
6750 Tn on Road Car} NC 27518
919 8:)11912

SECTION 404/N EPA INTERAGENCY AGREEMENT
CONCURRENCE POINT NO 3
LEAST ENVIRONMENTALLY DAMAGING PRACTICABLE
ALTERNATIVE (LEDPA)
PROJECT TITLE AND PROJECT NUMBERS
Proposed SR 1409 (Mihtar� Cutoff Road) Extension and Proposed US 17 Hampstead B� pass New
Hanover and Pender Counties
TIP Nos U 4751 (Mihtai) Cutoff Road Extension) and R 3300 (Hampstead B3 pass)
State Project No 40191 12 Corps Action ID 2007 1386
PURPOSE AND NEED OF THE PROPOSED ACTION
The purpose of the US 17 Corridor Study is to improve the traffic carrying capacity and safety of the
US 17 and Market Street corridor in the project area
LEAST ENVIRONMENTALLY DAMAGING PRACTICABLE ALTERNATIVE (LEDPA)
1 Alternative M 1 + E H ❑ Yes ❑ No 4 Alternative M 1 + U ❑ Yes ❑ No
2 Alternative M2 +0 ❑ Yes ❑ No 5 Alternative M2 +U ❑ Yes ❑ No
3 Alternative M1 +R ❑ Yes ❑ No
The project team has concurred on the LEDPA for the proposed project as hsted above
NAME AGENCY DATE
USACE
USEPA
USFWS
NMF
NCDCM
NCSHPO
NCDMF
NCDWQ
NCWRC
NCDOT
\VMPO

TABLE OF CONTENTS
Meeting Agenda u
10 Introduction and Project Description 1
1 1
Purpose of Toda) s Meeting 1
12
Project Descuption 1
13
Purpose of the Proposed Action 1
14
Project Status 1
2 0 Detailed
Study Alternatives 2
21
Hampstead B) pass Alternatives 2
52
21 1 Alternative E H 2
8
2 1 2 Alternati-, e 0 3
Gamelands and Preser-, ation Areas
2 1 3 Alternative R 3
54
2 1 4 Alternau, e U 4
22
Mihtar� Cutoff Road Extension Alternati-, es 5
Water Supply Wells
2 2 1 Alternative M1 5
222 Alternati-, e M2 5
3 0 Hydraulic Recommendations 6
4 0 Corridor Public Hearings & Agency Comments on the DEIS 6
41
Public Hearings
6
42
Agenc) Comments on the DEIS
7
50 Environmental
Evaluation
8
5 1
Streams Ponds and Wetlands
8
52
Historic Arclitectural Resources
8
53
Gamelands and Preser-, ation Areas
9
54
Federall) Protected Species
10
55
Water Supply Wells
11
6 0 NCDOT Preferred Alternative 13
Table 1 1 otal Stream Impacts 8
Table 2 Historic Architectural Resource Effects 9
Table 3 Gamelands and Preservation Area Impacts 9
Table 4 Federall) Protected Species Effects 10
Table 5 Summary of CFPUA Wells in the Vicimt) of Military Cutoff Road Extension 12
Table 6 Summary of Current Detailed Stud) Alternatives Impacts 14
Appendix A — Figures
Appendix B — Tables from the DEIS
Appendix C — Agency Comments on the Draft Environmental Impact Statement
Appendix D — Evaluation of Impacts to Public Water Supply Groundwater Wells & Addendum
1

NEPA /Section 404 Merger Meeting
Concurrence Point 3
Proposed SR 1409 (Military Cutoff Road) Extension
and Proposed US 17 Hampstead Bypass
New Hanover and Pender Counties
NCDOT TIP Projects U 4751 and R 3300
j J M
\ State Project 4019112
\4� US Army Corps
Corps Action ID 2007 1386 of Engineers
WAm gton District
May 17 2012
Meeting Agenda
1 Introductions and Sign in
2 Purpose of Meeting
3 Project Review
Oven lew & Project Stltus
Purpose and Need (Concurrence Point 1)
Detailed Stud) Alternatives (Concurrence Point 2)
H5 drauhc Recommendations (Concurrence Point 2a)
Public Involvement Summar}
Comments on the DEIS
Ens ironmental Impacts EN aluation of Detailed Stud} Alternati-, es
4 LEDPA Discussion (Concurrence Point 3)
5 Concurrence on LEDPA
6 Completion of Concurrence Point 3 Signature Form
11

10 INTRODUCTION AND PROJECT DESCRIPTION
11 Purpose of Today s Meeting
'I he purpose of todaj s meeting is to reach concurrence on the Least En-, ironmentallj Damaging
Practicable Alternati-, e (LEDPA) (Concurrence Point 3) Form it concurrence on the LEDPA ,,vill
be requested during this meeting
12 Project Description
State Transportation Improvement Program (S7 IP) projects U 4751 and R 3300 in-, ol-, e the
construction of Military Cutoff Road Extension in New Hano-, er CountS and the US 17
Hampstead B) pass in Nea Hano-, er and Pender Counties respects-, el) These projects are
included in the 2012 2018 STIP
_I�
IIII
For project U 4751 the North Carolina Department of Transportation ( NCDOT) proposes to
extend Mshtar5 Cutoff Road -is a six lane divided roadway on new location from its current
terminus at US 17 (Market Street) in Wilmington north to an interchange with the US 17
Wilmington Bypass (John Jai Burne3 Jr Freewal) Limited and full control of access is proposed
For project R 3300 NCDOT proposes to construct the US 17 Hampstead B) pass as a freeway on
new location The US 17 Hampstead B) pass may connect to the proposed Military Cutoff Road
Extension at the existing US 17 Wilmington B5 pass and extend to existing US 17 north of
Hampstead Full control of access is proposed for the US 17 Hampstead B) pass The project area
is shown in Figure 1 in Appendix A
Project U 4751 is programmed for right of way acquisition in State Fiscal Year (FY) 2014 with
construction in FY 2017 Project R 3300 is programmed for right of waj acquisition in 2017
Construction of R 3300 is not currend) funded Current anticipated costs -, arj b5 alternati-, e and
range from $356 2 million to $404 8 million
13 Purpose of the Proposed Action
The purpose of the US 17 Corridor Stud) project is to improve the traffic carr) ing capacity and
safety of the US 17 and Market Street corridor in the project area
14 Project Status
The Section 404 /NEPA Merger l earn for the US 17 Corridor Stud) agreed on the purpose of and
need for the project at their September 21 2006 meeting
The NEPA /Section 404 Merger Team reviewed project alternatives at three meetings between
February 2007 and August 2007 During these meetings the merger team dropped alternatives
from further consideration added alternati-, es for evaluation and combined some alternatiN es
The merger team concurred on alternatives to be studied in detail at their August 23 2007 meeting
The current detailed study alternatives are reviewed in Section 2 0
_I�
IIII

1 he NEPA /Section 404 Merger 1 eam reached concurrence on Bridging and Alignment Re-, iew
(CP 2a) on M i) 27 2010 A summary of H) drauhc Recommendations for the proposed project is '
included in Section 3 0
The US 17 Corridor Stud) Draft EnN ironmental Impact Stltement (DEIS) was signed on Jul) 28
2011 Comments recei-% ed on the DEIS and during the public hearing comment period are
summarized in Section 4 0
The NEPA /Section 404 Merger Team met on December 15 2011to rex iew the project status
discuss comments on the DEIS and to identify any additional information needed prior to the
selection of the LEDPA
20 DETAILED STUDY ALTERNATIVES
There are four ne« location build alternati-, es for the Hampstead B) pass (R 3300) and two new
location build altern iti-\ es for Mihtary Cutoff Road Extension (U 4751) still under consideration
The current detailed stud) altern itt-, es for Hampstead B) pass include E H O R and U (see
Section 2 1) The current detailed stud) alternati-, es for Mihtary Cutoff Road Extension include
M1 and M2 (see Section 2 2) The current detailed stud) alternatives are shown in DEIS Figure 9
and Figures 10A through 10K included in Appendix A T) pical sections are shown in DEIS
Figures 11 and 12 in Appendix A
As a result of comments received during the public hearing process modifications to the
northernmost Hampstead B) pass interchange design are being eN aluated and ma) be implemented
during final design It is expected that an) changes would take place within the existing corridor
alternati-,es Re-, isions to the northernmost Hampstead B) pass interchange would be applicable
for all alternatives Therefore increases or decreases in impacts to the human and natural
en-, ironments would be the same for each of the detailed stud) alternate-, es
As a result of comments received during the DEIS re-, iew Militar) Cutoff Road Extension
Alternatives M2 and M2 were shifted within the project stud) corridors to aN old impacts to Cape
Fear Public UtihtS Authority wells
21 Hampstead Bypass Alternatives
2 1 1 ALTERNATIVE E H
Alternati-, e E H begins in New Hano-, er County at a proposed interchange with the US 17
Wilmington B) pass approximatel) midwa) between 140 and Market Street The alternative
extends northwest past Sidbur) Road into Pender County Land use between the bypass and
Sidbury Road is mosd) undeveloped property Alternative E H turns to the northeast and
continues to a proposed interchange with NC 210 east of Island Creek Road
From its interchange at NC 210 Alternate% e E H extends northeast across several minor roads that
include lightly developed residential areas and through undeveloped forested areas Alternatn e E
H crosses Hoo-, er Road north of South Topsail Elementary School and continues northeast
through undo-, eloped property to a proposed interchange with realigned US 17 approximatel) 0 7
mile west of Grand-, iew Dri-, e Alternati-, e E H continues north behind the Topsail School

complex Ind then turns elst to tie into existing US 17 near Leeward L-ine Alternati-, e E H
continues north on existing US 17 to Sloop Point Loop Road
2 1 2 ALTERNATIVE O
Altern,itiN e O begins in New Hano-, er County at a proposed interchange with the US 17
Wilmington B) pass approximately one mile west of the Market Street interchange It extends
north from the bypass through undeveloped land and crosses Sidbur) Road at the New Hano-, er
Counts /Pender County line The alternative continues north through predominand) unde-, eloped
land to a proposed interchange at NC 210
From its interchange at NC 210 Alternative O extends northeast across several minor roads that
include hghtl) deN eloped residential areas and through undeveloped forested areas It continues
through farmland crosses Hoop er Road north of South Topsail Elementary School and continues
northeast through undeveloped propert) to a proposed interchange with realigned US 17
approximately 0 7 mile west of Grand-, iew Drip e Alternative O continues north behind the
Topsail School complex and then turns east to tie into existing US 17 near Leeward Lane
Alternative O continues north on existing US 17 to Sloop Point Loop Road
Access and Right of Way Alternatives E H, O and R
Full control of access is proposed for Hampstead Bypass For Alternatives E H O and R access
is proposed at interchanges with the US 17 Wilmington Bypass NC 210 and existing US 17
approximatel) 0 7 mile west of GrandN iew Drn e Interchange locations are shown on Figure 9 A
variable right of wa) width of 200 feet to 350 feet is proposed for Hampstead B) pass Alternatil es
EH OandR
2 1 3 ALTERNATIVE R
Alternative R begins in New Hano-, er County at an interchange with the US 17 Wilmington
B3 pass approximately midwa) between I 40 and Market Street Alternate' e R extends northeast
from the b3 pass across unde-, eloped land and crosses Sidbury Road at the New Hano-, er
County /Pender County line The alternative continues north through predominand) undeveloped
land to an interchange at NC 210
From its interchange at NC 210 Alternative R crosses Hoover Road north of South Topsail
Elementary School and continues northeast through undeN eloped property to a proposed
interch -inge with realigned US 17 approximatel) 0 7 mile west of Grand-, iew DriN e AlternatiN e R
continues north behind the Topsail School complex and then turns east to tie into existing US 17
near Leeward Lane Alternative R continues north on existing US 17 to Sloop Point Loop Road
Typical Sections Alternatives E H, O and R
From the proposed intenhaiage at the US 17 1Vilmangton Bypars to the propo red anterchange at NC 210 Six 12
foot lanes (three in each direction) with 14 foot outside shoulders (12 foot pa-, ed) A 46 foot
median is proposed
From the proposed interchange at NC 210 to existing US 17 Four 12 foot lanes (two in each direction)
with 14 foot outside shoulders (12 foot paved) A 46 foot median is proposed
Access and Right of Way Alternatives E H, O and R
Full control of access is proposed for Hampstead Bypass For Alternatives E H O and R access
is proposed at interchanges with the US 17 Wilmington Bypass NC 210 and existing US 17
approximatel) 0 7 mile west of GrandN iew Drn e Interchange locations are shown on Figure 9 A
variable right of wa) width of 200 feet to 350 feet is proposed for Hampstead B) pass Alternatil es
EH OandR

2 1 4 ALTERNATIVE U
Alternati-, e U begins in New Hano-, er Count) at a proposed interchange with the US 17
Wilmington B) pass The interchange location will -, an depending on the selected preferred
Mihtar- Cutoff Road Extension altern -an e (1\41 or M2) Altern itt-, e U follows the Wilmington
B) pass through the existing interchange at Market Street 1 he alternative runs along existing
US 17 to n pioposed interchange with realigned Sidbur) Road Alternati-, e U continues north on
existing US 17 for approximatel} two miles to where it transitions to new location at a proposed
interchange with existing US 17 AlternatiN e U continues north on new location to intersect with
NC 210 at a proposed interchange approximatel) 0 5 mile west of existing US 17
From its interchange at NC 210 Alterniti-% e U continues north parallel to existing US 17 and
crosses Hoo-, er Road south of South Topsail Elementary School the ilternatiN e continues
northe,ist through unde-, eloped property to a proposed interchange with realigned US 17
approximately 0 5 mule west of Grandview Drip e Alternati-, e U continues north behind the
Topsail School complex and then turns east to tie into existing US 17 near Leeward Lane
Alternati-, e U continues north on existing US 17 to Sloop Point Loop Road
Typical Sections Alternatives U
Fro1v the proposed interchange at the US 77 lYliln7angton Byparr to the proposed interchange With existing US 77
youth ofHainprtead Ten 12 foot lanes (fi-, e in each direction) with 14 foot outside shoulders (12
foot paved) A 22 foot median with ten foot inside shoulders and a two foot concrete barrier is
proposed
Se-, eral considerations factored into the proposed t) pical section for this segment of Alternati-, e U
Year 2035 traffic projections for Alternati-, e U in this area are comparable to traffic found
on the busiest roads in the most populated areas in North Carolina including Charlotte
and Raleigh
Traffic anal) ses show that the number of lines required between the proposed interchange
with the US 17 Wilmington B) pass and the proposed interchange at NC 210 are higher for
Alternative U than for Alternati-, es E H O and R between the same points This is
because Alternatives E H O and R provide northbound traN elers the option of either
using the proposed H- impstead B) pass or existing US 17 while all traffic is directed along
one route with AlternatiN e U More lanes are required to process this increased traffic on
Alternative U
US 17 Wilmington B) pass and existing US 17 each with four lanes and poor traffic sen ice
come together along this section of Alternate-, e U With their combined traffic and an
additional 70 000 cars ten lanes are needed to accommodate projected 2035 traffic
volumes
NCDOT proposes a freeway facility with full control of access for the Hampstead Bypass
because in addition to increasing safety it would pro-, ide greater benefit in terms of traffic
sern ice than the partial or open control of access options An expresswa) or non freewa)
option with direct access from the b) pass to adjacent properties would require 14 travel
lanes to provide adequate traffic carrying capacity The signals required for an expresswa)
4

reduce the capacitj from approximately 2 200 passenger cars per hour foi a freeway lane to
' approximately 450 -, ehicles per hour for an expressway lane In addition there would be
dri-, er expectanc3 and safet) concerns associated with the Hampstead B) pass making the
transition from a freewa) to a 14 lane expressway with signalization and turning
' mop ements and back to a freeway
• Where Alternati-, e U trap els along existing US 17 a frontage road s) stem is needed in
addition to the main tra-, el lanes to provide access to adjacent properties Senn ice roads
' would provide access to businesses residences and community facilities along existing
US 17 between the existing interchange with US 17 Wilmington B5 pass and the proposed
interchange with existing US 17 where Hampstead Bypass transitions to new location
' Utilizing service roads minimizes impacts by reducing relocations and right of wa) costs
From the proposed interchange wth eYistang US 17 ronth of Hampstead to the proposed interchange atNC210
' Six 12 foot lanes (three in each direction) with 14 foot outside shoulders (12 foot pa-, ed) A 46
foot median is proposed
From the proposed interchange at NC 210 north to exastiiig US 17 Four 12 foot lanes (two in each
direction) with 14 foot outside shoulders (12 foot paved) in each direction and a 46 foot median
Access and Right of Way Alternative U
For Alternative U access is proposed at interchanges with the US 17 Wilmington B) pass the
existing US 17 Wilmington B3 pass interchange at Market Street Sidbur} Road the proposed
interchange with existing US 17 where Hampstead Bypass transitions to new location south of
Hampstead NC 210 and existing US 17 approximatel) 0 5 mile west of Grandview Drive To
pro -, ide access to adjacent properties service roads are proposed for the sections of Alternati-% e U
that travel along existing US 17 from Market Street to where Hampstead Bypass transitions to new
location A -, ariable right of wa3 width of 200 feet to 520 feet is proposed for Alternatil e U
22 Military Cutoff Road Extension Alternatives
Military Cutoff Road Extension Alternatives M1 and M2 are new location alternati-, es extending
Military Cutoff Road from Market Street to the US 17 Wilmington Bypass
2 2 1 ALTERNATIVE M 1
Alternati-, e M1 begins at a proposed interchange at Military Cutoff Road and Market Street The
alternative extends north through vacant County property between the two sections of Ogden
Park and residential areas Alternative M1 turns northwest and ends near Plantation Road and
Crooked Pine Road at a proposed interchange with the US 17 Wilmington B) pass approaimatel)
midway between 1 40 and Market Street
2 2 2 ALTERNATIVE M2
Alternative M2 begins at a proposed interchange at Military Cutoff Road and Market Street
Alternative M2 follows the Alternative M1 alignment for approximately two miles Alternative M2
then turns northeast and extends through mostly undeveloped property to a proposed interchange
with the US 17 Wilmington B) pass approximately one mile west of Market Street
5

Typical Sections Alternatives M1 and M2
From thepropored anteic ban
ge at Market Sticet to applovzmat(ly 0 9 mzle north of Torchn)ood Boidevard Six
lanes (three in each direction) with a 30 foot median and curb and gutter Iwo 12 foot inside lanes
and one 14 foot outside lane (to accommodate bic) cles) with two foot curb Ind gutter and a ten
foot berm are proposed in each direction
From approyilvately 0 9 wile north of Torch;vood Boulevard to the propoced antenhangc at the US 17 ld /ilmington
Bypacc Sig. 12 foot lanes (three in each direction) with 14 foot outside shoulders (12 foot pa-, ed)
A 46 foot median is proposed
1 he Wilmington Metropolitan Planning Organization (MPO) has requested a multi use path be
constructed along proposed Mihtar) Cutoff Road Extension The multi use path would tie into an
existing multi use path along Mihtar5 Cutoff Road The construction of a multi use path as part of
the proposed project will be dependent upon a cost sharing and maintenance agreement between
the NCDOT and the Wilmington MPO The NCDOT will continue to coordinate with the
Wilmington MPO on the inclusion of the multi use path along Mihtar} Cutoff Road Extension
Access and Right of Way Alternatives M1 and M2
Mihtar5 Cutoff Road Extension is proposed as a full/limited control of access facility Access to
Mthtar5 Cutoff Road Extension is proposed at interchanges at Market Street and Militar) Cutoff
Road and the US 17 Wilmington B} pass Additional access along Military Cutoff Road Extension
is proposed at directional crosso-, ers with Putnam Dri-, e Lendire Road and Torchwood
Boulei and Onl) right turns will be pertrutted onto Mihtar} Cutoff Road Extension from these
roads U turn lanes will be provided to accommodate left turns A -, ariable right of wa3 width of
150 feet to 350 feet is proposed for Military Cutoff Road Extension
30 HYDRAULIC RECOMMENDATIONS
Table 2 5 from the DEIS in Appendix B lists the proposed major h3 drauhc structures for the
current detailed study alternatives The NEPA /Section 404 merger team concurred on the size
and location of the structures on May 26 and 27 2010 The locations of the structures are shown
on DEIS Figure 10A in Appendix A
40 CORRIDOR PUBLIC HEARINGS & AGENCY COMMENTS ON THE DEIS
41 Public Hearings
Two Corridor Public Hearings were held for the project
Monda) October 17 2011 at Noble Middle School in Wilmington 118 citizens registered
their attendance at the meeting
Tuesday October 18 2011 at Topsail High School in Hampstead 266 citizens registered their
attendance at this meeting
Fifteen individuals pro-, ided verbal comments after the formal presentations As of November 28

2011 a total of 92 written comments ha-, e been recen ed Twenty two of the written comments
' submitted included concerns related to Military Cutoff Road Extension I he remainder of the
written comments pertained to Hampstead B) pass Most of those comments were related to the
location of the northernmost interchange for the Hampstead B) pass Most commented that the
' lack of direct access to existing US 17 from Hampstead B) pass at the northern end of the project
is unacceptable
' The public hearing comment form pro-, ided the opportunity for commenters to rank the order of
their corridor preference(s) from among the five Current Detailed Study Alternati-, es Se-, eral
respondents stated their preferred alternate-, e(s) within their written comments instead of
' numbering the alternate-\ es on the comment form Preference by alternatiN e as indicated by
commenters is shown below
' Alternative 1 ` Choice 2 "d Choice 3 d Choice 4" Choice 5`h Choice
M1 +E H 15 1 2 1
M2 +0 15 3 4
M1 +R 11 4 1 1
M1 +U 5 2 3
M2 +U 10 3 2
42 Agency Comments on the DEIS
Comments on the DEIS from federal and state agencies are included in Appendix C Information
pertaining to these comments was discussed at the December 15 2011 US 17 Corridor Stud) CP3
informational meeting
In their comments on the DEIS EPA requested that several of their concerns be addressed prior
to the selection of the Least Environmentally Damaging Practicable Alternative A cop) of
NCDOT s responses to EPA s comments on the DEIS was distributed to the merger team on
March 1 2012 (see Appendix C)
At the December 15 2011 CP3 informational meeting the merger team requested additional
information on potential public water supply impacts prior to LEDPA concurrence In response
to the request supplemental information was pro-, ided to the merger team on February 9 2012 in
a report titled Evaluation of Impacts to Public Water Supply Groundwater Wells US 17 Corridor
Stud) NCDOT Projects U 4751 & R 3300 (Evaluation) EPA proi ided comments on the
E-, aluation on February 28 2012 A cop) of the E-, aluation and EPA s comments are included in
Appendix D An addendum to the E-, aluation addressing EPA s comments is also included in
Appendix D
At the December 15" meeting the merger team requested additional information on stormwater
pond permits and stream quality information DEIS Tables 4 11 and 4 13 have been updated to
include this information (see Appendix B)

50 ENVIRONMENTAL EVALUATION
DEIS Figures 10A through 10K in Appendtn A show en-, ironmental features in the project area
A summary of potential en-, ironmental impacts is pro-, ided in 1 able 6 on page 14 Details of
impacts to jurisdictional resources historic architectural resources gameland and presen ation
areas federall) protected species and water suppl) wells are described below Ri-, er Basin
boundaries the Cape fear Public Utility Authority s (CI,PUA) Wellhead Protection Area and
CFPUA water supply well locations in the project area ha-, e been added to Figure 10
51 Streams, Ponds and Wetlands
\Niter resources in the stud) aiea are part of the Cape rear and Onslow Bay Re er Basins (U S
Geological Sun e) [USG S] H) drologic Units 03030007 and 03020302) A total of D8 jurisdictional
streams 17 ponds and 107 jurisdictional wetlands are located within the current detailed stud)
alternatt-, es stud) corridors
Impacts to W hers of the U S would occur at x arious locations throughout the length of the
project at stream crossings wetland areas and ponds Anticipated impacts b) t) pe of stream are
presented for the detailed stud) alternates es in 1 able 1 Total stream wetland and pond impacts
for each alternatt-, e are shown in 1 able 6 on page 14 Anticipated impacts for each stream pond
and wetland are presented for the detailed stud) alternati,, es in DEIS Tables 4 11 4 13 and 4 15
located in Appendix B
Table 1 Total Stream Impacts
Delineated Stream
Impacts (linear feet)
Alternative
M1 +EH
M2 +0
M1 +R
M1 +U
M2 +U
Perennial
17 227
10 776
17 874
10 995
6 977
Intermittent
3 487
1 346
2 553
997
486
Other'
2 784
737
3 111
2 425
340
Total
23,498
1 12,859
23,538
14,417
1 7,803
i Tributary waters determined to be jurisdictional based on the presence of an ordinary high water mark
(OHWAI) These waters are classified as Waters of the US (impacts calculated in sq ft) and will not require
compensator} mitigation
52 Historic Architectural Resources
There is one propert) within the Area of Potential Effect listed on the National Register of
Historic Places and four properties eligible for listing The potential effect of the proposed project
on historic architectural resources is summarized by alternate e in Table 2 The State Historic
Preservation Office concurred with effect determinations at a meeting held on March 8 2011
Avoidance and minimization measures have been incorporated into the design at Poplar Grove
Mount Ararat AME Church Wesle) an Chapel United Methodist Church and Scotts Hill
Rosenwald School The State Historic Presen ation Office re-, iewed the avoidance and

mtnurruzation measures on December 13 2011 and re-, ised the effects determtnitton at Scotts Hill
Rosenwald School from Ad-, erse Effect to No Ad-, else Effect
Table 2 Historic Architectural Resource Effects
53 Gamelands and Preservation Areas
All of the detailed stud) alternatives will impact presen ation areas as shown in Table 3 below
Table 3 Gamelands and Preservation Area Impacts
Gamelands and Preservation
Area Impacts (acres)'
Alternative
M1 +EH
M2 +0
M1 +R
M1 +U
M2 +U
Historic Property
058
No
No
No
Ad-, erse
Ad-, erse
Poplar Grove
l,ffect
Effect
Effect
Effect
Effect
030
Ad-, erse
Ad-, erse
Adverse
Adverse
Ad-, erse
Mount Ararat AME Church
Effect
Effect
Effect
Effect
Effect
Wesle) an Chapel United Methodist
No
No
No
Adverse
Adverse
Church
l,ffect
Effect
Effect
Effect
Effect
No
No
No
No
No
Ad-, erse
Adverse
Scotts Hill Rosenwald School
Effect
Effect
Effect
Effect
Effect
No
No
No
No
No
Topsail Consolidated School
Effect
Effect
Effect
Effect
Effect
53 Gamelands and Preservation Areas
All of the detailed stud) alternatives will impact presen ation areas as shown in Table 3 below
Table 3 Gamelands and Preservation Area Impacts
Gamelands and Preservation
Area Impacts (acres)'
Alternative
M1 +EH
M2 +0
M1 +R
M1 +U
M2 +U
Corbett Tract Mitigation Site
058
000
058
008
000
Corbett Tract Residual Strip
355
027
355
285
000
Plantation Road Site
030
1328
030
031
2203
34 Acre Residual Site
000
2881
000
000
1237
Blake Savannah
000
058
058
000
000
TOTAL
443
4294
501
324
3440
I The project does not affect Holly Shelter Game Land or the 22 acre Residual 5nte in the vncnnnt5 of the US 17
Wilmington Bypass
9

54 Federally Protected Species
As of September 22 2010 the U S Fish Ind Wildlife Seri ice (USFWS) lists 11 feder -ill) protected
species for New Hano-, er Count) -nd 12 federally protected species for Pender Counts Table 4
summarizes the federall) protected species listed for New Hano-, er and Pender Counties 'Ind the
biological conclusion for this projects likely effect on each species
Table 4 hedeiall) Protected Species Effects
Scientific
Common
Federal
Biological
Name
Name
Status
County
Conclusion
Alternatives
Alligator
American
T(S/A)
New Hano,, er
Not Required
9
mcuru zensii
alligator
Pender
C /�elonza n�dai
Green sea
New H1nox er
No Effect
turtle
Pender
Caretta caretta
I oggerhead
T
New Hano-, er
No Effect
sea turtle
Pender
Cbaradnur
New Hanover
melodur
Piping ploy er
T
Pender
No Effect
Puoider borealis
Red cockaded
E
New Hanover
May Affect Likel)
E H O R U
woodpecker
Pender
to Adx erselt Affect
Aczpenrer
Shortnose
New Hanover
brevamstnim
sturgeon
E
Pender
No Effect
Tntbecbus
West Indian
New Hano-, er
E
No Effect
manatur
manatee
Pender
Scbwalbea
American
amencana
chaffseed*
E
Pender
No Effect
Tbahanim
Coole) s
New Hano -, er
Ma) Affect Likel)
cooly a
meadowrue
E
Pender
to Adversel Affect
O R
Carex lutea
Golden sedge
E
New Hanover **
Ma) Affect Likel)
O R
Pender
to Adx ersel Affect
Lyszmacbia
Rough leaved
E
New Hanover
May Affect Likel)
E H O R U
a endae olia
loosestrife
Pender
to Adx ersel Affect
M1 M2
Amarantbus
Seabeach
New Hano -, er
umdus
amaranth
T
I
Pender
No Effect
E — Endangered T — Threatened T(S/ A) Threatened due to Similarity of Appearance
* Historic record (the species was last observed in the county more than 50 ) ears ago)
" Listed as Probable /Potential
Protected species surveys will be updated in the spring of 2012 The USFWS has indicated the
biological conclusion for golden sedge remains to be determined If additional and appropriatel)
timed sun e) s do not re-, eal an) specimens of golden sedge the USFWS has noted the) would
concur with a 'no effect" conclusion for this species NCDOT will continue to coordinate with
the US Fish and Wildlife Sen ice on red cockaded woodpecker Cooley s meadowrue golden
sedge and rough lea-, ed loosestrife The handouts from the December 15 2011 CP3
informational meeting showing the location of known occurrences of Coole) s meadowrue and
rough leaved loosestrife are included in Appendix A
10

The CFPUA developed a Wellhead Protection Plan (WHPP) in coordination with the
NC Department of EnN ironment and Natural Resources Public Water Suppl) (PWS) Section
The CFPUA s WHPP is non regulatory and identifies strategies to manage the wellhead protection
area for their northern water s) stem Existing state rules and regulations are relied on to menage
risks associated with transportation infrastructure located within wellhead protection areas
managed through the non regulatory approach
The proposed project is not expected to result in imp icts to CFPUA s groundwater water suppl)
wells Impacts to the availability of the water suppl) are not anticipated as a result of the proposed
project The project is not expected to decrease the capacit) of the existing and planned water
suppl) infrastructure or the source aquifers
The NCDENR PWS Section has expressed the opinion and the CFPUA has agreed there are no
design elements such as hazardous spill catch basins that need to be added to the project The
PWS Section recommended that NCDOT assist with providing training to first responders in
dealing with hazardous materials spills in the wellhead protection area Prior to the completion of
the final en-N ironmental document for the project NCDO1 will meet with the CFPUA local fire
departments and other appropriate agencies to discuss additional protection measures for the
wellhead protection area Measures requiring NCDOT participation will be identified in the
project commitments
11
55 Water Supply Wells
The Cape Fear Public Uttht) Authority (CFPUA) has se-, eral existing and proposed well sites
associated with their groundwater nanofiltration water treatment plant (W`1 P) The Wl P is
'
located adj -icent to proposed Mihtar) Cutoff Road Extension Alternate-, es M1 and M2 where they
shire an alignment north of Torchwood Boulevard
just
At the time of completion of the DEIS for the project it was expected that Alternate e M1 would
'
cross two CFPUA well sites and Alternate e M2 would cross four existing well sites and a
proposed well site The alignments of both Alternate es M1 and M2 have been modified since
completion of the DEIS Neither alternatii e will cross any existing or future CFPUA well sites
'
Both Mihtar) Cutoff Road Extension alternatt-\ es would cross potable and raw water lines An)
impacted watei lines would be relocated as part of the project and returned to sern ice NCDOT
will coordinate with CFPUA on utility impacts resulting from the proposed project
Re-, isions to the Mil tar) Cutoff Road Extension design to a-, old the wells reduced the project s
wedand and stream impacts Three additional residential displacements and -►n additional three
acres of forested area impacts will result from the design shift for both AlternatiN es M1 and M2 A
Design Noise Report noting an) changes in proposed noise wall locations will be prepared for the
selected alternative A detailed evaluation of impacts to the public water suppl) wells is included in
Appendix D
Regulations for public water supply wells stipulate thlt the area within 100 feet of a well be owned
or controlled b) the person suppl) ing the water (15A NCAC 18C 0203) Mihtary Cutoff Road
Extension will be located a minimum of 100 feet away from existing wellheads and in most cases
much greater distances (see Table 5)
The CFPUA developed a Wellhead Protection Plan (WHPP) in coordination with the
NC Department of EnN ironment and Natural Resources Public Water Suppl) (PWS) Section
The CFPUA s WHPP is non regulatory and identifies strategies to manage the wellhead protection
area for their northern water s) stem Existing state rules and regulations are relied on to menage
risks associated with transportation infrastructure located within wellhead protection areas
managed through the non regulatory approach
The proposed project is not expected to result in imp icts to CFPUA s groundwater water suppl)
wells Impacts to the availability of the water suppl) are not anticipated as a result of the proposed
project The project is not expected to decrease the capacit) of the existing and planned water
suppl) infrastructure or the source aquifers
The NCDENR PWS Section has expressed the opinion and the CFPUA has agreed there are no
design elements such as hazardous spill catch basins that need to be added to the project The
PWS Section recommended that NCDOT assist with providing training to first responders in
dealing with hazardous materials spills in the wellhead protection area Prior to the completion of
the final en-N ironmental document for the project NCDO1 will meet with the CFPUA local fire
departments and other appropriate agencies to discuss additional protection measures for the
wellhead protection area Measures requiring NCDOT participation will be identified in the
project commitments
11

Table 5 Summary of CFPUA Wells to the Vicintt� of Nhhtar} Cutoff Road Extension
12
Well
WHPP
Closest
Distance from
Distance from
Well
Well
Depth
Aquifer,
Radius
Yield
MCRE
Wellhead to
Wellhead to
Site
ID
(ft)
(ft)
(gpm)
Alternative
MCRE Slope
MCRE Right of
Stake Limits (ft)
Way Limits (ft )
P
8
160
Peedee
2000
600
M1 M2
807
776
Q
16
175
Peedee
3 000
X00
M1 M2
1 936
1 938
B
22
170
Peedee
3 000
900
M1 M2
126
118
A
23
170
Peedee
3 000
1 000
M1 M2
1 762
1 749
M
28
175
Peedee
2000
750
M1 M2
568
524
N
29
175
Peedee
2000
750
M1 M2
797
764
O
30
175
Peedee
2000
X70
M1 M2
1 006
974
Castle
A
A CH
95
2 965
600
M1 M2
1 654
1 641
Has ne
Castle
B
B CH
80
3 097
640
M1 M2
134
123
Hal ne
Castle
C
C CH
105
2 406
600
M2
1 402
1 333
Hay ne
C
C PD
168
Peedee
3 000
X70
M2
1 379
1 309
Castle
F
F CH
105
2 273
600
M2
764
727
Ha} ne
F
F PD
170
Peedee
3 000
X70
M2
770
744
Castle
G
G CH
90
2 440
500
M2
523
471
Ha) ne
G
G PD
173
Peedee
3 000
570
M2
546
494
Castle
H
H CH
100
2 471
600
M2
184
152
Hai ne
H
H PD
175
Peedee
3 000
570
M2
160
128
Castle
I
I CH
95
2206
400
M2
2 109
2095
Hayne
I
I PD
175
Peedee
3 000
570
M2
2081
2067
Castle
J
J CH
100
2 493
600
M2
546
521
Ha) ne
J
J PD
175
Peedee
3 000
570
M2
573
548
Castle
•
K CH
100
2 713
200
M1 M2
1 334
1 304
Ha) ne
•
K PD
175
Peedee
3 000
600
M1 M2
1 272
1 241
Castle
L
L CH
85
3 054
500
M2
805
784
Ha) ne
L
L PD
170
Peedee
3 000
640
M2
789
763
12

11
1 he NCDENR PWS Section has indicated it would be beneficial to include signige to make the
' public aware the) are tra-, cling through a water suppl) area NCDOT will coordinate with the
Cape Fe1r Public Utility Authority on the potential inclusion of a sign on Mihtar) Cutoff Road
Extension The Emergent) Management Coordinator for CFPUA indicated th'it if there is a spill
' or potential contamination incident in the protected area the appropriate response is to call 911 or
the 24 hour CFPUA emergent) number
' Well locations and a 100 foot buffer around the wells will be depicted on final constructions plans
for Military Cutoff Road Extension The Special Provisions within the final design plans will
include a requirement for the contractor s to educate their emplo) ees that project construction is
' occurring within a wellhead protection area
' 6 o NCDOT PREFERRED ALTERNATIVE
NCD01 recommends Alternatix e M1 +E H for the proposed Militar) Cutoff Road E \tension
(U 4751) and Hampstead Bypass (R 3300) project NCDOT has selected Altern-an e Ml +E H as
' the preferred alternative for the following reasons
• Alternati-, e Ml +E H is expected to ha-, e the fewest impacts to federall) protected species
Coole) s meadowrue stems were found in very close proximity to the right of way for
Alternati-, es M2 +0 and M1 +R A number of rough lea-\ ed loosestrife stems were found
within the right of wa) for Military Cutoff Road Extension Alternative M2 which would affect
Alternatives M2 +0 and M2 +U
• Alternati-, e Ml +E H would have fewer impacts to preservation areas than Alternatives
M2 +0 M2 +U and M1 +R
• Alternatives M1 +U and M2 +U are not recommended because the) have more residential and
business relocations greater noise impacts greater impacts to cultural resources more impacts
to High Quahty Waters and greater total costs than Alternatives M1 +E H M2 +0 and M1 +R
• Alternate-, e M2 +0 is not recommended because it has more impacts to federally protected
species proposed future CFPUA water suppl) infrastructure wetlands ponds and
preservation areas
• Alternati-, e M1 +E H has fewer wetland pond and stream impacts than Alternatil e Ml +R
• AlternatiN e Ml +E H impro-, es the tr -iffic carry ing capacity and safety of the US 17 and Market
Street corridor in the project area
t
In addition to the detailed impacts presented in Tables 1 through 4 and in the tables included in
Appendix B a summary of Current Detailed Study Alternatives impacts is presented in Table 6
1 13
1

Table 6 Summar} of Current Detailed Stud) Alternati-, es Implcts
Current Detailed Study Alternatives
Alternati-, c
M1 ±E H
M2 +0
M1 +11
M1 +U
M2 +U
Military Cutoff Road Ett Segment
--
Segment Nest of NC 210
Segment East of NC 210
—_
FEATURE'
Length miles
17 5
166
171 3
18 s
16 8 L
Delineated Wetland Impacts acres
24458 Z
t38'
29588 v
21688
28266 a
Delineated Stream Impacts linear feet
23 498 V
12 8D9—
f-23-5M4'
14 417 3
7 803 (
Delineated Pond Impacts acres
38 y
rlc y
41 3
36
36
Displacements
Y
Residential
64
63
62
969
98 '-
Business
76
76
76 '
91
91'
Non profit
I
01 5
I13
1g 11''
, 11y
Red cockaded Woodpecker Future Potentially
867/
867/
867/
867/
867/
Suitable / Potentially Suitable Habitat acres
739
739
739
739
739
Other Surveyed Federal / State Threatened
and Endangered Species Habitat Present
Yes
Yes
1 Yes
1 es
Yes
Natural Heritage Program SNHA, Managed
v
94
s
y
Areas and Wetland Mitigations Sites acres
443
42
501
324
3440
Prime Farmlands/ Farmlands of Statewide
36B
y
Y
/
Importance acres
58
58
50
�0
Forest acres
s61�2
y 50723
466 97
' 406 97
'456 23
100 Year Floodplain and Floodway
'�
Y
Impacts(acres)
e1
88
88
30
30
Historic Properties no
L
Noise Receptor Impacts
3 257
1 236
248
sCno
y 304
Recorded Archaeological Sites no
0
0
0
y6)
L 93
Wildlife Ref i s /Game Lands acres
0
0
0
0
0
Recreational Areas /Parks no
0
0
0
0
0
High Quality Waters (HQW, ORW, WS
' 19
9 19
9 19
g 1
11-9
Protected or Critical Areas acres
Public Water Supply Wells 100' Buffer
0
0
0
0
0
Cemeteries no
( 2
2
2
61
Potential UST / Hazmat Sites no
4
4
4
4
4
Total Cost (in millions )
$362 0
-$3593
$3562
f 40 Z$
y $398 4
Notes 'Impact calculations are based on prelurnnar} design slope stake limits plus an additional 25 feet
14

Appendix A
Figures

77'� 40
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so
P E N,&
ii
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VICINITY
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Sidbury
Figure 1
PROJECT VICINITY
US 17 Corridor Study
NCDOT TIP Nos. U-4751 and R-3300
New Hanover and Pender Counties
North Carolina
0
I Department of Transportation
OF TR A
Hill
Holly ShelU
70
STUDY CORRIDORS
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Appendix B
Reference Tables
from the DEIS

I able 2 5 Proposed H) drauhc Structures
Site
Wetland
Corridor
Existing
Recommended
No'
Stream ID
ID
Alternative
Structure
Structure
U at M1
1 @12 x8
Retain and Extend
1
ZSB
EWF
U 1t M2
RCBC
Existing Cul-, ert
U it M1
2
KWD
1 @9 a8 RCBC
U at M2
3
BSP
BWI
M1 M2
2 @7 x12 RCBC
4
DWC
1\42
1 @9 a8 RCBC
5
GWA
O R
3 @12 x7 RCBC
Dual 100 Long
6
ISA ISB
IWN
O R
Bridges
7
ISD
IWF
O R
3 @11 x8 RCBC
8
LSC LSCC
L�VD
E H O R
3@48 CM
2 @6 x5 RCBC+
LSCF
E H O R
1 @72 RCP
Retain existing and
10
CSA FSA
add two 1@ 72
U at M1
RCP
11
FSI
E H R
1 @12 x9 RCBC
HBSF
Dual 230 Long
15
HBSH
HBWK
E H
Bridges
Dual 200 Long
16
HBSD(2)
HB`VD
E H
Bridges
17
HSX
HWB
E H
3 @10 x9 RCBC
21
FSA
F\VB
E H R
2 @11 x9 RCBC
22
FSE
FWC
Ell R
2 @12 x7 RCBC
23
LSD
LWI
E H O R
2 @9 x7 RCBC
25
HBSC
HBWF
E H
1 @9 x8 RCBC
B1

v
V
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Table 4 15 Indi-, idual Wetland Impacts
Wetland
Figure
Corridor
Cowardin
Hydrologic
DWQ
Wetland
ID
No
Alternative(s)
Classification'
Classification
Wetland
Impacts
Rating
(acres)
W
BB
10 C
M1 M2
PF04B
Non riparian
27
0 23
BWC
10 C
M1 M2
PFO
Non riparian
2D
018
B \ \/'D
10 C
M1 1\42
PFO
Non riparian
34
171
BWI
10 C
M1 M2
PF01/3/413
Non riparian
34
M1 089
M2 144
C \\7A
10 C
M1 M2
PF03 /4A
Non riparian
34
M1 651
M2 496
10 C
M1 R
]�H R111
CWB
10D
U1�
PSS3 /413
Non riparian
36
M1 12 52
U1 106
CWD
10D
E H R U1
PSS3 /4Bd
Non riparian
36
EH R 7 51
U1 9 82
CWE
10D
EH R U1
PF03 /4Bg
Non riparian
36
E H 36 83
R 36 83
Riparian
U1 23 89
EH R
10C
EH O R U1
2152 O
CWF
10 D
U2
PF03 /413
Non riparian
36
211
U1 7 23
U2 105
EH R013
10 C
EH M2 O
09269
DWC
10 D
PSS3 /4B
Non riparian
36
U1 0 12
R U1 U2
10 E
M2 92 54
U2 77 40
EWF
10 E
U1 U2
PFO
Riparian
14
037
EWH
10 G
U1 U2
PFO
Non riparian
20
118
EWH1
10 G
U1 U2
PFO
Riparian
20
123
EWI
10 G
U1 U2
PFO
Riparian
37
053
EWK
10 G
U1 U2
PSS1C
Non riparian
25
006
M
10 G
U1 U2
PF01C
Ri arian
19
5 26
rF��,VVA
10 C
O 0 67
O U1 U2
PFO
Non riparian
30
U1 0 45
10 D
U2 048
IM

rl
I
Table 4 15 Inds, idual Wetland Impacts Co Iumed
Wetland
ID
Figure
No
Corridor
Alternative(s)
Cowardin
Classification'
Hydrologic
Classification
DWQ
Wetland
Rating
Wetland
Impacts
(acres)
FNVB
10D
E H R
PFO
Riparian
20
501
FWC
10D
10F
E H R
PFO
Non riparian
48
E H 146
R824
Riparian
FWD
10 F
R
PSS3B
Non riparian
28
736
FWF
10 F
E H
PFO
Non riparian
37
689
Ri ariln
FWHB
10 F
E H
PFO
Non riparian
24
004
FWI
10 F
E H
Pro
Non riparian
17
038
FWL
10 F
E H
PFO
Non riparian
19
003
FWY
10D
Ell R
Pro
Non riparian
20
018
GWA
10 F
O R
PLM /PSS
Riparian
61
O 605 R
794
GWC
10 C
10D
10 E
O U1 U2
PFO
Non riparian
32
07581
U1 068
U2 27 17
GNVD
10 E
10 F
O
PFO
Non riparian
32
453
Riparian
HBAA'
10 F
E H
PSS /PFo
Riparian
32
006
HBAB
10 F
E H
PSS /PFO
Non riparian
27
109
HBWD
10 F
E H
PSS /PFO
Riparian
83
114
HBWF
10 F
E H
PEM /PSS
Riparian
32
076
HBWK4
10 F
E H
PFO /PSS
Riparian
83
147
HBWT
10 F
E H
PSS
Non riparian
14
039
HVTB
10H
E H
PFO
Riparian
50
236
HWD
10H
E H
PFO
Non riparian
21
035
HWG
10 H
E H
PFO /PSS
Riparian
15
088
Non riparian
HWH
10H
E H
PFO
Non riparian
26
015
HWH1
10H
L H
PFO
Non riparian
26
009
HWH2
10H
E H
PFO
Non riparian
26
003
HWH3
10 H
E H
PFO
Non riparian
26
007
HWH4
10 H
E H
PFO
Non riparian
26
002
HWHS
10 H
E H
PFO
Non riparian
26
023
HNVY
10 H
E H
PFO
Non riparian
26
023
HWAA`
10 F
E H
PFO
Non riparian
40
1540
Riparian
HWEE
10 F
E H
PFO
Riparian
25
015
HWHH
10 F
F EH
PFO
Non riparian
34
024
li

I able 4 15 IndiN idual Wetland Impacts Cowinared
Wetland
ID
Figure
No
Corridor
Alternative(s)
Cowardm
Classification'
Hydrologic
Classification
DWQ
Wetland
Rating
Wetland
Impacts
(acres)
HWMX
10H
E H
Pro
Non riparian
40
005
IWA
10 H
E H O R
PFO
Riparian
80
003
IWA_MM
10 H
O R
PFO
Non riparian
39
481
IWB
10H
E H O R
Pro
Riparian
25
009
IWC
10H
E H O R
PFO
Riparian
20
013
I \VD
10 H
E H O R
PFO
Non riparian
31
O R 17 43
E 11 18 64
Ri arian
IVT
10H
E H O R
PFO
Non riparian
13
016
I \VF
10 H
O R
Pro
Riparian
69
761
Non riparian
IWHs
10 H
O R
Pro
Non riparian
53
767
M ariln
IWK
10 F
O R
PFO
Riparian
77
730
Non riparian
IWN
10 F
O R
PFO
Riparian
79
489
IWQ
10 F
O R
PFO
Non riparian
7
048
IWT'
10 F
O R
Pro
Non riparian
41
1457
Riparian
IWU
10 F
O R
PFO
Non riparian
13
029
IWV
10 F
O R
Pro
Non riparian
42
481
I\X/'\V
10 F
O R
PFO
Non riparian
45
1038
KWA
101
U1 U2
PFO3 /4B
Non riparian
30
227
KWC
101
U1 U2
PF01 /2C
Non riparian
17
447
KWD
101
U1 U2
PFO4A
Non riparian
26
473
K�VF
101
U1 U2
PFO /PSS
Non riparian
45
601
KWG
101
EH O R U1
U2
PFO1 /2G
Non nparian
43
EHOR
0 D7 U1 U2
288
KWH10
101
U1 U2
PF01 /2C
Non riparian
42
570
KWI
10G
U1 U2
PFO1 /3/4B
Non riparian
49
3218
KWN
10 G
U1 U2
PFO4B
Non riparian
46
2401
KWO
10 G
U1 U2
PFO4B
Non riparian
37
1802
KWS
10I
U1 U2
PFO1 /4B
Non riparian
33
U1 U2 052
LWA
10 H
E H O R
PFO
Riparian
70
013
LWB
10 H
E H O R
PFO
Riparian
72
781
LWD
10H
E H O R
PFO
Riparian
83
586
LWD1
10 H
E H O R
Pro
Riparian
48
008
LWE
10H
E H O R
PFO
Non riparian
29
822
LWG
10H
E H O R
Pro
Non n arian
46
017
LWH
10H
E H O R
PFO
Non riparian
23
020
IC 1

Table 4 15 Indi -,idual Wetland Impacts Continued
B 11
DWQ
Wetland
Wetland
Figure
Corridor
Cowardm
Hydrologic
Wetland
Impacts
ID
No
Alternatives)
Classification'
Classification
Rating
(acres)
LWI
110Ij
E H O R
PFO
Riparian
80
250
LWJ
101
E H O R
Pro
Non riparian
40
526
M\VM(2)
10 H
E H O R
Pro
Riparian
68
270
Non riparian
NVT
10K
E H O R U1
PEM /Pr0
Non riparian
13
002
NWE
10 K
E H O 2 U1
PEM /PFO
Non riparian
12
003
NWF
10K
E H O 2 U1
PEM /PSS
Non riparian
12
004
EHOR
NWJ
10 K
EH O R U1
PSS /PFO
Non ripari in
12
0 02 U1 U2
U2
002
NWK
10 K
U1 U2
PSS
Non riparian
12
002
EHOR
NW1\4
10 K
E H O R U1
PFO
Non riparian
22
0 68 U1 U2
068
NWO
101
EHOR
PFO4
Non riparian
17
311
EHOR
NWP
101
EH O R U1
PSS
Non riparian
17
2913
U2
U1 U2 11 38
ZWJ
10 E
U1 U2
Pro
Non riparian
26
137
ZWK
10L
U1 U2
PEM
Non riparian
16
008
ZWL
10 G
U1 U2
PFO
Non riparian
20
024
ZXXrM
10 G
U1 U2
PFO
Non riparian
20
004
ZWCC
10 K
E H O R U1
PFO
Riparian
28
003
ZWDD
10D
E H R
PFO
Non riparian
26
116
Riparian
PD 01"
10 C
M1 M2
PFO /PSS
Non riparian
N/A
007
PD 03
10 C
M1 M2
PFO /PSS
Non riparian
N/A
721
PD 04
10 C
M1 M2
PFO /PSS
Non riparian
N/A
576
PD 15
101
E H O R U1
PFO /PSS
Non riparian
N/A
048
PD 16
101
E H O R U1
PFO /PSS
Non riparian
N/A
058
EHOR
PD 29
101
EH O R U1
PFO /PSS
Non riparian
N/A
8 58 U1 U2
U2
856
PD 31
10I
E H 02 U1
PFO /PSS
Non riparian
N/A
291
B 11

Table 4 15 Indi-, idual Wetland Imp icts Cozlinued
Wetland
Figure
Corridor
Cowardm
Hydrologic
DWQ
Wetland
ID
No
Alternative(s)
Classification'
Classification
Wetland
Impacts
Rating
(acres)
PD 33
101
E H O R U1
PFO /PSS
Non riparian
N/A
082
Riparian
PD 34
101
E H 02 U1
PFO /PSS
Non riparian
N/A
108
PD 35
101
E H O R U1
PFO /PSS
Non rip -irian
N/A
308
CORardln classifications are bised on characteristics of each wetland at the specific time ind location of
observation Wetlands ha -, ing No ID were not characterized due to impacted appearance at the time of
obsen anon
Includes wetland FEW Includes wetland IWG
3 Includes wetland HBAC Includes wetland IWI
4 Includes wetland HBWP Includes wetlands MIR
Includes wetlands HV /Al HXVN HWO 10 Includes wetlands hWJ K\VIL and K-A7J
G Includes wetlands H­\VBB HWII HWLL I I Delineation data previously verified no DWQ
wetland rating forms completed for these wetlands
U1 is Hampstead Bypass Alternative U starting at an interchange with US 17 Wilmington Bypass at Mihtar}
Cutoff Road Extension Alternatee 1\11 U2 is Hampstead Bypass Alternatee U starting at in interchange with
US 17 Wilmington B3 pass at l\fihtary Cutoff Road Extension Alternative 1\I2
Impacts are for all alternati-,es unless otherwise noted Indeidual impacts calculated for Mihtar} Cutoff Road
Extension Alternate es M1 and 1\12 utilize the corresponding Hampstead 13} pass Alternative U interchange
configuration
B12

Appendix C
Agency Comments on the
Draft EIS

s
a 40
I STATE OF NORTH CAROLINA
1
DEPARTMENT OF TRANSPORTATION
BEVERLY EAVES PERDUE EUGENE A CONTI JR
GON ERNOR SECREIARI
March 1 2012
Heinz J Mueller
' Chief NEPA Program Office
Region 4
United States Environmental Protection Agency
61 Forsyth Street
Atlanta Georgia 30303 8960
' Dear Mr Mueller
SUBJECT NCDOT Response to EPA Comments on the DEIS for Proposed Military
Cutoff Road Extension /US 17 Hampstead Bypass New Hanover and Pender
Counties TIP Projects U 4751 and R 3300
' Thank you for your November 15 2011 letter providing comments on the draft
environmental impact statement (DEIS) for Projects U 4751 and R 3300 We have
' reviewed your agency s comments and offer the following responses
Comment It should be noted that EPA and the U S Fish and Wildlife Service are listed
I' on the DEIS cover as Cooperating Agencies Section 1501 6 of the Council on
Environmental Quality (CEQ) regulations should be further explored by the USACE and
NCDOT for specific requirements of Cooperating Agencies
Response The FEIS will note the DEIS cover incorrectly included the EPA and USFWS
as Cooperating Agencies
Comment EPA has rated the DEIS alternatives E H +MI O +M2 R +MI U +M1 and
U +M2 as Environmental Objections (EO 2) EPA has rated detailed study alternative
(DSA) U as Environmental Concerns (EC 2) Those DSAs rated as EO 2 are those
i, alternatives where there is a potential for significant environmental impacts to water
supply wells and high quality waters of the U S that cannot be addressed without
significant project modification or the development of other feasible alternatives The
j' DEIS fails to address the requirements of the Safe Drinking Water Act and the Clean
Water Act with respect to current and future water supplies and the Military Cutoff Road
extension impacts (I e DSA M1 and M2) The DEIS fails to identify avoidance and
MAILING ADDRESS TELEPHONE [phone] LOCATION
NC DEPARTMENT OF TRANSPORTATION FAX [phone] CENTURY CENTER BUILDING A
PROJECT DEVELOPMENT AND ENVIRONMENTAL ANALYSIS 1000 BIRCH RIDGE DRIVE
1548 MAIL SERVICE CENTER WEBSITE WWW NCDOT ORG/DOWPRECONSTRUCT /PE/ RALEIGH NC 27610
RALEIGH NC 27699 1548

U 4751/R 3300
March 1 2012 Letter to Heinz Mueller
Page 2 of 3
minimization measures and compensatory mitigation under Section 404 of the Clean
Water Act for significant impacts to high quality waters of the U S
Response EPA s above comments were further expanded upon in Attachment A to the
letter NCDOT s response is included with those additional comments
Comment "The rating of 2 indicates that DEIS information and environmental analysis
is not sufficient and that additional information is required EPA has substantial
environmental concerns with respect to wetland and stream impacts and appropriate
avoidance and minimization measures and compensatory mitigation in addition EPA also
has environmental concerns for potential impacts to wetland mitigation and preservation
sites prime farmland impacts impacts to threatened and endangered species wildlife
habitat fragmentation and human environment impacts EPA recommends that all of the
technical comments in the attachment be addressed prior to the issuance of a Final EIS
(FEIS) Furthermore all relevant environment impacts that have not been disclosed in this
document should be addressed in additional documentation prior to the next Merger
decision point
Response EPA s comments will be addressed prior to the issuance of the FEIS
Additional information requested by EPA prior to Concurrence Point 3 will be addressed
with the merger team prior to the selection of the LEDPA
Comment "EPA has rated DSA U as having environmental concerns (EC 2) because it
has significant environmental impacts to human and natural resources that have not been
fully or accurately addressed in the DEIS and additional information is required EPA
believes that strictly combined with other transportation alternatives such a Transportation
System Management (TSM) and Travel Demand Management (TDM) DSA U can
possibly help meet the purpose and need However additional avoidance and
minimization measures would be needed for DSA U to prevent degradation to protected
and jurisdictional resources EPA is requesting a conceptual mitigation plan prior to the
selection of the Least Environmentally Damaging Practicable Alternative (LEDPA) EPA
will not be able to concur on the Least Environmentally Damaging Practicable Alternative
(LEDPA) until the significant environmental issues identified in the attachment are
satisfactorily resolved

r
' U 4751/R 3300
March 1 2012 Letter to Heinz Mueller
Page 3 of 3
I
Response EPA s above comments were further expanded upon in Attachment A to the
' letter NCDOT s response is included with those additional comments
I hope the information presented here and in Attachment A is useful If you have
additional questions regarding these projects please feel free to contact Jay McInnis
Project Engineer at [phone] or by e mail at jmcumis@ncdot g_o_v
Sincerely,
' Grego J horpe, PhD Manager
Project Development and Environmental Analysis
'Unit
cc Scott McLendon USACE
Brad Shaver USACE
NEPA/404 Merger Team Members
I
.1

U 4751/R 3300 Response to EPA DEIS Comments
Page l of 18
Attachment A
Purpose and Need for the Proposed Proiect
Comment The DEIS includes an elaboration on the purpose and need on Pages 1 3 and
1 4 The discussion concerning safety is not fully examined EPA believes that the
severity of accidents and potential fatalities within the project study area may increase
with a new location highway [sic] speed freeway While overall minor traffic accidents
may be expected to decrease along US 17 /Market Street with a new multi lane bypass
facility FHWA and National Safety Council studies have shown that new location high
speed freeways in rural areas can potentially increase the severity of accidents NCDOT
safety studies also indicate that the total crash rate for US 17 between US 17 Wilmington
Bypass (I 140) and Sloop Point Loop Road is below the 2005 2007 statewide crash rate
for rural U S routes Most of the proposed Hampstead Bypass is located substantially
north of where the traffic and accident problems are located along existing US 17 /Market
Street
Response Statewide crash rates do not support EPA s belief that the severity of
accidents and potential fatalities will increase with a new location freeway NCDOT
requests copies of the FH WA and National Safety Council studies EPA is citing While
future crash rates for a specific facility cannot be predicted a comparison of statewide
crash rates shows that rural freeways (such as the proposed Hampstead Bypass) have
lower fatal and injury crash rates than urban facilities with no control of access (such as
portions of existing Market Street /existing US l 7) The 2007 2009 statewide fatal crash
rate for rural US route freeways is almost half the fatal crash rate for urban five lane US
routes with no control of access The injury crash rate for rural US route freeways is over
five times lower than the injury crash rate for urban five lane US routes
Comment This section of the DEIS includes an additional need concerning
transportation demand The DEIS states that with the population increase there is a
corresponding growth in tourism and supporting services that resulted in a mixed purpose
traffic on US 17 This section of the DEIS does not specifically identify the correlation
between population growth and the growth in tourism and supporting services The
population growth trends presented in Table 1 4 by decade for the periods of 2010 2020
and 2020 2030 are not reflective of more recent soc►o economic trends The large number
of annual visitors for tourism does not specifically translate into increased population
growth for the project study area Considering the extensive wetland systems present in
the project study area and that most upland areas have already been developed for
retirement and seasonal second homes future trends in permanent population growth are
believed to be overestimated to justify new location facilities
Response The DEIS does not assert there is a correlation between population increase
and growth in tourism Rather these are two distinct variables which are both causing
increased demand on area roadways The population growth trends were taken from data
compiled by the North Carolina Office of Budget and Management (OBM) This data will
be updated in the FEIS using the most current statistics available from the OBM

' U 4751/R 3300 — Response to EPA DEIS Comments
Page 2 of 18
' Additional data sources were consulted to support the projections obtained from
the OBM The Cape Fear Commutes 2035 Transportation Plan, prepared by the
Wilmington Urban Area MPO (December 2010) projects that by 2035 the population for
' Pender County will more than triple (from its 2008 level) and the population for New
Hanover County will grow by approximately 67 percent for the same period The MPO
data will be included in the FEIS and the text will be revised for clarity
Comment Figure 2 of the DEIS includes the 2008 Levels of Service (LOS) along some
' of the major routes in the project study area This figure is confusing as it only provides
LOS from A to C and then breaks out LOS D E and F
i
' Response Figure 3 not Figure 2 presents 2008 level of service for existing conditions
The designation of levels of service A through C as a single color is intended to simplify
the figure as these levels of service are considered acceptable
Comment Twenty four (24) intersections are also provided with a LOS EPA notes
that a majority of existing Military Cutoff Road within the project study area shown is
LOS A C Additionally EPA estimates that based upon peak hour NCDOT traffic
estimates approximately 66 500 feet of 123 375 total feet of existing roadways operate at
a satisfactory LOS of A C Major sections of the existing multi lane US 17 highway in
Pender County and 1 140 /Wilmington Bypass show no current traffic capacity issues
Eight (8) of the 24 intersections also operate at LOS A C
Response The project is intended to address capacity issues on Market Street and the US
17 corridor not existing Military Cutoff Road It should be noted that the existing
Military Cutoff Road /Market Street intersection operated at level of service F in 2008
Also existing (2008) conditions show that most of Market Street and two thirds of all
intersections analyzed either approach or exceed an acceptable level of service Figure 5
presents 2035 no build levels of service Virtually all of Market Street and existing US 17
within the project limits will be operating at level of service F in the year 2035 without the
proposed projects
Comment "From Figure 2 it can be seen that while the i 140 /Wilmington Bypass
operates at an acceptable LOS US 17 from College Road to Futch Creek Road
(approximately 7 miles) operates at LOS F Apparently 1 140/ Wilmington Bypass is not
drawing sufficient through traffic from downtown Wilmington roadways The interchange
of 1 140 /Wilmington Bypass and US 17 north of Porters Neck Road is rated with a LOS A
j C Similarly the traffic problems (LOS F) south of the proposed extension of Military
1 Cutoff Road would not expect to be improved with a new location 6 lane freeway
connecting to 1 140 with a new interchange EPA is uncertain how the new location US
17 /Hampstead Bypass of approximately 12 to 15 miles will improve traffic carrying
capacity south of the proposed connections and new interchange with 1 140 /Wilmington
Bypass Except for one small area south of Scotts Hill Loop Road and a similarly small
e

U 4751/R 3300 Response to EPA DEIS Comments
Page -) of 18
area by Topsail High School US 17 between the 1 140 interchange to the northern
terminus operates at LOS D or better
Response It should be noted that EPA is citing 2008 levels of service from Figure 3 of
the DEIS Figure 5 of the DEIS presents 2035 no build levels of service for the project
area while Figures 14A through 14D present 2035 levels of service for the project area
with construction of the projects Comparison of these figures shows that the proposed
Hampstead Bypass will improve the level of service of portions of existing US 17 Much
of existing Market Street will operate at level of service F even with proposed Military
Cutoff Extension However Table 2 7 of the DEIS shows that with the proposed projects
average intersection delay will decrease at almost all of the intersections in the project
area At many intersections the intersection delay will be less than half of what it would
have been without the projects
Comment Figure 5 includes the projected 2035 LOS No build Nearly all multi lane
roadways and intersections operate at LOS F based upon projected growth The DEIS does
not include the 2035 LOS in the project study area with the proposed new facilities (Build
Scenario)
Response 2035 level of service in the project study area for the build alternatives is
depicted on Figures 14A through 14D and discussed in Section 2 5 3 of the DEIS In
addition Table 2 7 of the DEIS presents average intersection delay and level of service
along existing Market Street and US 17 for the no build and the detailed study
alternatives
Comment The project need appears to be based solely upon past population growth
numbers in the two counties from 1990 to 2000 and 2000 to 2010
Response The needs to be addressed by the proposed project are detailed in Section
1 3 1 of the DEIS These include traffic carrying capacity safety and transportation
demand EPA concurred with the project purpose and need at a NEPA /404 merger team
meeting held on September 21 2006
Traffic forecasts for the base year (2008) and horizon year (2035) were prepared
for the project in June 2008 using output from the Wilmington Metropolitan Planning
Organization s Travel Demand Model The Travel Demand Model uses various
socioeconomic data to forecast growth in order to predict demands on a transportation
network Regional growth expectations help to determine projected traffic in a horizon
year Assumptions about future development activity and changes in distribution of
population and employment in the forecast study area are implicit in the model It is
anticipated there will be periods where housing and employment market trends will
fluctuate up and down through the horizon year

U 4751/R 3300 — Response to EPA DEIS Comments
Page 4 of 18
Comment The DEIS does not separate seasonal peak traffic numbers from the Average
Annual Daily Traffic (AADT)
Response Traffic analysis for this project was based on peak hour analysis as a
' percentage of the average annual daily traffic Seasonal peak traffic numbers would likely
be higher than the average annual daily traffic numbers presented in the DEIS
Comment "The DEIS does not provide a break down by year of population growth rates
within the demographic area EPA would not anticipate that population growth rates from
2008 to present are at the same substantial percentage levels as was seen earlier in the
decade These 2035 population projections do not appear to take into account the project
setting and the availability of other necessary infrastructure
Response September 2011 annual population projections for New Hanover and Pender
Counties obtained from the NC Office of State Budget and Management show
fluctuating growth rates between 1990 and 2030 The annual rates vary between one
percent and five percent from 1990 to 2000 between one percent and four percent for the
period 2000 2010 and between one percent and two percent for 2010 2030 Ten year
trends and projections through the horizon year show growth rates for both counties that
are consistently above the state rate even though the rates have declined or are projected
to decline for each decade since 1990 2000 The overall growth rate for the period 1990
2030 is approximately 108 percent for New Hanover County and 128 percent for Pender
County In addition the Pender County Water Master Plan (McKim and Creed July
2006) which takes into account available infrastructure such as water and sewer projects
a growth rate for Pender County of 153 percent between 2000 and 2030 For those
projections a moderate growth model developed in consultation with Pender County was
used
Comment Overall the information contained in the DEIS does not adequately support
the purpose and need for multi lane (6 lanes for Military Cutoff Road Extension and 4
lanes for the Hampstead Bypass) new location roadways including a 12 to 15 mile
freeway and a 3 5 mile 6 lane boulevard Other transportation initiatives such as
widening existing roadways providing interchanges and improved intersection
movements adding turn lanes providing traffic calming measures and other
Transportation Systems Management and Travel Demand Management measures could
meet current and possible future traffic problems Regional traffic plans do not fully
address the existing traffic conditions of the 1 140 /Wilmington Bypass and why the
northern terminus was selected at its current location if it was not expected to draw
regional and seasonal traffic from more congested local routes Based upon NCDOT
studies I 140 / Wilmington Bypass and its interchanges operate successfully at LOS A C
Response NCDOT disagrees with EPA s assertion that the DEIS does not adequately
support the purpose and need Much of the information presented in the DEIS is updated
information to what was presented at the 2006 NEPA /404 merger team meeting to discuss
purpose and need EPA concurred along with the rest of the NEPA /404 merger team on
the project purpose and need in September 2006

U 4751/R 3300 Response to EPA DEIS Comments
Page 5 of 18
Figure 5 presents the 2035 levels of service in the project area for the no build
scenario As Figure 5 shows the entire length of Market Street and existing US 17 will
operate at level of service F in the design year
Traffic volumes along Market Street and existing US 17 far exceed the existing
roadway s capacity With the exception of widening the existing roadways the other
transportation initiatives EPA lists in their comment would not appreciably increase the
traffic capacity of the existing facility Traffic calming measures would degrade the
capacity of the facility Widening the existing facility (Alternative Z) was studied in detail
for this project EPA concurred along with the rest of the NEPA /404 merger team to drop
Alternative Z from consideration at a merger team meeting held in April 2010
Based on 2008 traffic volumes the existing Wilmington Bypass does operate at an
acceptable level of service as shown on Figure 3 of the DEIS However by the year
2035 the Wilmington Bypass will operate at level of service F as shown on Figure 5 of
the DEIS
Comment Recent purpose and need guidance by the Federal Highway Administration
(FHWA) indicates that safety issues on existing facilities cannot always be addressed by
the construction of new location facilities Safety improvements along existing US 17
could be accomplished through a multiple [sic] of enhancements including the addition of
auxiliary turn lanes restricting driveway access improved signal timing reducing the
posted speed limit increased signage etc Considering the rural and suburban nature of a
majority of the project study area new location and multi lane facilities combined with
existing safety concerns along US 17 will potentially increase the number and severity of
accidents
Response The addition of turn lanes improving access control etc would likely
improve safety along the existing roadway However these improvements would not
address the capacity issues along the existing roadway as well as the proposed alternatives
As discussed previously statewide crash rates do not support EPA s contention that new
location roadways will potentially increase the number and severity of accidents
Statewide total fatal and injury crash rates for rural freeways are much lower than the
crash rates for urban and rural facilities with no control of access or partial control of
access
Preliminary and Detailed Study Alternatives
Comment The DEIS includes discussions in Section 2 2 regarding Transportation
Systems Management (TSM) Alternative Travel Demand Management (TDM)
Alternative and Mass Transit Alternatives These transportation alternatives were not
given full consideration and were eliminated from detailed study because they did not
meet the purpose and need for the proposed new location projects These alternatives
were given only cursory consideration as individual alternatives and were never

U 4751/R 3300 — Response to EPA DEIS Comments
Page 6 of 18
considered in combination along with other select improvements to existing roadways and
intersections
Under the Mass Transit Alternative EPA notes that NCDOT has concluded that
there is a potential lack of demand EPA requests a copy of the public survey and other
traffic studies that support this conclusion The DEIS also cites a diversity of trip origins
and destinations EPA requests a copy of the origin /destination (O /D) study that was
prepared to support this position
Response TSM TDM and Mass Transit Alternatives were considered to the extent
necessary to determine whether or not they would meet the project purpose and need
None of these alternatives would meet the project purpose and need even if combined
Traffic volumes along existing Market Street and existing US 17 greatly exceed the
capacity of the facilities
The conclusion that there is a potential lack of demand for mass transit is based on
observation of the project area As discussed in the DEIS there are a number of origins
and destinations in the area However if one was to assume that there is sufficient
demand for transit such that increased transit would reduce traffic volumes along Market
Street and existing US 17 by 20 percent eight lanes would still be required along portions
of existing US 17 It would require approximately 479 buses to carry enough passengers
to reduce traffic on the highest volume sections of the existing facility by 20 percent
Increased transit will not meet the purpose and need of the project
Comment The DEIS discusses the N C Strategic Highway Corridor (SHC) vision plan
adopted by the N C Board of Transportation in 2004 as part of the purpose and need for
the project The SHC was not included in the purpose and need that Merger team
representatives concurred on in September of 2006 The extension of Military Cutoff Road
is designated as a boulevard in the SHC plan The Hampstead Bypass is depicted in the
2004 SHC vision plan as a new location freeway that follows the most westerly routes of
some of the Detailed Study Alternatives (DSAs) Without fully examining other
transportation alternatives or knowing the full extent of traffic problems on US 17 /Market
Street it was determined in 2004 that new multi lane routes would be the vision for the
corridor
Response Section 1 3 5 of the DEIS recognizes the proposed project has been designated
by NCDOT as a Strategic Highway Corridor The DEIS does not include the language
related to the SHC Vision in the purpose statement or in the summary of need for the
proposed action However NCDOT recognizes the location of this discussion could be
confusing and will move this discussion to Section 3 2 (Land Use and Transportation
Planning) in the FEiS
�J
Comment The DEiS does not explain the correlation between the traffic problems on
existing US 17 /Market Street and the need for additional traffic carrying capacity new

U 4751/R 3300 Response to EPA DEIS Comments
Page 7 of 18
multi lane routes of travel that are at a substantial distance from the poor LOS areas and
intersections and areas with higher accident rates shown on Page 2 2
Response Section 1 2 of the DEIS explains the purpose and need of the project and lists
several benefits of the project The purpose and need of the project is to improve the
traffic carrying capacity and safety of the US 17 and Market Street corridor in the study
area The projects will reduce congestion and increase safety on existing Market Street by
reducing traffic volumes on portions of that roadway The proposed Hampstead Bypass
will provide a freeway with much greater traffic carrying capacity for the US 17 corridor
than the existing roadway
Comment EPA does not believe that other non new location transportation
alternatives either singly or in combination were given full consideration in the DEIS
Response NCDOT gave consideration to all non new location alternatives identified in
the DEIS in particular their ability to meet the proposed project s purpose and need As
discussed previously the improve existing alternative (Alternative Z) was eliminated
from further study at the April 20 2010 NEPA /Section 404 meeting EPA concurred with
the decision to eliminate Alternative Z
Comment The DEIS includes a comparison of 23 preliminary corridor alternatives
(Alternatives A through W and Z) for the Hampstead Bypass and 2 preliminary corridor
alternatives (Alternatives M 1 and M2) for the Military Cutoff Road Extension Many of
these preliminary study corridors were apparently identified by NCDOT to strictly avoid
residential relocations within the proposed 300 foot corridor without any context sensitive
regard to natural system impacts (e g Alternative W 501 5 acres of wetland impacts and
63 residential relocations)
Response During the development of the preliminary study alternatives efforts were
made to avoid and minimize impacts to wetlands and streams wherever practicable
Preliminary build alternatives (Section 2 2 4 of the DEIS) were established through an
evaluation of suitability mapping based on available socioeconomic cultural and
environmental resource data Potential corridor alternatives were screened for suitability
based on several criteria including meeting the purpose and need for the proposed project
minimizing impacts to natural resources and consideration of community features
Roadway alignments which meet design criteria were developed and placed within the
000 foot corridors to minimize impacts to resources
Alternative W is one of the few preliminary alternatives developed outside of this
process The Alternative W alignment was prepared in response to a request from the
merger team at the May 9 2007 alternative screening meeting
Comment The DEiS design for DSA U indicates a 250 to 350 [foot] right of way
required for this DSA The DEIS does not provide a specific justification for this
proposed width compared to the other alternatives under consideration This right of way

J
' Wider right of way is proposed for Alternative U because ten lanes and service
roads are required along the portion of Alternative U which follows existing US 17 north
of the Wilmington bypass Alternative U typical sections are presented in Section
' 2 4 2 2 1 of the DEIS This section includes a discussion of other typical sections which
were considered for this portion of Alternative U
Comment The 5 DSAs under consideration in the DEIS do not necessarily meet the
requirements under 40 CFR Part 1502 14
U 4751/R 3300 — Response to EPA DEIS Comments
'
Page 8 of 18
('
width is also contradictory to the environmental commitment included on page 1 of 2 of
'
the Green Sheets
Response There is a typographical error in Section 2 4 2 3 and on Figures 1 I and 1 1B
'
of the DEIS A variable right of way width of 200 to 350 feet is proposed for Alternatives
E H O and R not 250 to 350 feet as stated in the DEiS A variable right of way width of
i
200 to 520 feet is proposed for Alternative U not 250 to 520 feet as stated in the DEIS
NCDOT is committed to maintaining a maximum right of way width of 200 feet in the
vicinity of Holly Shelter Game Land as noted in the DEIS in the Project Commitments
section and page 4 37 The FEIS will update the right of way width noted for Hampstead
Bypass alternatives in the text and on the typical section figure
' Wider right of way is proposed for Alternative U because ten lanes and service
roads are required along the portion of Alternative U which follows existing US 17 north
of the Wilmington bypass Alternative U typical sections are presented in Section
' 2 4 2 2 1 of the DEIS This section includes a discussion of other typical sections which
were considered for this portion of Alternative U
Comment The 5 DSAs under consideration in the DEIS do not necessarily meet the
requirements under 40 CFR Part 1502 14
1�'
Response The NCDOT believes the DEIS meets the requirements under 40 CFR Part
1502 14 Chapter 2 of the DEIS presents the environmental impacts of the proposal and
('
the alternatives in comparative form All reasonable alternatives are explored and
'
evaluated Reasons leading to the elimination of alternatives from detailed study are
discussed Each alternative considered in detail is fully described so that reviewers may
evaluate their comparative merits Reasonable alternatives are discussed The No Build
or No Action alternative is included NCDOT did not elect to identify a preferred
i
alternative prior to receiving additional public and agency input therefore no preferred
alternative was identified Discussion of measures taken to minimize impacts to the red
cockaded woodpecker is presented Additional discussion regarding mitigation is
included in other sections of the DEIS After a LEDPA is identified, a mitigation plan
will be developed
1�'
Comment Traffic carrying capacity and accident issues are located south of the
1 140 /Wilmington Bypass interchange along US 17 These issues were discussed during
previous Merger team meetings and agencies were informed that the NCDOT would
'
evaluate a full range of alternatives that would singly or in combination meet the purpose
and need The initially proposed project study area was expanded at the request of the
USACE and other agency representatives to insure that a full suite of reasonable
alternatives would be explored during the NEPA process
i
Response Over the course of four meetings alternatives were discussed with the merger
team Detailed study alternatives were selected and concurred on by the merger team
including EPA based on their ability to meet purpose and need and minimize impacts
1�'

U 4751/R 3300 Response to EPA DEIS Comments
Page 9 of 18
The detailed study alternatives address traffic carrying capacity and safety issues on
Market Street and US 17 in the project study area
Human Environment Impacts
Relocations
Comment The DEIS included non profit organizations in the business relocation totals
This is not a common NCDOT practice nor consistent with current NEPA /Section 404
Merger guidance
Response NCDOT does not have a standard way of presenting non profit organization
relocation information in impact tables It varies as to whether non profit organizations
are listed separately or included in the business totals Merger meeting information
guidance does not address listing non profit organization relocatees on impact tables The
FEIS will update Table 4 1 of the DEIS to include a separate line item for non profit
relocations
Comment In addition NCDOT also included a church cemetery graves and a 0
employee daycare in the Appendix C business relocations for U 4751 Alternatives M1
and M2 Appendix C appears to 'double count certain business relocations For DSA U
the report includes the relocation of 9 non profit organizations including 7 churches This
report identified a cell tower will be'isolated by this alternative as well as water tanks for
the Belvedere Plantation subdivision However this relocation report does not identify at
least two existing water supply wells operated by Cape Fear Public Utility Authority that
will be impacted by both DSA M 1 and M2 (Page 4 22 of the DEIS) EPA requests that a
consistent and accurate analysis of residential and business relocations be provided to EPA
and other Merger team agencies prior to the CP3 LEDPA meeting and included in the
FEIS
Response The relocation reports for Alternatives M 1 and M2 incorrectly included Enoch
Chapel Enoch Chapel Graveyard and Ogden Volunteer Rescue in the business relocation
totals Enoch Chapel and Ogden Volunteer Rescue were also listed under non profit
organizations The DEIS listed 65 business relocations (including non profit
organizations) for Alternatives M 1 and M2 The correct number is 62 (including non
profit organizations) Relocation reports for the project will be updated for the FEIS As
stated previously non profit organizations will be listed separately on impact tables in the
FEIS
The information regarding cell tower and water tanks in the relocation reports were
included as notes to the project engineers of items the right of way agent observed during
the field review The relocation report is not intended to present utility impacts of the
project

J
® Comment Ogden Park is described on Page 4 2 of the DEIS and discusses the park
■ boundary that was designed to accommodate a future transportation corridor through the
U 4751/R 3300 — Response to EPA DEIS Comments
t
Page 10 of 18
'
Community Resources
Comment Access to Prospect Cemetery is expected to be eliminated by either DSA MI
or M2 Page 4 2 of the DEIS states that access to Prospect Cemetery will be evaluated
during final roadway design EPA believes that this is a known impact resulting from the
Military Cutoff Road Extension and access road options and associated impacts should
'
have been identified in the DEIS including potential impacts to jurisdictional wetlands
and streams
Response Access to Prospect Cemetery has been provided in the preliminary design for
the project by a break in the proposed control of access at the existing driveway for the
cemetery No wetland or stream impacts are associated with the provision of this access
Comment The DEIS identifies an impact under DSA M 1 and M2 to a driving range
(golf) under community facilities and services This is a commercial business ( #57 under
'
Business Relocations) and not a public or non profit community facility The DEIS does
identify that Holly Shelter Game Land is located in the project study area However
unlike the driving range it is a public and community facility as well as a gameland and
preservation area It is used extensively by the public EPA requests that inaccuracies
contained in the DEIS be addressed in the FEIS
'
Response The driving range will be removed from the list of community facilities and
Holly Shelter Game Land will be added to the list of community facilities in the FEIS
Comment Mount Ararat AME Church a historic property is also expected to be
impacted by DSA M l or M2 In addition the DEIS also indicates that grave sites in this
cemetery could also be impacted but does not quantify the potential number of grave sites
In the Appendix C relocation report it is provided that DSA U will reportedly impact
647 + / grave sites Wesley Chapel United Methodist Church (395 +/ graves) McClammy
and King Family Cemetery (17 +/ graves) and Pollock's Cemetery (235 +/ graves) The
number of grave sites in the relocation report for DSA Ml and M2 under TIP project
number U 4751 is not provided Potential cemetery impacts for DSAs E H O and R are
not identified in the report
Response The FEIS will note that no graves are expected to be relocated for the portion
of the detailed study alternatives that include Hampstead Bypass Alternatives E H O and
R The number of grave sites that may be impacted by the portion of the detailed study
I'
alternatives that include Military Cutoff Road Extension will be included in the FEIS The
number of affected grave sites affected by Military Cutoff Road Extension (Ml and M2)
will be added to the total number of grave sites associated with the Hampstead Bypass
alternatives (E H O R and U) and summarized by detailed study alternative
® Comment Ogden Park is described on Page 4 2 of the DEIS and discusses the park
■ boundary that was designed to accommodate a future transportation corridor through the

U 4751/R 3300 Response to EPA DEIS Comments
Page 11 of 18
middle of the county park In addition Pedestrian access to existing multi use path
facilities and Ogden Park would be improved if pedestrian facilities are constructed
There is no identification of any proposed pedestrian facilities between the two sections of
the park
Response This statement was made in reference to the Wilmington MPO s request for
the inclusion of a multi use path along the proposed Military Cutoff Road Extension As
noted in the Project Commitments section and in Sections 2 4 2 2 2 4 2 2 3 and 5 3 13
of the DEIS the multi use path would tie into an existing multi use path along Military
Cutoff Road NCDOT will continue to coordinate with the Wilmington MPO on the
inclusion of a multi use path along Military Cutoff Road Extension
Farmland Impacts
Comment Prime farmland impacts are quantified for each DSA in Table 4 5 Section
4 3 3 does not reference the required AD 1006 forms EPA is unable to locate the forms
in the DEIS appendices EPA requests how these very exact impact numbers were
calculated and if the Natural Resource Conservation Service (MRCS) completed AD 1006
forms for the DSAs The DEIS does not provide any further information concerning
potential N C Voluntary Agricultural Districts (VADs) or what measures to minimize
farming impacts might be appropriate (e g Equipment access across dissected fields)
According to the N C Department of Agriculture and Consumer Services Pender County
in 2008 was working towards establishing VADs Sections 3 3 3 and 4 3 3 of the DEIS
fails to provide the relative importance of farming and other forest products for the Pender
County economy and its employment contribution Prior to the issuance of a FEIS EPA
recommends that supplemental information and analysis be provided regarding prime
farmland and other agricultural land impacts resulting from the proposed project
Response Natural Resource Conservation Service (MRCS) CPA 106 forms were
completed for this project The forms are located in Appendix B of the DEIS A
reference to these forms will be added to the farmland impacts discussion in the FEIS
Prime and other important farmland soils were identified for New Hanover and Pender
Counties Impacts presented in Table 4 5 were calculated by overlaying the detailed study
alternative s impact boundary on the soil information The FEIS will round the impacts
The FEIS will note there are no Voluntary Agricultural Districts in the project area As
noted in the DEIS the NRCS has indicated the detailed study alternatives in New Hanover
County and portions of the study area in Pender County are exempt from evaluation of
prime farmland impacts The relocation reports provided in Appendix C of the DEIS note
that the proposed project will not result in the relocation of any farms
Section 3 3 3 of the DEIS will be updated for the FEIS to describe the agricultural
economy of Pender County Section 4 3 3 of the DEIS will be updated for the FEiS to
note the proposed interchange at US 17 where Alternatives Mi +U and Alternative M2 +U
would go on new location is zoned as Agriculture However this area is classified as an
Urban Growth Area in the Pender County CAMA Land Use Plan and Mixed Use in
the Coastal Pender Small Area Plan

U 4751/R 3300 — Response to EPA DEIS Comments
Page 12 of 18
Noise Receptor Impacts
Comment Total noise receptor impacts are shown in Table 4 4 However design year
2035 traffic noise levels that are expected to approach or exceed the NAC are different
than from the table
Response The text preceding Table 4 4 presents the number of receptors impacted due
to traffic noise levels either approaching or exceeding the NAC while Table 4 4 includes
both receptors impacted due to noise levels approaching or exceeding the NAC and
receptors impacted due to a substantial increase in exterior noise levels The FEIS will
simplify the wording of this section for clarity
Historic Properties and Archaeological Sites
Comment Thus all of the DSAs have at least one adverse effect on a historic
property There is no identified avoidance alternative The impacts to historic properties
from DSA U are based upon using a freeway' design along portions of existing US 17 and
including parallel service roads Some of the impacts to historic properties may be
avoided or minimized if other reasonable designs are pursued during final design
Hazardous Materials
Comment Section 3 3 5 on hazardous materials is not accurate and should be corrected
in the FEIS Hazardous materials are regulated by the U S Department of Transportation
(USDOT) under 49 CFR Parts 100 185 This section of the DEIS does not conform to
other NEPA documents prepared by the NCDOT and reviewed by the EPA Hazardous
materials are identified in the Impacts to the Physical Environment section and not in the
'Human Environment impact section
Some of the identified geoenvironmental sites described in this section may meet the
cleanup requirements of more than one Federal statute Only 5 of the 28 sites referenced
in Section 3 3 5 are described in Section 4 3 5 These 5 sites are associated with DSA M 1
and M2 There is no qualifying description of the phrase low geoenvironmental
impacts" Details concerning the other 23 hazardous material sites is not provided in the
Response Two of the historic properties along Alternative U Poplar Grove and
Wesleyan Chapel United Methodist Church are directly across from each other on
existing US 17 Any widening of the existing road would affect at least one of these
1
properties Section 2 4 2 2 1 provides an extensive discussion regarding the proposed
typical section for Alternative U and presents alternative typical sections that were
examined NCDOT has coordinated with the State Historic Preservation Office on effects
to historic architectural resources Additional minimization efforts have resulted in
eliminating adverse effects to the Scott s Hill Rosenwald School by Alternative U After
selection of the LEDPA NCDOT will evaluate additional avoidance and minimization
M
efforts within the corridor of the selected alternative
Hazardous Materials
Comment Section 3 3 5 on hazardous materials is not accurate and should be corrected
in the FEIS Hazardous materials are regulated by the U S Department of Transportation
(USDOT) under 49 CFR Parts 100 185 This section of the DEIS does not conform to
other NEPA documents prepared by the NCDOT and reviewed by the EPA Hazardous
materials are identified in the Impacts to the Physical Environment section and not in the
'Human Environment impact section
Some of the identified geoenvironmental sites described in this section may meet the
cleanup requirements of more than one Federal statute Only 5 of the 28 sites referenced
in Section 3 3 5 are described in Section 4 3 5 These 5 sites are associated with DSA M 1
and M2 There is no qualifying description of the phrase low geoenvironmental
impacts" Details concerning the other 23 hazardous material sites is not provided in the

U 4751/R 3300 Response to EPA DEIS Comments
Page 13 of 18
DEIS Supplemental information and analysis should be provided to EPA prior to the
issuance of the FEIS This future geotechnical investigation and evaluation should include
the potential for existing hazardous material sites and underground storage tanks to
contaminate shallow groundwater resources
Response The wording of Section 3 3 5 will be modified in the FEIS for clarity The
DEIS includes the discussion of hazardous materials in the Physical Environment
Characteristics and impacts to the Physical Environment sections in accordance with
NCDOT EIS guidance The 28 sites referenced in Section 3 3 5 and shown on Figures
l0A IOK will be described in table format in the FEIS Section 4 3 5 of the DEIS
includes information related to those sites that may be impacted by the project Site
assessments to identify the nature and extent of any contamination will be performed on
these sites after the selection of the LEDPA and before right of way acquisition The FEIS
will clarify the term low geoenvironmental impacts to indicate the anticipated impacts
severity of potentially contaminated sites on the detailed study alternatives is low and little
to no impacts to cost or schedule are anticipated
Natural Resources Impacts
Groundwater Impacts and Water Supply Wells
Comment The Cape Fear Public Utility Authority ( CFPUA) is reported to have several
existing and proposed well sites associated with the Nano Water Treatment Plant
(NWTP) Section 4 5 3 1 1 identifies that DSA MI and M2 cross two existing well sites
operated by the CFPUA Additionally DSA M2 would also impact two additional
existing CFPUA well sites (to total 4) and a proposed well site DSA M2 is anticipated to
impact a raw water line and concentrate discharge line that provides a connection to
several anticipated well sites The DEiS states that estimates provided by CFPUA include
the loss of up to 6 million gallons per day (mgd) of anticipated future water supplies for
the project study area The DEIS lacks any specificity as to what the loss of the existing
water supplies might be what the potential to feasibly relocate the wells might be or what
the costs might be should either DSA M1 or M2 be selected
Response Since completion of the DEIS the preliminary designs of both Alternatives
M1 and M2 have been modified to avoid existing and proposed well sites Neither
alternative will require the relocation of a public water supply well Any water lines
crossed by the project will be relocated
Comment DSA U is also expected to impact 3 existing 'transient non community water
supply wells in the vicinity of the proposed US 17 interchange at Sidbury Road and Scott
Hill Loop Road Transient non community wells are described as being ones that serve 25
or more people at least 60 days out of the year at facilities such as restaurants and
churches The DEIS does not provide any additional information regarding these impacts
including current withdrawal rates the availability of alternative drinking water supplies
the costs to owners to relocate wells etc

U 4751/R 3300— Response to EPA DEIS Comments
Page 14 of 18
Response The FEiS will note that now only two non community water supply wells are
being impacted by Alternative U due to minimization measures incorporated into the
Alternative U interchange at Sidbury Road
The FEIS will also explain that during the right of way process NCDOT will compensate
property owners for the expense of drilling a new well or connecting to a public water
system If an alternate water supply is not available for a property NCDOT will purchase
the property and provide relocation assistance
Comment The DEIS does not address what the potential for contamination to existing
well fields will be The depth and distance of CFPUA well sites is not provided with
' respect to the alternatives under consideration The potential threat from hazardous
material accidents to other existing wellheads is not evaluated in the DEIS
The full impacts to water supplies are not detailed in the DEIS EPA believes that the
construction of either DSA M1 or M2 will potentially violate this Clean Water Act
requirement NCDOT should also refer to the Safe Drinking Water Act for additional
requirements The DEIS fails to provide any potential avoidance or minimization
measures or mitigation to address the loss of current and future water supplies in the
project study area
Response The FEIS will address the potential for contamination to existing wells and
identify the distance of the wells from the detailed study alternatives in proximity to the
wells NCDOT will request well depth information from the CFPUA The FEIS will
discuss measures that were and /or could be taken to avoid minimize or mitigate impacts
to the CFPUA water supply wells A qualitative assessment of the project impacts to
public water supply wells was provided to the EPA and merger team by e mail on
February 9 2012
Jurisdictional Streams and Wetlands
Comment NCDOT provided the DWQ Wetland rating for each of the 286 wetland
systems The DEIS did not provide wetlands ratings using the multi agency accepted
North Carolina Wetlands Assessment Methodology ( NCWAM)
Response NCDOT is not yet rating wetlands using NCWAM
Comment Section 4 5 4 1 contains a discussion on avoidance and minimization of
impacts to jurisdictional resources Seventeen (17) mayor hydraulic crossings were
identified during the CP 2A field meeting Thirteen (13) structures are various sized
reinforced concrete box culverts (RCBC) and one existing RCBC is proposed to be
extended The DEIS does not identify any additional avoidance and minimization
measures to reduce impacts to jurisdictional streams and wetlands such as reduced median
widths increased side slopes the use of single bridges and tapered medians retaining
walls reduced paved shoulders etc

U 4751/R 3300 Response to EPA DEIS Comments
Page 15 of 18
Response After selection of the LEDPA NCDOT will evaluate additional avoidance and
minimization efforts within the corridor of the preferred alternative Additional measures
to reduce impacts will be reviewed at NEPA /Section 404 Merger Concurrence Points 4A
4B and 4C
Comment Considering the magnitude and severity of the impacts to high quality
streams and wetlands EPA requests a conceptual mitigation plan prior to the selection of a
LEDPA and the issuance of a FEIS There are no details as to what mitigation
opportunities are available on site and what credits or mitigation assets are available
through the EEP Considering the location of the proposed project and the presence of
high quality waters of the U S the conceptual mitigation plan should be sufficiently
detailed and provide for full compensation for lost functions and values to high quality
resources
Response NCDOT does not typically extensively investigate on site mitigation
opportunities until the LEDPA has been chosen NCDOT s memorandum of agreement
with the NC Ecosystem Enhancement Program limits on site mitigation to sites adjacent
and contiguous with the roadway corridor Therefore NCDOT can only pursue sites
adjacent to the LEDPA corridor and not on any of the others
Comment During the Merger process EPA also learned that several NCDOT
mitigation sites associated with the I 140 /Wilmington Bypass might be impacted from
[sic] the proposed project including the Plantation Road Site From Figure l OC of the
DEIS it appears that the 34 acre Residual Site might also be impacted from several of
the DSAs From Figure l OD it appears that the Corbett Strip Residual Site is probably
going to be impacted from several of the DSAs Discussions in the DEIS regarding the
potential impacts to these NCDOT mitigation sites is included in Section 3 3 8 3 Impacts
to these sites are not specifically identified in the summary table S l but are addressed
Table 4 3 8 3 Additional information including credit /debit ledgers restrictive covenants
and easements and other property records is being requested by EPA prior to the selection
of a LEDPA and the issuance of a FEIS NCDOT should avoid impacting approved
Mitigation sites that were required for compensation for previous highway project impacts
(i e 1140/US 17 Wilmington Bypass)
Response At a merger team meeting held on December 15 2011 additional details were
provided regarding these mitigation properties This information will be included in the
FEIS
Terrestrial Forest Impacts
Comment Terrestrial forest impacts mclude[d in] Table S 1 summary of impacts for the
DSAs are as follows DSA E H +M 1 518 acres DSA O +M2 512 acres DSA R +M 1 472
acres DSA U +M1 406 acres and DSA U +M2 455 acres These impact numbers do not
match the terrestrial community impacts shown in Table 4 9 Eliminating the impact
estimates to maintain[ed] and disturbed communities still does not provide for an
accurate estimate of terrestrial forest impacts The FEIS should identify how the terrestrial

U 4751 /R 3300 — Response to EPA DEIS Comments
Page 16 of 18
forest impacts were calculated for each DSA and what natural communities were included
in the estimates
Response An error exists in the forest impacts shown on Tables S 1 2 3 and 4 10 of the
DEIS These tables will be corrected in the FEIS
Comment EPA notes the comment concerning Executive Order 13112 on Invasive
species and NCDOT s Best Management Practices (BMPs) EPA acknowledges the
NCDOT invasive plant species list in Section 3 5 2 1 2 of the DEIS The FEIS should
identify specific BMPs to be followed to minimize the spread of invasive plant species
following construction and provide detailed environmental commitments on how these
BMPs are to be implemented It would be useful to the public and decision makers if
NCDOT could provide previous project examples where these invasive species BMPs
have cost effectively resulted in the long term elimination or reduction in invasive plant
species following roadway construction activities There are numerous Significant Natural
Heritage Areas that are present in the project study area and the proposed new location
alternatives represent a significant long term threat to these unique habitats resulting from
the introduction of aggressive and persistent roadside invasive plant species
Response Additional discussion on best management practices to be followed regarding
invasive species will be included in the FEIS
Threatened and Endangered Species
Comment Sections 3 5 4 3 and 4 5 4 3 address protected species including Federally
listed species under the Endangered Species Act (ESA) Considering the potential impacts
to NCWRC's managed Holly Shelter Game Land the DEIS should have also identified
any State listed species under their jurisdictional and within the project study area
Response NCDOT does not survey for state listed species as the state law does not
apply to NCDOT activities As noted in Table 4 7 of the DEIS the proposed project will
not have any direct impacts to Holly Shelter Game Land
Comment "Generally EPA has significant environmental concerns regarding wildlife
habitat loss and fragmentation resulting from most of the DSAs including E H O and R
Potential animal /vehicle collisions involving new location multi lane high speed facilities
in rural areas in close proximity to game lands and other preservation areas need to be
analyzed and studied prior to the issuance of a FEIS
Response The potential for crashes involving animals along the proposed project will be
discussed in the FEIS

U 4751/R 3300 Response to EPA DEIS Comments
Page 17 of 18
Other Environmental Issues
Comment Regarding socio economic issues EPA acknowledges the following DEIS
comment It is anticipated that the proposed project will enhance long term access and
connectivity opportunities in New Hanover and Pender County and will support local
regional and statewide commitments to transportation improvement and economic
viability Enhanced long term access and connectivity are not part of the purpose
and need for the proposed project that EPA and other Merger Team agencies agreed
with in 2006
Response This statement is included in DEIS Section 4 9 Relationship Between Long
Term & Short Term Uses/Benefits This information is being presented as a project
benefit not as a part of the purpose and need It is not included in the Purpose and Need
chapter
Comment Impacts to Holly Shelter Game Land and the 22 Acre Residual Site should
be removed from the table as all of the impacts are zero to these two areas The total
impacts for the DSAs are as follows DSA E H +MI 4 43 acres DSA O +M2 42 94 acres
DSA R +M1 5 01 acres DSA U +M1 3 24 acres and DSA U +M2 34 40 acres Most of the
impacts are associated with DSA M2 and are to the Plantation Road and 34 Acre Residual
mitigation sites These significant impacts should be included in Table S 1 and future
impact tables
Response We do not agree with EPA s comment to remove Holly Shelter Game Land
and the 22 Acre Residual Site from Table 4 7 as it is important for the reader to know
that none of the alternatives will affect these sites As noted in EPA s comment this table
provides details associated with the detailed study alternative s impacts to game lands and
preservation areas, similar to the way Table 4 11 details individual stream impacts or
Table 4 17 details federally protected species impacts The impacts to the mitigation sites
are currently summarized in Table S i of the DEIS Table S 1 in the FEIS will also
provide a summary of this information
Indirect and Cumulative Effects
Comment EPA does not agree with the assumptions and conclusions in the indirect and
cumulative effects section of the DEIS The analysis cites travel time benefits without
providing the specific travel time savings or other traffic analyses required to make such a
claim The analysis ignores a critical component water supply within the project study
area and the importance it may have on current and future development and land uses
Furthermore the qualitative ranking in Tables 4 18 and 4 19 are not supported by actual
data or facts These ranking appear to be very subjective and based upon past trends and
not upon more recent socio economic factors The relationship of the information
contained in Table 4 20 compared to the proposed project is not made clear in Section 4 6
Considering the significant impact predicted for the project study area watersheds EPA is

U 4751/R 3300— Response to EPA DEIS Comments
Page 18 of 18
requesting a review copy of the indirect and cumulative quantitative water quality impacts
analysis that was requested by the NCDWQ and prior to the issuance of a FEIS
Response Section 4 6 1 of the DEIS states the Hampstead Bypass will result in more
than ten minutes in travel time savings The DEiS further explains that this time savings
is because the proposed bypass will not have the traffic signals and congestion of the
existing facilities
The iCE screening matrices used in the DEiS are not the most current quasi
quantitative matrices used in ICE analysis The Relative Rating of Indirect and
Cumulative Effects matrices (Tables 4 18 and 4 19 of the DEIS) are the version that was
in effect at the time the combined Community Impact Assessment and Qualitative Indirect
and Cumulative Effects Assessment was prepared Since that time the screening matrix
has been updated to include additional categories and a quantitative component
A revised Indirect and Cumulative Effects analysis including an updated ICE
Screening report and an ICE Land Use Scenario Assessment will be prepared for
incorporation into the FEIS The new ICEs will include information about water and
sewer In addition the cumulative effects summary in the ICE will be expanded to more
fully document past present and future actions by all parties
Table 4 20 presents baseline wetland and stream data for the project area Changes
to the wording of this section will be considered for the FEIS to make this clearer EPA
will be provided a copy of the quantitative indirect and cumulative impacts analysis
which is not prepared until after the FEIS is complete
J

Ja�ZEo Sr4l
A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
�F
0 2 61 FORSYTH STREET
ATLANTA GEORGIA 30303 8960
November 15 2011
Dr Gregory J Thorpe, Ph D , Manager
Project Development and Environmental Analysis Branch
North Carolina Department of Transportation
1548 Mail Service Center
Raleigh North Carolina 27699 1548
SUBJECT Federal Draft Environmental Impact Statement for the US 17 Hampstead
Bypass and Military Cutoff Road Extension New Hanover and Pender 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 has 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)
The U S Army Corps of Engineers (USACE) and the North Carolina Department of
Transportation (NCDOT) are proposing to extend Military Cutoff Road on new location
for several miles (approximately 3 5 miles) as a 6 lane median divided facility and
connect to a 12 to 15 mile new location multi lane, median divided bypass facility of US
17 Highway in New Hanover and Pender Counties, North Carolina Both multi lane
facilities are expected to tie in with I 140 Wilmington Bypass (Also known as US 17
John Jay Burney Jr Freeway) 1 140 currently connects to US 17 (Market Street) with an
interchange at Futch Creek Road
EPA has been participating in the proposed project under the NEPA/Section 404
Merger process since 2005 and before the NCDOT proposed to combine the two facilities
into one proposed project According to EPA s records the Purpose and Need
(Concurrence Point CP 1) for the combined roadway facilities was concurred on
September 21 2006 On August 23 2007 EPA concurred on the Detailed Study
Alternatives to be carried forward (Concurrence Point 2) Another CP 2 meeting was
held on April 20 2010 that further narrowed down the Detailed Study Alternatives EPA
concurred on CP 2A Bridging and Alignment Review on May 27 2010 EPA s
technical review comments on the DEIS are attached to this letter (See Attachment A)
1
Intemet Address (URL) http / /www epa gov
Recycle"acyclable Printed wRh Vegetable 00 Based Inks on ReWded Paper (Minimum 309' Postconsumeo

It should be noted that EPA and the U S Fish and Wildlife Service are listed on
the DEIS cover as Cooperating Agencies Section 15016 of the Council on
Environmental Quality (CEQ) regulations should be further explored by the USACE and
NCDOT for specific requirements of Cooperating Agencies
EPA has rated the DEIS alternatives E H +M1 O +M2 R +M1 U +M1 and U +M2
as Environmental Objections (EO 2) EPA has rated detailed study alternative (DSA) U
as Environmental Concerns (EC 2) Those DSAs rated as EO 2 are those alternatives
where there is a potential for significant environmental impacts to water supply wells and
high quality waters of the U S that cannot be addressed without significant project
modification or the development of other feasible alternatives The DEIS fails to address
the requirements of the Safe Drinking Water Act and the Clean Water Act with respect to
current and future water supplies and the Military Cutoff Road extension impacts (i e
DSA M1 and M2) The DEIS fails to identify avoidance and minimization measures and
compensatory mitigation under Section 404 of the Clean Water Act for significant
impacts to high quality waters of the U S
The rating of 2 indicates that DEIS information and environmental analysis is
not sufficient and that additional information is required EPA has substantial
environmental concerns with respect to wetland and stream impacts and appropriate
avoidance and minimization measures and compensatory mitigation In addition EPA
also has environmental concerns for potential impacts to wetland mitigation and
preservation sites prime farmland impacts impacts to threatened and endangered
species wildlife habitat fragmentation and human environment impacts EPA
recommends that all of the technical comments in the attachment be addressed prior to
the issuance of a Final EIS (FEIS) Furthermore all relevant environment impacts that
have not been disclosed in this document should be addressed in additional
documentation prior to the next Merger decision point
EPA has rated DSA U as having environmental concerns (EC 2) because it has
significant environmental impacts to human and natural resources that have not been
fully or accurately addressed in the DEIS and additional information is required EPA
believes that strictly combined with other transportation alternatives such a
Transportation System Management (TSM) and Travel Demand Management (TDM)
DSA U can possibly help meet the purpose and need However additional avoidance and
minimization measures would be needed for DSA U to prevent degradation to protected
and jurisdictional resources EPA is requesting a conceptual mitigation plan prior to the
selection of the Least Environmentally Damaging Practicable Alternative (LEDPA)
EPA will not be able to concur on the Least Environmentally Damaging Practicable
Alternative (LEDPA) until the significant environmental issues identified in the
attachment are satisfactorily resolved
Mr Christopher Militscher of my staff will continue to work with you as part of
the NEPA/Section 404 Merger Team process EPA will continue to work with your staff
and other Merger Team agencies on modifications to the DSAs and developing

alternatives that can potentially meet the stated purpose and need for the protect study
area Should you have any questions concerning these comments please feel free to
contact him at Militscher chns a,epa gov or [phone] or [phone] Thank
you
Sinceiely
11�w IV
Heinz J Mueller
Chief NEPA Program Office
Cc S
McClendon, USACE
B
Shaver USACE
P
Benjamin USFWS
B
Wrenn NCDWQ
D
Wainwright, NCDWQ
M
Herndon NCDWQ
D
Cox NCWRC
S
Sollod NCDCM

ATTACHMENT A
Draft Environmental Impact Statement
US 17 Hampstead Bypass and Military Cutoff Road Extension
New Hanover and Pender Counties
TIP Project Nos R -3300 and U -4751
Detailed Technical Comments
Purpose and Need for the Proposed Project
The NEPA/Section 404 Merger Concurrence Point (CP) 1 Purpose and Need
statement is included in Appendix B of the DEIS The stated purpose and need that
Merger team representatives agreed to is as follows The purpose of the project is to
improve the traffic carrying capacity and safety of the US 17 and Market Street corridor
in the project study area The DEIS includes an elaboration on the purpose and need on
Pages 1 3 and 1 4 The discussion concerning safety is not fully examined EPA
believes that the severity of accidents and potential fatalities within the project study area
may increase with a new location highway speed freeway While overall minor traffic
accidents may be expected to decrease along US 17 /Market Street with a new multilane
bypass facility FHWA and National Safety Council studies have shown that new
location high speed freeways in rural areas can potentially increase the severity of
accidents NCDOT safety studies also indicate that the total crash rate for US 17 between
US 17 Wilmington Bypass (I 140) and Sloop Point Loop Road is below the 2005 2007
statewide crash rate for rural U S routes Most of the proposed Hampstead Bypass is
located substantially north of where the traffic and accident problems are located along
existing US 17 /Market Street
This section of the DEIS includes an additional need concerning transportation
demand U S Census Bureau population data for New Hanover County and Pender
County is provided The DEIS states that with the population increase there is a
corresponding growth in tourism and supporting services that resulted in a mixed
purpose traffic on US 17 This section of the DEIS does not specifically identify the
correlation between population growth and the growth in tourism and supporting
services The population growth trends presented in Table 1 4 by decade for the periods
of 2010 2020 and 2020 2030 are not reflective of more recent socio economic trends
The large number of annual visitors for tourism does not specifically translate into
increased population growth for the protect study area Considering the extensive
wetland systems present in the project study area and that most upland areas have already
been developed for retirement and seasonal second homes future trends in permanent
population growth are believed to be over estimated to justify new location facilities
Figure 2 of the DEIS includes the 2008 Levels of Service (LOS) along some of
the mayor routes in the project study area including 1 140 /Wilmington Bypass US
17/Market Street and US 17 to Sloop Point Loop Road at the northern project terminus
This figure is confusing as it only provides LOS from A to C and then breaks out LOS
D E and F Twenty four (24) intersections are also provided with a LOS EPA notes

1
EPA also notes the issue of local traffic versus regional through traffic From
that a majority of existing Military Cutoff Road within the project study area shown is
'
LOS A C Additionally EPA estimates that based upon peak hour NCDOT traffic
'
estimates approximately 66 500 feet of 123,375 total feet of existing roadways operate at
a satisfactory LOS of A C Mayor sections of the existing multi lane US 17 highway in
Pender County and 1140/Wilmington Bypass show no current traffic capacity issues
'
Eight (8) of the 24 intersections also operate at LOS A C
Figure 5 includes the projected 2035 LOS No build Nearly all multi lane
roadways and intersections operate at LOS F based upon projected growth The DEIS
does not include the 2035 LOS in the project study area with the proposed new facilities
(Build Scenario) This information is necessary to determine if after the 16 to 18 miles of
new facilities are constructed that there will be any observable improvements to the
existing facilities in the future The project need appears to be based solely upon past
population growth numbers in the two counties from 1990 to 2000 and 2000 to 2010
Section 3 Table 3 1 of the DEIS provides Population Characteristics for North Carolina,
New Hanover County Pender County Wilmington and Demographic Area The DEIS
defines the demographic area as the area in and around the study area The DEIS does
not separate seasonal peak traffic numbers from the Average Annual Daily Traffic
(AADT) The DEIS does not provide a break down by year of population growth rates
within the demographic area EPA would not anticipate that population growth rates
from 2008 to present are at the same substantial percentage levels as was seen earlier in
the decade These 2035 population projections do not appear to take into account the
protect setting and the availability of other necessary infrastructure
Overall the information contained in the DEIS does not adequately support the
purpose and need for multi lane (6 lanes for Military Cutoff Road Extension and 4 lanes
for the Hampstead Bypass) new location roadways including a 12 to 15 mile freeway
and a 3 5 mile 6 lane boulevard Other transportation initiatives such as widening
existing roadways providing interchanges and improved intersection movements adding
turn lanes providing traffic calming measures and other Transportation Systems
Management and Travel Demand Management measures could meet current and possible
EPA also notes the issue of local traffic versus regional through traffic From
Figure 2 it can be seen that while the 1 140 /Wilmington Bypass operates at an acceptable
LOS US 17 from College Road to Futch Creek Road (approximately 7 miles) operates at
'
LOS F Apparently 1 140 /Wilmington Bypass is not drawing sufficient through traffic
from downtown Wilmington roadways The interchange of 1- 140 /Wilmington Bypass
and US 17 north of Porters Neck Road is rated with a LOS A C Similarly the traffic
'
problems (LOS F) south of the proposed extension of Military Cutoff Road would not
expect to be improved with a new location 6 lane freeway connecting to I 140 with a
new interchange EPA is uncertain how the new location US 17 /Hampstead Bypass of
approximately 12 to 15 miles will improve traffic carrying capacity south of the proposed
connections and new interchange with I 140 /Wilmington Bypass Except for one small
area south of Scotts Hill Loop Road and a similarly small area by Topsail High School
'
US 17 between the I 140 interchange to the northern terminus operates at LOS D or
better
Figure 5 includes the projected 2035 LOS No build Nearly all multi lane
roadways and intersections operate at LOS F based upon projected growth The DEIS
does not include the 2035 LOS in the project study area with the proposed new facilities
(Build Scenario) This information is necessary to determine if after the 16 to 18 miles of
new facilities are constructed that there will be any observable improvements to the
existing facilities in the future The project need appears to be based solely upon past
population growth numbers in the two counties from 1990 to 2000 and 2000 to 2010
Section 3 Table 3 1 of the DEIS provides Population Characteristics for North Carolina,
New Hanover County Pender County Wilmington and Demographic Area The DEIS
defines the demographic area as the area in and around the study area The DEIS does
not separate seasonal peak traffic numbers from the Average Annual Daily Traffic
(AADT) The DEIS does not provide a break down by year of population growth rates
within the demographic area EPA would not anticipate that population growth rates
from 2008 to present are at the same substantial percentage levels as was seen earlier in
the decade These 2035 population projections do not appear to take into account the
protect setting and the availability of other necessary infrastructure
Overall the information contained in the DEIS does not adequately support the
purpose and need for multi lane (6 lanes for Military Cutoff Road Extension and 4 lanes
for the Hampstead Bypass) new location roadways including a 12 to 15 mile freeway
and a 3 5 mile 6 lane boulevard Other transportation initiatives such as widening
existing roadways providing interchanges and improved intersection movements adding
turn lanes providing traffic calming measures and other Transportation Systems
Management and Travel Demand Management measures could meet current and possible

future traffic problems Regional traffic plans do not fully address the existing traffic
conditions of the I- 140 /Wilmington Bypass and why the northern terminus was selected
at its current location if it was not expected to draw regional and seasonal traffic from
more congested local routes Based upon NCDOT studies 1- 140 /Wilmington Bypass and
its interchanges operate successfully at LOS A C
Recent purpose and need guidance by the Federal Highway Administration
(FHWA) indicates that safety issues on existing facilities cannot always be addressed by
the construction of new location facilities Safety improvements along existing US 17
could be accomplished through a multiple of enhancements including the addition of
auxiliary turn lanes restricting driveway access improved signal timing reducing the
posted speed limit, increased signage, etc Considering the rural and suburban nature of a
majority of the protect study area, new location and multi lane facilities combined with
existing safety concerns along US 17 will potentially increase the number and severity of
accidents
Preliminary and Detailed Study Alternatives
The DEIS includes discussions in Section 2 2 regarding Transportation Systems
Management (TSM) Alternative, Travel Demand Management (TDM) Alternative and
Mass Transit Alternatives These transportation alternatives were not given full
consideration and were eliminated from detailed study because they did not meet the
purpose and need for the proposed new location projects These alternatives were given
only cursory consideration as individual alternatives and were never considered in
combination along with other select improvements to existing roadways and
intersections Under the Mass Transit Alternative, EPA notes that NCDOT has concluded
that there is a potential lack of demand EPA requests a copy of the public survey and
other traffic studies that support this conclusion The DEIS also cites a diversity of trip
origins and destinations EPA requests a copy of the origin/destination (O /D) study that
was prepared to support this position
The DEIS discusses the N C Strategic Highway Corridor (SHC) vision plan
adopted by the N C Board of Transportation in 2004 as part of the purpose and need for
the project The SHC was not included in the purpose and need that Merger team
representatives concurred on in September of 2006 The extension of Military Cutoff
Road is designated as a boulevard in the SHC plan The Hampstead Bypass is depicted in
the 2004 SHC vision plan as a new location freeway that follows the most westerly routes
of some of the Detailed Study Alternatives (DSAs) Without fully examining other
transportation alternatives or knowing the full extent of traffic problems on US 17/Market
Street it was determined in 2004 that new multi lane routes would be the vision for the
corridor The DEIS does not explain the correlation between the traffic problems on
existing US 17 /Market Street and the need for additional traffic carrying capacity new
multi lane routes of travel that are at a substantial distance from the poor LOS areas and
intersections and areas with higher accident rates shown on Page 2 2 EPA does not
believe that other non new location transportation alternatives either singly or in
combination were given full consideration in the DEIS

The DEIS includes a comparison of 23 preliminary corridor alternatives
(Alternatives A through W and Z) for the Hampstead Bypass and 2 preliminary corridor
alternatives (Alternatives M1 and M2) for the Military Cutoff Road Extension Many of
' these preliminary study corridors were apparently identified by NCDOT to strictly avoid
residential relocations within the proposed 300 foot corridor without any context
sensitive regard to natural system impacts (e g Alternative W 501 5 acres of wetland
' impacts and 63 residential relocations) The original list of preliminary study alternatives
were narrowed down to 13 DSAs on August 23, 2007, at a Concurrence Point (CP) 2
Merger meeting The list of 13 DSAs was further narrowed down on April 20 2010 to 6
' DSAs at a second CP 2 meeting The current list of DSAs includes Alternatives E H O,
R U and M1 and M2 Alternatives E H O R and U all share the same northern terminus
by Sloop Point Loop Road and US 17 Alternatives M1 and M2 share a common
' southern terminus at the intersection of Military Cutoff Road and US 17 Combining the
freeway alternatives and Military Cutoff Road extension alternatives represents 5 DSAs
Alternatives E H O and R are located more than a mile to the west of the existing
multi lane US 17 facility for a majority of their length Alternative E H appears at its
most westerly point to be located more than 3 miles from the existing US 17 corridor
Alternative U is considered to be a shallow bypass and utilizes the existing corridor for
approximately half of its length Alternative U does not require a new location
interchange along I 140 /Wilmington Bypass The DEIS design for DSA U indicates a
250 to 350 right of way required for this DSA The DEIS does not provide a specific
justification for this proposed width compared to the other alternatives under
consideration This right of way width is also contradictory to the environmental
commitment included on page I of 2 of the Green Sheets
Alternatives Ml and M2 follow the same alignment for more than half of its
length and then tie in two future I- 140 /Wilmington Bypass interchanges that are
approximately one mile apart The current DSAs combinations are included in the
summary comparison in Table S I The 5 DSAs under consideration in the DEIS do not
necessarily meet the requirements under 40 CFR Part 1502 14 Traffic carrying capacity
and accident issues are located south of the I 140 /Wilmington Bypass interchange along
US 17 These issues were discussed during previous Merger team meetings and agencies
were informed that the NCDOT would evaluate a full range of alternatives that would
singly or in combination meet the purpose and need The initially proposed project study
area was expanded at the request of the USACE and other agency representatives to
insure that a full suite of reasonable alternatives would be explored during the NEPA
process
Human Environment Impacts
Relocations
' Residential and business relocations for the DSA E H +M1 O +M2 R +M1, U +M1
and U +M2 are shown in Table S l and are as follows 61/84, 60/84, 59/84 93/106 and

95/106 The business relocations include non profit displacements (i a Relocations)
There are no large business employers identified within the demographic area (Pages 3 2 I
and 3 3 of the DEIS)
EPA compared residential and business relocations for the DSAs to similar multi '
lane facilities identified and analyzed under the 2010 Merger Performance Measures
Environmental Quality Indicators (Baseline and 2009 data) For residential relocations
impacts per mile for the five DSAs were comparable in range to the Baseline and 2009 '
impact numbers (2 0 to 4 2 residential relocations per mile for Eastern new location
projects respectively) Business relocations are higher for all 5 DSAs compared to the
Baseline and 2009 impact numbers The DEIS included non profit organizations in the ,
business relocation totals This is not a common NCDOT practice nor consistent with
current NEPA/Section 404 Merger guidance In addition NCDOT also included a
church cemetery graves and a 0 employee daycare in the Appendix C business '
relocations for U 4751 Alternatives M1 and M2 According to this report 63 business
relocations will result from either DSA M 1 or M2 Appendix C appears to double count
certain business relocations For DSA U the report includes the relocation of 9 non profit ,
organizations including 7 churches Another 32 displaced businesses are identified for
DSA U Also included in the list of 32 business relocations for DSA U is a seasonal
produce stand a small business with name unknown and a new business under '
construction (no name) This report identified a cell tower will be isolated by this
alternative as well as water tanks for the Belvedere Plantation subdivision However this
relocation report does not identify at least two existing water supply wells operated by '
Cape Fear Public Utility Authority that will be impacted by both DSA M1 and M2 (Page
4 22 of the DEIS) EPA requests that a consistent and accurate analysis of residential and
business relocations be provided to EPA and other Merger team agencies prior to the CP '
3 LEDPA meeting and included in the FEIS
Minority and Low Income Populations Environmental Justice
Table 4 1 identifies minority owned residential and business relocations
including the following DSA EH +MI 13 out of 61 residential and 11 out of 84
businesses DSA O +M2 11 out of 60 residential and 11 out of 84 businesses, DSA
R +M1 13 out of 59 residential and 11 out of 84 businesses DSA U +M1 36 out of 93
residential and 22 out of 106 businesses DSA U +M2 36 out of 95 residential and 22 out
of 106 businesses The Environmental Justice impacts based upon 2000 Census data are
described on Pages 4 4 to 4 -6 of the DEIS The DEIS concludes that the proposed project
is not expected to have disproportionately high and adverse human health and
environmental effects on low income or minority populations
Community Resources
Access to Prospect Cemetery is expected to be eliminated by either DSA M1 or
M2 Page 4 2 of the DEIS states that access to Prospect Cemetery will be evaluated
during final roadway design EPA believes that this is a known impact resulting from the
Military Cutoff Road Extension and access road options and associated impacts should

I
have been identified in the DEIS including potential impacts to jurisdictional wetlands
and streams The DEIS identifies an impact under DSA M1 and M2 to a driving range
(golf) under community facilities and services This is a commercial business ( #57 under
Business Relocations) and not a public or non profit community facility The DEIS does
identify that Holly Shelter Game Land is located in the project study area However
unlike the driving range it is a public and community facility as well as a gameland and
preservation area It is used extensively by the public EPA requests that inaccuracies
' contained in the DEIS be addressed in the FEIS
Mount Ararat AME Church a historic property, is also expected to be impacted
' by DSA M1 or M2 In addition the DEIS also indicates that grave sites in this cemetery
could also be impacted but does not quantify the potential number of grave sites In the
Appendix C relocation report it is provided that DSA U will reportedly impact 647 + /
' grave sites Wesley Chapel United Methodist Church (395 +/ graves) McClammy and
King Family Cemetery (17 +/ graves) and Pollock s Cemetery (235 +/ graves) The
number of grave sites in the relocation report for DSA M1 and M2 under TIP project
' number U 4751 is not provided Potential cemetery impacts for DSAs E H, O and R are
not identified in the report
Ogden Park is described on Page 4 2 of the DEIS and discusses the park boundary
that was designed to accommodate a future transportation corridor through the middle of
the county park In addition Pedestrian access to existing multi use path facilities and
' Ogden Park would be improved if pedestrian facilities are constructed There is no
identification of any proposed pedestrian facilities between the two sections of the park
Additional details concerning non profit relocations are provided in Section 4 12
of the DEIS DSA E H O and R will impact 3 churches including St John the Apostle
Catholic Church Angel Food Ministries and Topsail Baptist Church
Hampstead is an unincorporated community in Pender County and is an area
characterized as a home to four golf courses that are centered in large residential
developments The northern area of the project study area is characterized as being rural
with natural areas preserved for recreation and education The N C Wildlife Resources
Commission manages Holly Shelter Game Land and North Carolina State University
manages its blueberry research station There are numerous other public and private
mitigation sites and preserved lands in the project study area Notably there are several
NCDOT mitigation sites (associated with the I 1401US 17 /Wilmington Bypass project)
including but not limited to the Plantation Road Site Corbett Strip Residual Site and the
Corbett Tract Mitigation Site
Farmland Impacts
Impacts to prime farmlands are described in Section 4 3 on the impacts to the
physical environment Farming and agricultural practices are a human activity and
represent businesses In addition to N C Executive Order 96 on the Conservation of
Prime Agricultural and Forest Lands the Lead Federal Agency (i e USACE) is required

to comply with the Farmland Protection Policy Act (FPPA) of 1981 for those NEPA
actions impacting pnme farmland as defined under 7 CFR Part 658 Please see
http / /www nres usda gov for more information
Prime farmland impacts are quantified for each DSA in Table 4 5 Impacts are
very specifically quantified as follows DSA E H +M1 67 48 acres DSA O +M2 58 10
acres DSA R +M1 58 12 acres DSA U +M1 49 88 acres and DSA U +M2 49 88 acres
Section 4 3 3 does not reference the required AD 1006 forms EPA is unable to locate the
forms in the DEIS appendices EPA requests how these very exact impact numbers were
calculated and if the Natural Resource Conservation Service (NRCS) completed AD
1006 forms for the DSAs The DEIS does not provide any further information
concerning potential N C Voluntary Agricultural Districts (VADs) or what measures to
minimize fanning impacts might be appropriate (e g , Equipment access across dissected
fields) According to the N C Department of Agriculture and Consumer Services
Pender County in 2008 was working towards establishing VADs
Sections 3 3 3 and 4 3 3 of the DEIS fails to provide the relative importance of
farming and other forest products for the Pender County economy and its employment
contribution Prior to the issuance of a FEIS EPA recommends that supplemental
information and analysis be provided regarding prime farmland and other agricultural
land impacts resulting from the proposed project
Noise Receptor Impacts
Impacts to noise receptors are described in Section 4 3 on the impacts to the
physical environment Human environment impacts are described in Section 4 1 Noise
impacts are based upon receptor criteria to the human environment Total noise receptor
impacts are shown in Table 4 4 However design year 2035 traffic noise levels that are
expected to approach or exceed the NAC are different than from the table Table S 1
includes the actual noise receptor impacts for each DSA DSA E H +M 1 257 receptors
DSA O +M2 236 receptors DSA R +M1 248 receptors DSA U +M1 310 receptors and
DSA U +M2 304 receptors
Based upon the NCDOT Traffic Noise Abatement Policy potentially 9 noise wall
bamers are expected to meet the NCDOT s current feasibility and reasonableness criteria
as identified on Page 4 11 The decision on the construction of the cost effective noise
barriers to provided needed noise abatement is being deferred by NCDOT until final
design more in depth' Traffic Noise Modeling (TNM) and additional public
involvement
Histonc Properties and Archaeological Sites
DSA U has 4 historic property adverse effects including Poplar Grove Scott s
Hill Rosenwald School and Wesleyan Chapel united Methodist Church and Mount Ararat
AME Church The Mount Ararat AME Church impact (adverse effect) is associated with
DSA Ml or M2 Thus all of the DSAs have at least one adverse effect on a historic

property There is no identified avoidance alternative The impacts to historic properties
' from DSA U are based upon using a freeway design along portions of existing US 17
and including parallel service roads Some of the impacts to historic properties may be
avoided or minimized if other reasonable designs are pursued during final design
Archaeological surveys have not been conducted for the DSAs and they are not proposed
to be conducted until after the selection of the preferred alternative
' Hazardous Materials
Section 3 3 5 on hazardous materials is not accurate and should be corrected in
' the FEIS Hazardous materials are regulated by the U S Department of Transportation
(USDOT) under 49 CFR Parts 100 185 This section of the DEIS does not conform to
other NEPA documents prepared by the NCDOT and reviewed by the EPA Hazardous
' materials are identified in the Impacts to the Physical Environment section and not in
the Human Environment Impact section
Hazardous wastes are regulated under the Resource Conservation Recovery Act
(RCRA) of 1976 as amended Hazardous substances are regulated under the
Comprehensive Environmental Response Compensation and Liability Act (CERCLA) of
1980 as amended The NEPA/Section 404 Merger Guidance provides additional details
concerning these laws and requirements Some of the identified geoenvironmental sites
described in this section may meet the cleanup requirements of more than one Federal
statute Only 5 of the 28 sites referenced in Section 3 3 5 are described in Section 4 3 5
These 5 sites are associated with DSA M1 and M2 There is no qualifying description of
the phrase low geoenvironmental wipacts Details concerning the other 23 hazardous
material sites is not provided in the DEIS Supplemental information and analysis should
be provided to EPA prior to the issuance of the FEIS This future geotechnical
investigation and evaluation should include the potential for existing hazardous material
sites and underground storage tanks to contaminate shallow groundwater resources
Natural Resources Impacts
Groundwater Impacts and Water Supply Wells
Sections 3 5 3 and 4 5 3 of the DEIS discuss impacts to the project area water
supply Groundwater aquifers are generally described in Section 3 5 3 1 The Cape Fear
Public Utility Authority ( CFPUA) is reported to have several existing and proposed well
sites associated with the Nano Water Treatment Plant (NWTP) Section 4 5 3 1 1
identifies that DSA M1 and M2 cross two existing well sites operated by the CFPUA
Additionally DSA M2 would also impact two additional existing CFPUA well sites (to
total 4) and a proposed well site DSA M2 is anticipated to impact a raw water line and
concentrate discharge line that provides a connection to several anticipated well sites
The DEIS states that estimates provided by CFPUA include the loss of up to 6 million
gallons per day (mgd) of anticipated future water supplies for the project study area The
DEIS lacks any specificity as to what the loss of the existing water supplies might be

what the potential to feasibly relocate the wells might be or what the costs might be
should either DSA M1 or M2 be selected
DSA U is also expected to impact 3 existing transient non community water
supply wells in the vicinity of the proposed US 17 interchange at Sidbury Road and Scott
Hill Loop Road Transient non community wells are described as being ones that serve
25 or more people at least 60 days out of the year at facilities such as restaurants and
churches The DEIS does not provide any additional information regarding these impacts
including current withdrawal rates the availability of alternative drinking water supplies
the costs to owners to relocate wells etc
The DEIS does not address what the potential for contamination to existing well
fields will be The depth and distance of CFPUA well sites is not provided with respect to
the alternatives under consideration The potential threat from hazardous material
accidents to other existing wellheads is not evaluated in the DEIS Section 5 3 1 4
identifies 33 CFR 320 4(m) with respect to water supply impacts EPA has provided the
following specific USACE citation
Water is an essential resource basic to human survival economic growth and the
natural environment Water conservation requires the efficient use of water resources in
all actions which involve the significant use of water or that significantly affect the
availability of water for alternative uses including opportunities to reduce demand and
improve efficiency in order to minimize new supply requirements Actions affecting water
quantities are subject to Congressional policy as stated in section 101(g) of the Clean
Water Act which provides that the authority of states to allocate water quantities shall
not be superseded abrogated or otherwise impaired
The full impacts to water supplies are not detailed in the DEIS EPA believes that
the construction of either DSA M1 or M2 will potentially violate this Clean Water Act
requirement NCDOT should also refer to the Safe Drinking Water Act for additional
requirements The DEIS fails to provide any potential avoidance or minimization
measures or mitigation to address the loss of current and future water supplies in the
project study area
Jurisdictional Streams and Wetlands
Surface water impacts are included to Sections 3 5 3 2 and 4 5 3 2 of the DEIS A
total of 134 streams were identified in the project study area Four (4) streams within one
mile downstream of the project study area have been designated as High Quality Waters
(HQW) and one stream within one mile downstream has been designated Outstanding
Resource Waters (ORW) These five streams are Futch Creek Old Topsail Creek Pages
Creek an unnamed tributary to the Atlantic Intercoastal Waterway (AIWW) and Howe
Creek respectively There are no Section 303(4) listed impaired waters in the project
study area The physical characteristics of all of the streams in the project study area are
provided in Table 3 7

J
1
Jurisdictional stream impacts for the DSAs are as follows DSA E H +M 1 24 531
1
linear feet or 4 6 miles DSA O +M2 13 842 linear feet or 2 6 miles DSA R +M1 24 571
linear feet or 4 6 miles DSA U +M1 15 450 linear feet or 2 9 miles and DSA U +M2
8 786 linear feet or 1 7 miles EPA compared stream impacts for the DSAs to similar
multi lane facilities identified and analyzed under the 2011 Merger Performance
Measures Environmental Quality Indicators (Baseline and 2010 data) Stream impacts
per mile for four of the DSAs were a magnitude or more above the 2004 -2009 Baseline
1
of 410 linear feet/mile and the 2010 Eastern new location value of 200 linear feet /mile
Except for DSA U +M2 of 523 linear feet/mile the other 4 DSAs had impacts per mile as
follows 1 402 linear feet /mile (Greater than 3 times the Baseline) 834 linear feet/mile
1
(Greater than 2 times the Baseline) 1 437 linear feet/mile (Greater than 3 times the
Baseline) and 858 linear feet /mile (Greater than 2 times the Baseline) EPA does not
believe that impacts to jurisdictional streams will be substantially reduced from these
1
DEIS values following the selection of a LEDPA due to constructability issues within the
project study area
1
A total of 85 ponds and 286 jurisdictional wetland systems were identified in the
project study area The physical characteristics of these surface waters are detailed in
Tables 3 8 and 3 9 of the DEIS By EPA s estimate as many as 43 of the 85 ponds are
classified as stormwater ponds NCDOT provided the DWQ Wetland rating for each of
the 286 wetland systems The DEIS did not provide wetlands ratings using the multi
agency accepted North Carolina Wetlands Assessment Methodology (NCWAM)
Jurisdictional wetland impacts for the DSAs are as follows DSA E H +M 1 246 1
acres DSA O +M2 384 4 acres DSA R +M1 297 4 acres, DSA U +M1 218 4 acres and
DSA U +M2 283 8 acres Impact calculations were based on preliminary design slope
stake limits plus an additional 25 feet EPA does not anticipate that final impact numbers
to jurisdictional wetlands will be reduced from these specific impact estimates
Conversely recent highway projects in the Coastal Plain of N C have shown an increase
in wetland impacts following the selection of the LEDPA due to constructability issues
brought forward by NCDOT (e g R 3620 Poorly drained soils requiring that the road
bed be raised by 4 to 6 feet above natural ground elevation) EPA compared wetland
impacts for the DSAs to similar multi lane facilities identified and analyzed under the
2011 Merger Performance Measures Environmental Quality Indicators (Baseline and
2010 data) Similar to the stream impact comparisons, wetland impacts per mile for each
DSA greatly exceeded the Baseline and 2010 Eastern new location project values of 2 1
acres /mile and 1 5 acres /mile, respectively EPA estimates the following DSA E H +M1
14 1 acres /mile DSA O +M2 23 2 acres /mile DSA R +M1 17 4 acres /mile DSA U +M1
12 1 acres /mile and DSA U +M2 16 9 acres /mile These wetland impacts per mile range
from 6 to 10 times the 2004 2009 Baseline for an Eastern new location project EPA does
not believe that impacts to jurisdictional wetlands will be substantially reduced from
these DEIS values following the selection of a LEDPA due to possible constructability
issues and potential NCDOT safety concerns regarding 3 1 side slopes and the use of
guardrails along a future high speed facility

Section 4 5 4 1 contains a discussion on avoidance and minimization of impacts to
jurisdictional resources Minimum hydraulic badges are recommended at Site #6, UT to '
Island Creek (Wetlands ISA and ISB) and Site #15 and Island Creek and UT to Island
Creek (Wetlands HBSF and HBSH) Dual 200 foot bridges are recommended at Site #16
UT to Island Creek (Wetland HBSD2) Seventeen (17) major hydraulic crossings were '
identified during the CP 2A field meeting Thirteen (13) structures are various sized
reinforced concrete box culverts (RCBC) and one existing RCBC 1s proposed to be
extended The DEIS does not identify any additional avoidance and minimization
measures to reduce impacts to jurisdictional streams and wetlands such as reduced
median widths, increased side slopes the use of single bridges and tapered medians
retaining walls reduced paved shoulders etc '
Compensatory mitigation for unavoidable impacts to jurisdictional resources is
very generally discussed in Section 4 5 4 12 of the DEIS NCDOT proposes to seek on ,
site mitigation opportunities and utilize the N C Ecosystem Enhancement Program (EEP)
for off site mitigation needs Considering the magnitude and severity of the impacts to
high quality streams and wetlands EPA requests a conceptual mitigation plan prior to the ,
selection of a LEDPA and the issuance of a FEIS There are no details as to what
mitigation opportunities are available on site and what credits or mitigation assets are
available through the EEP Considering the location of the proposed project and the '
presence of high quality waters of the U S the conceptual mitigation plan should be
sufficiently detailed and provide for full compensation for lost functions and values to
high quality resources '
During the Merger process EPA also learned that several NCDOT mitigation
sites associated with the 1 140 /Wilmington Bypass might be impacted from the proposed '
project including the Plantation Road Site From Figure IOC of the DEIS it appears
that the 34 acre Residual Site might also be impacted from several of the DSAs From
Figure l OD it appears that the Corbett Strip Residual Site is probably going to be '
impacted from several of the DSAs Discussions in the DEIS regarding the potential
impacts to these NCDOT mitigation sites is included in Section 3 3 8 3 Impacts to these
sites are not specifically identified in the summary table S 1 but are addressed Table '
4 3 8 3 Additional information including credit/debit ledgers restrictive covenants and
easements and other property records is being requested by EPA prior to the selection of
a LEDPA and the issuance of a FEIS NCDOT should avoid impacting approved '
mitigation sites that were required for compensation for previous highway project
impacts (i e I- I40/US 17 Wilmington Bypass)
Terrestrial Forest Impacts
Terrestrial forest impacts include Table S 1 summary of impacts for the DSAs are
as follows DSA E H +M1 518 acres DSA O +M2 512 acres DSA R +M1 472 acres
DSA U +M1 406 acres and DSA U +M2 455 acres These impact numbers do not match
the terrestrial community impacts shown in Table 4 9 Eliminating the impact estimates
to maintain and disturbed communities still does not provide for an accurate estimate of
terrestrial forest impacts The FEIS should identify how the terrestrial forest impacts

ere calculated for each DSA and what natural communities were included in the
estimates EPA notes the comment concerning Executive Order 13112 on Invasive
species and NCDOT s Best Management Practices (BMPs) EPA acknowledges the
NCDOT invasive plant species list in Section 3 5 2 12 of the DEIS The FEIS should
identify specific BMPs to be followed to minimize the spread of invasive plant species
following construction and provide detailed environmental commitments on how these
BMPs are to be implemented It would be useful to the public and decision makers if
NCDOT could provide previous project examples where these invasive species BMPs
have cost effectively resulted in the long term elimination or reduction in invasive plant
species following roadway construction activities There are numerous Significant
Natural Heritage Areas that are present in the project study area and the proposed new
location alternatives represent a significant long term threat to these unique habitats
resulting from the introduction of aggressive and persistent roadside invasive plant
species
Threatened and Endangered Species
Sections 3 5 4 3 and 4 5 4 3 address protected species including Federally listed
species under the Endangered Species Act (ESA) Considering the potential impacts to
NCWRC s managed Holly Shelter Game Land the DEIS should have also identified any
State listed species under their Jurisdictional and within the project study area Twelve
(12) Federally listed threatened or endangered species are shown on Table 3 10
According to a copy of the U S Fish and Wildlife Service ( USFWS) letter dated October
5, 2011 there are numerous unresolved issues concerning threatened and endangered
species including Red cockaded woodpecker (RCW) and issues associated with the
endangered plants and NCDOT mitigation sites that will be impacted from DSAs E H 0,
and R EPA s defers to the NCWRC and USFWS concerning specific requirements
involving Section 7 of the ESA and other wildlife issues Generally EPA has significant
environmentally concerns regarding wildlife habitat loss and fragmentation resulting
from most of the DSAs including E -H O and R Potential animal /vehicle collisions
involving new location multi lane high speed facilities in rural areas in close proximity
to game lands and other preservation areas need to be analyzed and studied prior to the
issuance of a FEIS
Other Environmental Issues
EPA notes the other DEIS comments and issues concerning Air Quality including
transportation conformity Mobile Source Air Toxics (MSATs) FEMA floodplain
impacts socio economic issues, land use plans, pedestrian and bike path issues
gameland and preservation area direct impacts and indirect and cumulative effects (ICE)
resulting from the proposed project
Regarding socio economic issues, EPA acknowledges the following DEIS
comment It is anticipated that the proposed project will enhance longterm access and
connectivity opportunities to New Hanover and Pender County and will support local
regional and statewide commitments to transportation improvement and economic

viability Enhanced long term access and connectivity are not part of the purpose and
need for the proposed project that EPA and other Merger Team agencies agreed with in
2006
Impacts to Holly Shelter Game Land Corbett Tract Mitigation Site Corbett Tract
Residual Strip Plantation Road Site 34 Acre Residual Site 22 Acre Residual Site and
Blake Savannah are detailed for the different DSAs in Table 4 7 Impacts to Holly
Shelter Game Land and the 22 Acre Residual Site should be removed from the table as
all of the impacts are zero to these two areas The total impacts for the DSAs are as
follows DSA E H +M1 4 43 acres DSA O +M2 42 94 acres DSA R +M1 5 01 acres
DSA U +M1 3 24 acres and DSA U +M2 34 40 acres Most of the impacts are
associated with DSA M2 and are to the Plantation Road and 34 Acre Residual mitigation
sites These significant impacts should be included in Table S 1 and future impact tables
EPA does not agree with the assumptions and conclusions in the indirect and
cumulative effects section of the DEIS The analysis cites travel time benefits without
providing the specific travel time savings or other traffic analyses required to make such
a claim The analysis ignores a critical component water supply within the project study
area and the importance it may have on current and future development and land uses
Furthermore the qualitative ranking in Tables 4 18 and 4 19 are not supported by actual
data or facts These ranking appear to be very subjective and based upon past trends and
not upon more recent socio economic factors The relationship of the information
contained in Table 4 20 compared to the proposed project is not made clear in Section
4 6 Considering the significant impact predicted for the project study area watersheds
EPA is requesting a review copy of the indirect and cumulative quantitative water quality
impacts analysis that was requested by the NCDWQ and prior to the issuance of a FEIS

1r-
CH g �0A0
RECEIVED
Division of Highways
United States Department of the Interior OCT 01 2011
FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box 33726
Raleigh North Carolina 27636 3726
October 5, 2011
Gregory J Thorpe, PhD
Project Development and Environmental Analysis
North Carolina Department of Transportation
1548 Mail Service Center
Raleigh, North Carolina 27699 1548
Dear Dr Thorpe
preconstrucUon
project Developnzet d
EnVtronrnental Analysis aranch
This letter is in response to your August 29, 2011 letter which requested comments from the U S
Fish and Wildlife Service (Service) on the Draft Environmental Impact Statement (DEIS) for the
proposed SR 1409 (Military Cutoff Road) Extension and proposed US 17 Hampstead Bypass,
New Hanover and Pender Counties, North Carolina (TIP No U 4751 and R 3300) These
comments are provided in accordance with provisions of the National Environmental Policy Act
(42 U S C 4332(2)(c)) and Section 7 of the Endangered Species Act (ESA) of 1973 as amended
(16 U S C 1531 1543)
For U 4751 the North Carolina Department of Transportation ( NCDOT) proposes to extend
Military Cutoff Road as a six lane divided roadway on new location from its current terminus at
US 17 (Market Street) in Wilmington north to an interchange with the US 17 Wilmington
Bypass For R 3300 NCDOT proposes to construct the US 17 Hampstead Bypass as a freeway
on new location The US 17 Hampstead Bypass may connect to the proposed Military Cutoff
Road Extension at the existing US 17 Wilmington Bypass and extend to existing US 17 north of
Hampstead There are currently five remaining alternatives under consideration
The Service has been actively involved for several years in early coordination on this project
through the combined NEPA/404 Merger Process, and many of our previous comments and
recommendations are reflected in the DEIS The Service has helped narrow the range of
reasonable alternatives and assisted in refining remaining alternatives
The cover page of the DEIS incorrectly states that the Service is a Cooperating Agency
Although the Service has participated in early coordination through the Merger Process for years,
the Service was not formally requested to be a Cooperating Agency (as per 40 CFR Section
15016), nor has the Service participated in the preparation of the DEIS
Page 2 29 states that a total right of way width of 250 to 350 feet is proposed for Hampstead
Bypass Alternatives E H O and R, and that a total right of way width of 250 to 520 feet is
proposed for Alternative U This statement appears inconsistent with the `Green Sheet project
commitment Roadway widening improvements associated with Hampstead Bypass along
existing US 17 in this area [in the vicinity of Holly Shelter Game Land] will not exceed a width

of 200 feet in order to maintain connectivity between red cockaded woodpecker foraging habitat '
partitions This commitment also appears on page 4 37 For red cockaded woodpecker (RCW
Picoides borealis) habitat east of US 17 to be counted towards the total habitat acreage within
foraging partitions EC and 17 it is imperative that the total cleared area not exceed 200 feet '
Page 3 49 incorrectly states that green sea turtles (Chelonia mydas) do not nest in North
Carolina Green sea turtles do sporadically nest in North Carolina in small numbers Page 3 49
also states Loggerheads occasionally nest on North Carolina beaches Actually, loggerhead ,
sea turtles (Caretta caretta) consistently nest in North Carolina
Table 4 7 on page 4 17 displays the impacts to certain preservation areas Especially '
problematic are the impacts to the Plantation Road Site This site contains several stems of the
federally endangered rough leaved loosestrife (Lysimachia asperulaefolia) Page 3 16 correctly
states that the Plantation Road Site was, as per the conservation measures in the January 2002 '
NCDOT Biological Assessment (BA) and May 22 2002 Service Biological Opinion (BO) for
the 140 Connector (R 2405A), to be maintained as a preservation area for rough leaved
loosestrife Alternatives M2 +0 and M2 +U would impact a large portion of the preservation site '
as well as a significant number of rough leaved loosestrife stems The Service opposes these two
alternatives Although the other alternatives would have much smaller impacts to this
preservation area and may not directly impact rough - leaved loosestrife stems, the designs should '
be modified to further avoid or minimize impacts
The Corbett Tract Mitigation Site, as per the aforementioned BA and BO, was, in addition to
providing wetland mitigation to also serve as a preservation site for rough leaved loosestrife At
the time of the 2002 Section 7 consultation for the 140 Connector this site had over 100 stems
of rough leaved loosestrife Although the M1 alternatives would only have small impacts to this
site (0 08 — 0 58 acre) the Service strongly recommends refining the designs to further avoid or
mimm»e these impacts
Four of the five remaining alternatives would impact the Corbett Tract Residual Strip to some
degree (0 27-3 55 acres) Asper the conservation measures in the aforementioned BA and BO,
this area was to be utilized' as a buffer between the I -40 Connector and adjacent rough leaved
loosestrife clusters Although rough leaved loosestrife is not known to occur within this area,
impacts should be avoided or minimized in accordance with the intent of the conservation
measures within the BA and BO
Table 4 17 on page 4 35 lists federally protected species by county Golden sedge (Carex lutea)
is now listed in New Hanover County with a record status of probable /potential American
chaffseed (Schwalbea americana) is incorrectly listed in New Hanover County It is actually
only listed in Pender County as a historic occurrence
Page 4 37 states It is anticipated that the USACE will request of the USFWS that formal
consultation for red cockaded woodpecker be initiated after the least environmentally friendly
damaging practicable alternative for the proposed protect has been identified The Service
believes it would be prudent to delay formal Section 7 consultation until at least after
Concurrence Point 4A (CP4A) in the Merger Process when more refined design information is
available If consultation were to begin prior to CP4A, it is likely that the RCW foraging habitat
removal locations and extent would need to be repeatedly revised thus necessitating re initiation

of Section 7 consultation Due to encroaching private development, the habitat for RCWs in the
protect area and the status of the RCW groups have changed significantly in the last few years
and will likely continue to change As such, the Service strongly recommends that the timing of
formal Section 7 consultation be carefully planned so as to avoid multiple re initiations It is
very possible that biological conclusions may change within the next few years
Page 4 39 and Table 4 17 state that the biological conclusion for golden sedge (Carex lutea) is
May Affect Likely to Adversely Affect" The Service believes that this remains to be
determined As stated in the DEIS, no specimens of golden sedge have been observed within the
project area Although habitat is present and the closely associated Cooley s meadowrue
(Thalictrum cooleyi) is present, the Service believes that more surveys are warranted If
additional and appropriately timed surveys do not reveal any specimens of golden sedge, the
Service would concur with a no effect conclusion for this species
Pages 4 38 through 4 41 address the effects to Cooley's meadowrue (Thahctrum cooleyi) and
rough leaved loosestrife (Lysimachia asperulaefolca) Given the disparate degree of effects to
these species depending upon the alternative selected graphics depicting the location of the
known locations of these species in relation to the different alternatives would be helpful
The Service would like to emphasize the serious and complex issues regarding the effects of this
project to RCWs As the DEIS points out the RCWs located in the adjacent Holly Shelter Game
Land are part of the Coastal North Carolina Primary Core Recovery Population within the Mid
Atlantic Coastal Plain Recovery Unit The Service has diligently worked with NCDOT to refine
the alternative designs to minimize the level of take on RCWs We acknowledge the efforts put
forth by NCDOT to reduce the level of take on this species Based on current information it
appears that the project will still result in a take of at least one active RCW group Given the fact
that the Coastal North Carolina Primary Core Population is still far from achieving its minimum
size required for delistuig (350 potential breeding groups) the loss of even one potential
breeding group is significant Additional coordination is needed to resolve this issue
The Service appreciates the opportunity to review this project If you have any questions
regarding our response please contact Mr Gary Jordan at (919) 856 -4520, ext 32
Sincerely,
Pete Benjamin
Field Supervisor
Electronic copy Chris Milrtscher USEPA Raleigh, NC
Travis Wilson NCWRC, Creedmoor NC

iy /
� 9
United States Department of the Interior .�
P NA E i�� '
'�►+ OFFICE OF THE SECRETARY
Office of Environmental Policy and Compliance
Richard B Russell Federal Building '
75 Spring Street S W
Atlanta Georgia 30303
ER 11/881 '
9043 1
November 22 2011
Mr Brad Shaver
U S Army Corps of Engineers
Wilmington Regulatory Office
69 Darlington Avenue
Wilmington NC 28403 1343
Re Comments and Recommendations for the Draft Environmental Impact Statement (DEIS)
for Improvements to U S 17 Hampstead Bypass New Hanover and Pender Counties
NC
Dear Mr Shaver
The U S Department of Interior (Department) has reviewed the Draft Environmental Impact
Statement (DEIS) for the proposed SR 1409 (Military Cutoff Road) Extension and proposed US
17 Hampstead Bypass located in New Hanover and Pender Counties North Carolina (TIP No
U 4751 and R 3300) These comments are provided in accordance with provisions of the
National Environmental Policy Act (42 U S C 4332(2)(c)) and Section 7 of the Endangered
Species Act (ESA) of 1973 as amended (16 U S C 1531 1543)
For U 4751 the North Carolina Department of Transportation ( NCDOT) proposes to extend
Military Cutoff Road as a six lane divided roadway on new location from its current terminus at
US 17 (Market Street) in Wilmington north to an interchange with the US 17 Wilmington
Bypass For R 3300 NCDOT proposes to construct the US 17 Hampstead Bypass as a freeway
on new location The US 17 Hampstead Bypass may connect to the proposed Military Cutoff
Road Extension at the existing US 17 Wilmington Bypass and extend to existing US 17 north of
Hampstead There are currently five remaining alternatives under consideration
The Department has been actively involved for several years in early coordination on this project
through the combined NEPA /404 Merger Process and many of our previous comments and
recommendations are reflected in the DEIS The Department has helped narrow the range of
reasonable alternatives and assisted in refining remaining alternatives
The cover page of the DEIS incorrectly states that the Service is a Cooperating Agency
Although the Service has participated in early coordination through the Merger Process for years

8 US 17 Hampstead Bypass Project
the Service was not formally requested to be a Cooperating Agency (as per 40 CFR Section
1501 6) nor has the Service participated in the preparation of the DEIS
Page 2 29 states that a total right of way width of 250 to 350 feet is proposed for Hampstead
Bypass Alternatives E H O and R and that a total right of way width of 250 to 520 feet is
proposed for Alternative U This statement appears inconsistent with the Green Sheet project
commitment Roadway widening improvements associated with Hampstead Bypass along
existing US 17 in this area [in the vicinity of Holly Shelter Game Land] will not exceed a width
of 200 feet in order to maintain connectivity between red cockaded woodpecker foraging habitat
partitions This commitment also appears on page 4 37 For red cockaded woodpecker (RCW
Picoides borealis) habitat east of US 17 to be counted towards the total habitat acreage within
foraging partitions EC and 17 it is imperative that the total cleared area not exceed 200 feet
Page 3 49 incorrectly states that green sea turtles (Chelonia mydas) do not nest in North
Carolina Green sea turtles do sporadically nest in North Carolina in small numbers Page 3 49
also states Loggerheads occasionally nest on North Carolina beaches Actually loggerhead
sea turtles (Caretta caretta) consistently nest in North Carolina
Table 4 7 on page 4 17 displays the impacts to certain preservation areas Especially
problematic are the impacts to the Plantation Road Site This site contains several stems of the
federally endangered rough leaved loosestrife (Lysimachla asperulaefolia) Page 3 16 correctly
states that the Plantation Road Site was as per the conservation measures in the January 2002
NCDOT Biological Assessment (BA) and May 22 2002 Service Biological Opinion (BO) for
the 140 Connector (R 2405A) to be maintained as a preservation area for rough leaved
loosestrife Alternatives M2 +0 and M2 +U would impact a large portion of the preservation site
as well as a significant number of rough leaved loosestrife stems The Department opposes these
two alternatives Although the other alternatives would have much smaller impacts to this
preservation area and may not directly impact rough leaved loosestrife stems the designs should
be modified to further avoid or minimize impacts
The Corbett Tract Mitigation Site as per the aforementioned BA and BO was in addition to
providing wetland mitigation to also serve as a preservation site for rough leaved loosestrife At
the time of the 2002 Section 7 consultation for the 140 Connector this site had over 100 stems
of rough leaved loosestrife Although the M1 alternatives would only have small impacts to this
' site (0 08 — 0 58 acre) the Department strongly recommends refining the designs to further avoid
or minimize these impacts
Four of the five remaining alternatives would impact the Corbett Tract Residual Strip to some
degree (0 27 — 3 55 acres) As per the conservation measures in the aforementioned BA and BO
this area was to be utilized as a buffer between the 140 Connector and adjacent rough leaved
' loosestrife clusters Although rough leaved loosestrife is not known to occur within this area
impacts should be avoided or minimized in accordance with the intent of the conservation
measures within the BA and BO
Table 4 17 on page 4 35 lists federally protected species by county Golden sedge (Carex lutea)
is now listed in New Hanover County with a record status of probable /potential American
' 2

US 17 Hampstead Bypass Project
chaffseed (Schwalbea americana) is incorrectly listed in New Hanover County It is actually
only listed in Pender County as a historic occurrence
Page 4 37 states It is anticipated that the USACE will request of the United States Fish and
Wildlife Service (USFWS) that formal consultation for red cockaded woodpecker be
initiated after the least environmentally friendly damaging practicable alternative for the
proposed project has been identified The Department believes it would be prudent to delay
formal Section 7 consultation until at least after Concurrence Point 4A (CP4A) in the Merger
Process when more refined design information is available If consultation were to begin prior to
CP4A it is likely that the RCW foraging habitat removal locations and extent would need to be
repeatedly revised thus necessitating re initiation of Section 7 consultation Due to encroaching
private development the habitat for RCWs in the project area and the status of the RCW groups
have changed significantly in the last few years and will likely continue to change As such the
Service strongly recommends that the timing of formal Section 7 consultation be carefully
planned so as to avoid multiple re initiations It is very possible that biological conclusions may
change within the next few years
Page 4 39 and Table 4 17 state that the biological conclusion for golden sedge (Carex lutea) is
May Affect Likely to Adversely Affect The Department believes that this remains to be
determined As stated in the DEIS no specimens of golden sedge have been observed within the
project area Although habitat is present and the closely associated Cooley s meadowrue
(Thahctrum cooleyi) is present the Department believes that more surveys are warranted If
additional and appropriately timed surveys do not reveal any specimens of golden sedge the
Department would concur with a no effect conclusion for this species
Pages 4 38 through 4 41 address the effects to Cooley s meadowrue (Thahctrum cooleyi) and
rough leaved loosestrife (Lysimachza asperulaefolia) Given the disparate degree of effects to
these species depending upon the alternative selected graphics depicting the location of the
known locations of these species in relation to the different alternatives would be helpful
We would like to emphasize the serious and complex issues regarding the effects of this project
to RCWs As the DEIS points out the RCWs located in the adjacent Holly Shelter Game Land
are part of the Coastal North Carolina Primary Core Recovery Population within the Mid
Atlantic Coastal Plain Recovery Unit The Department has diligently worked with NCDOT to
refine the alternative designs to minimize the level of take on RCWs We acknowledge the
efforts put forth by NCDOT to reduce the level of take on this species Based on current
information it appears that the project will still result in a take of at least one active RCW group
Given the fact that the Coastal North Carolina Primary Core Population is still far from
achieving its minimum size required for dehstmg (350 potential breeding groups) the loss of
even one potential breeding group is significant Additional coordination is needed to resolve
this issue
We appreciate the opportunity to review this project If you have any questions regarding our
response I can be reached on [phone] or via email at loyice stanley(oaos doi gov

US 17 Hampstead Bypass Project
cc Jerry Ziewitz — FWS
Gary Jordan FWS
Brenda Johnson USGS
David Vela — NPS
Tommy Broussard — BOEM
OEPC — WASH
Sincerely
r �
Joyce Stanley MPA
Regional Environmental Protection Assistant
for
Gregory Hogue
Regional Environmental Officer
4

North Carolina
Department of Administration
Beverly Eaves Perdue Governor
November 15 2011
Ms Olivia Farr
N C Department of Transportation
Transportation Building
1548 Mail Service Center
Raleigh NC
Dear Ms Farr
Moses Carey Jr Secretary
Re SCH File # 12- E4220 -0061, DEIS, Military cutoff extension from US 17 (Market Street) to
the proposed I -140 in New Hanover County & US 17 bypass of Hampstead in New
Hanover & Pender counties
The above referenced environmental impact information has been submitted to the State Clearinghouse
under the provisions of the National Environmental Policy Act According to G S 113A -10 when a
state agency is required to prepare an environmental document under the provisions of federal law the
enti ironmental document meets the provisions of the State Environmental Policy Act Attached to this
letter for your consideration are additional comments made by agencies in the course of this review
If any further environmental review documents are prepared for this project they should be forwarded to
this office for intergovernmental review
Should you have any questions please do not hesitate to call
Sincerely
William E H Creech
Attachments
cc Region O
Wailing Address Telephone [phone] Location Address
1301 Mad Service Center Fax [phone] West Jones Street
Raleigh NC 27699 1301 State Courier #51 -01-00 Raleigh North Carolina
e mad state clearinghouse @doa nc goti
An Equal Opportunity/.4frmatrve Achon Employer

L _II
NORTH CAROLINA STATE CLEARINGHOUSE
DEPARTMENT OF ADMINISTRATION
INTERGOVERNMENTAL REVIEW
COUNTY NEW HANOVER
PENDER
MS SUSAN DECATSYE
CLEARINGHOUSE COORDINATOR
DEPT OF AGRICULTURE
1001 MSC - AGRICULTURE BLDG
RALEIGH NC
F02 HIGHWAYS AND ROADS
STATE NUMBER
DAVE RECZIVED
AGENCY RESPONSE
REVIEW CLOSED
12 -E -4220 -0061
09/07/2011
10/25/2011
10/30/2011
REVIEW DISTRIBUTION
CAPE FEAR COG
CC &PS - DIV OF EMERGENCY MANAGEMENT
DENR - COASTAL MGT
DENR LEGISLATIVE AFFAIRS
DEPT OF AGRICULTURE
DEPT OF CULTURAL RESOURCES
DEPT OF TRANSPORTATION
PROJECT INFORMATION
APPLICANT N C Department of Transportation
TYPE National Environmental Policy Act
Draft Environmental Impact Statement
DESC Military cutoff extension from US 17 (Market Street) to the proposed I -140 in New
Hanover County & US 17 bypass of Hampstead in New Hanover & Pender counties
CROSS - REFERENCE NUMBER 06 -E- 4220 -0107
The attached pro)ect has been submitted to the N C State Clearinghouse for
intergovernmental review Please review and submit your response by the above
indicated date to 1301 Mail Service Center Raleigh NC 27699 -1301
If additional review time is needed please contact this office at (919)807 -2425
AS A RESULT OF T IS REVIEW THE FOLLOWING IS SUBMITTED ❑ NO COMMENT
SIGNED BY )(OZ 6; f
T_
DAT
F1COMMENTS ATTACHED
` lk'i
O
F
wool
DON
y
` lk'i

cu TV
N
Steven W Troxler North Carolina Department of Agriculture Vernon cox
Commissioner and Consumer Services LnN ironmental Programs
Agricultural Services Specialist
Ms Sheila Green October 31 2011
State Clearinghouse
N C Department of Administration
1301 Mail Service Center
Raleigh North Carolina 27699 1301
State # 12 E 4220 0061
RE Proposed extension from US 17 to the proposed 1 -140 in New Hanover County and US 17 bypass of
Hampstead in New Hanover and Pender Counties
Dear Ms Green
Thank you for the opportunity to comment on the proposed extension from US 17 to the proposed 1 140
in New Hanover County and US 17 bypass of Hampstead in New Hanover and Pender Counties The
North Carolina Department of Agriculture and Consumer Services (NCDA &CS) is concerned about the
conversion of North Carolinas faun and forest lands to other uses Due to the importance of agricultural
activities in the area as well as the economy of the entire state NCDA &CS strongly encourages the
project planners to avoid conversion of agricultural land to other uses whenever possible When
avoidance is not possible all reasonable efforts to minimize impacts to farming operations and
agricultural land should be implemented
tctfully
n Cox
Environmental Programs Specialist
- ��0d Late
r
E mail vemon cox @ncagr gov
1001 Mail Service Center Raleigh North Carolina 27699 1001 [phone] • Fax [phone]
TTY 1-800 -735 2962 Voice 1 877 735 -8200
An Equal Opportunity Affirmative Action Employer

North Carolina
Department of Administration
Beverly Eaves Perdue Governor
November 7, 2011
Ms Olivia Farr
N C Department of Transportation
Transportation Building
1548 Mall Service Center
Raleigh NC
Dear Ms Farr
Moses Carey Jr Secretary
Re SCH File # 12 -E -4220 -0061, DEIS, Military cutoff extension from US 17 (Market Street) to
the proposed I -140 in New Hanover County & US 17 bypass of Hampstead in New
Hanover & Pender counties
The above referenced environmental impact information has been submitted to the State Clearinghouse
under the provisions of the National Environmental Policy Act According to G S 113A 10 when a
state agency is required to prepare an environmental document under the provisions of federal law the
environmental document meets the provisions of the State Environmental Policy Act Attached to this
letter for your consideration are the comments made by agencies in the course of this review
If any further environmental review documents are prepared for this project, they should be forwarded to
this office for intergovernmental review
Should you have any questions please do not hesitate to call
Sincerely
William E H Creech
Attachments
cc Region O
' Mading Address Telephone [phone] Location Address
1301 Mail Service Center Fax [phone] West Jones Street
Raleigh NC 27699 1301 State Courser #51 01 -00 Raleigh North Carolina
e marl state clearmghouse@doa nc gov
An Equal Opporlumty/Affirmatve Acton Employer

ATLA.
RCDENR
North Carohm Dcl)utmCI1L of EIINirunnlLIlt lnd Narural Rt- �ourccs
BcltrlN I -I%L,, K3CllK [)�L rtcem In
( oNernor �4crLr2r%
11EV0R. -%0U'1
-ro ZeKe Cteech
SLite Clearinghouse
FROM 11elba MCGL.e
Project Review Coordinator
FE 12 0061 DEIS - Pr000sed SR 1.309 Ertens_or and US 17
Imp-o ements _r Re Hanover ind Pender Counties
DATE Octozet 20 2011
The Department of En -,ironment and NituLal Resoirces has tevte�ed the
proposed project
The department asks that the Depait.mertt of Transportation continue to
,cork directly with our commenting agencies during the NEPA Merger Process
ana take all practicable measuzes to minimize environmental impacts This
� ill `reln avo_d dell s at the oermi.t phase
Thank ci, for the oovortan -� to comment on L111S 0r03ec�
Attachments
1601 Mad Service Center Raleigh North Carolina 27699 1601 One
N l Carolina
Phone [phone] Internet http //portal ncdenr org AlatuW111
� n Eaunt ppporunrt) % A"4rma3%e A, ton Employe - 30 Racyc -tl

i
n
L
10119/2011 16 51 9195289839 PAGE 03
9 North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director
MEMORANDUM
TO Melba McGee
Office of Legislative and Intergovernmental Affairs, DENR
FROM Travis Wilson, Highway Project Coordinator
Habitat Conservation Program
DATE October 19, 2011
SUBJECT North Carolina Department of Transportation (NCDOT) State Draft
Environmental Impact Statement (DEIS) for the proposed SR 1409 extension and
the proposed improvements to US 17 in New Hanover and gender Counties,
North Carolina. TIP Nos U-4751 and R-3300 SCH Project No 12 -0061
Staff biologists with the N C Wildlife Resources Commission have reviewed the subject
DEIS and are familiar with habitat values in the project area The purpose of tins review was to
assess project impacts to fish and wildlife resources Our comments are provided in accordance
with certain provisions of the National Environmental Policy Act (42 U S C 4332(2)(c)) and the
Fish and Wildlife Coordination Act (48 Stat 401, as amended, 16 U S C 661 -667d)
Two projects have been combiricd and are included m the DEIS For project U-4751 the
NCDOT is proposing to extend Military Cutoff Road from Market Street to the US 17 Bypass,
and R -3300 consist of improvements to US 17 from the exist US 17 Bypass north to include a
bypass of Hampstead The projects are being planned wider the NEPA/Section 404 Merger 01
process WRC is represented in this process and comments provided in conjunction with this
process have been documented. However the impacts associated with the remairung alternatives
are substantial and continued efforts to avoid and minimize impacts are necessary Specific
impacts of concern are
• Impacts to the Corbett and Plantation Road mitigation sites, these sites and associate
tracts provide compensatory mitigation as well as serve as eonservatwn areas for
sensitive plants species Not only are direct impacts to these sites a concern, but also
indirect impacts resulting from road and development proximity that may further limit the
Mailing Address Division of Inland Fishemes 1721 Mail Service Center - Raleigh NC 27699 -1721
Telephone [phone] • Fax [phone]

10/19/2011 16 51 9195289839 PAGE 04
U-4751 and R 3300
Page 2
October 19 2011
ability to manage these sites Impacts to the was should be avoided or fluther
minimized.
• Direct impacts to Holly Shelter Gagne land have been avoided, however indirect impacts
as a result of constructing these improvements in close proximity to Holly Shelter may
restrict the ability for WRC to manage portions of this area with prescribed burning, this
issue is not mentioned in the indirect and cumulative effects section of the document.
• Impacts to the Red- cockaded woodpecker (Picoides borealis) contnue to be assessed,
continued coordmation should result in the flirther reduction of impacts to RCW habitat.
• Stream and wetland impacts with all remaining altmnatives are significant, however we
anticipate further avoidance and mmrmizatton of these resources
This plgmt will comtinue to go tbrough the NEPA/Section 404Merger process, and
additional agency coordination will occur through the remaining concurrence points Thank you
for the opportunity to comment if we can be of further assistance please call me at (919) 528-
9886
cc Gary Jordan, USFWS
David Wainwright, DWQ
Brad Shaver, USAGE
Chris Militscher, EPA

AGA
NCDENR
North Carolina Department of Environment and Natural Resources
Diosion G 4Idoi Malt y
84 rw ty Eav--s P=rdu, Coleen ti S.illins Dee Freeman
Govemot Directoi Geae a j
OclobLr 13 2011
To Nlelbi Nteti1.e I n+ironnILIII If ( oordin nor o fie1. ill I e_tsI iti+e mil inti q.,MLrnnienial
\I1 iirs
From Da+ id Wain%%rl`ht Dix iNion of Water Quallt% C entral Otft1.e��
Suble1.t Conini, nt, on the Draft I-n+ ironnu.nt'il ]nip ILt Statc.inent rel tt,.(] to proposed SR 1.109
(Milit ir+ C utofl Ro -id) t_%tt-n,ion and the propa.ed I Ianlpste id 13+p is. (I1S 17) Ne++
H ino+er vid Pe11d1.r C Ounlles itlte Proleet No 4091 1 2 11 i', R 3 ,00 ind 11 47:) 1
St it1. C leirin house Prole(.( No 12 0061
This office has rLx te++ed th,- ref1.renee'd doeumult d ited Jut+ 201 1 1 ht NC Dix tslon of 11r9ter Qualit+
(NC DWQ) Is msponsihte for the t,stiane1. of the Seetion 401 W iter Owilm C ertrf is ition for rc.tr+ ntc, th it
impact W hers of i111. t S Inr_IudIIIL %%Ltlands It is Our und1.rst-induig III it die prolci.t is pres1.ntt-d %% Ill
r1.,ul1 to unpaets to lurlsdletI011 11 ++etl -ands stR uns ind other surfILIL ++ater, NC D1', Q offer, them
tollo++In� comments b ISLd on r ,-+ IL++ of the tforLmLntioned documUnt
Prolcct Specific Comments
1 This project r, being pl inned as p in of th1. 4040'NEPA )tferi.er PrOCCss As I p irticipatin& t1. un
munb1.r NCDWQ x\ Ill continue to +pork With Ilse to 1111
Re+te++ of the project r1. +C -lk the presence of stirtac.e ++ n1.rs classifiul '1. S,\ I1I_11 Quallt+
W-itcrs of the 'ilale in the projcct,tud, tre I I h1s is 0111. 01 the hlghc,t ui i „the. Molls for %%at1.r
qu iht% Ptirstrint to IAA NCA( 311 i006 Ind i:)A NC AC 3B 0224 NCDo)T ++III h1. rulutred iii
oht nn -t Suite Yorni++ i(Lr P,.rmit prior it) c.onsiniction t.,cLpt in North Caroliwi, , t%% 01t% eoWal
Bounties
Re+ IC%% of the prolec.t re%e9lJ the pres1.iiee of surlut. ++ iteh ela,>IhLd 9s S \ OutstnndnlL
Resource Waters of the St 1111. Ill th1. prol1.ct study aria i lie ++ater qu 1111+ 1.I is,th1.ation of SA
ORW Is one of the hlghcst LIassifte,itiOtis Ill the SInl1. I lie NCDWQ is 1.\trL["Ll% concerned w uh
an+ impat t, th-it nm\ elLcltr It) sire In1S \% [ill Cllr, C11,SItIL9Ulln ll is preferred th it the,1. resource,
be a+oidcd if at all possible 11 it Is not possibly, to t+oid these re,our1.es the impact-, should he
mnlitnr7ed to the ir1.It1.5t e\11.111 posslblL (ii+lii the pot1.nU 11 101 inipaLl" to thee. rt-sour1.es
luring the proleet nlplunun pion CDW0 rt(Iue st, it it NCDt7T strn + -ldherL I , North
Cuollna reLUfatnlns e.ntlth d i t sw t Stand irds Ili Seri 1t1+ t. 11 itersheds (I.-) 4 NC 1C 04P
012.1) throua hour design and consh 11.1011 of the, prof+_t Pursu int to Is # NCAC 211 100 i 1nd
1.)A NCAC 313 1132.1
Transpo*�an PeT airs; Unn
1650 Mall Service Center Rale>gh Nona Carona M99 1650
Locamm 312 tt Sastnry stmt Rat zgh Na-ih Cawlm MIX
Phone 919M7.630p1FAX.[phone]
Intemet h1p!lpartatncd- =eT1V-ebh'q
rn Equal07wu -iryt Ame re Azon Zmplo,er
NorthQuol>na
Naturally

4 It is stated that there are no waters in the project area that are listed on the 303(d) list However it
is not stated from which 303(d) lest this information was derived This should be based on the '
most recent list, which would be from 2010 The 2010 303(d) list has all waters in the state listed
as impaired based on a statewide fish consumption advisory due to elevated mercury levels. If the
2010 list was not used, there may be other listings that are not included in the document this '
information should be venfied
5 Section 3 1 (Human Environment) makes reference to a Qualitative Indirect and Cumulative
Effects Assessment dated June 2009 The NCDWQ has not had a chance to review this I
information and requests a copy of the Assessment
6 The NCDWQ encourages the NCDOT to investigate any potential for onsite mitigation to offset I
the impacts of the project
7 The "Travel Demand Management' (TDM) section concludes b) stating that "TDM
improvements would not add new lanes or provide alternative routes or means of travel to
existing roadways " The Purpose Statement for the project does not specifically state that adding
new lanes providing alternative routes, or adding means of travel within the project area are the
purpose of the project With respect to TDM the focus would be reducing traffic especially '
during weekday peak travel times With a reduction in traffic the safety should increase on
Market Street and the reduction in traffic would also reduce the need to increase the carrying
capacity of the street However TDM is based on enough employers allowing such flexibility in '
work schedule combined with enough employees partaking of the flexibility It is doubtful that
the combination of the two would reduce traffic enough such that a noticeable decrease in crashes
and traffic would occur ■
General Comments
8 Appropriate mitigation plans will be required prior to issuance of a 401 Water Quality
Certification
9 Environmental impact statement alternatives should consider design cniena that reduce the
impacts to streams and wetlands from storm water runoff These alternatives should 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, prefonned scour holes, retention basins
etc
10 After the selection of the preferred alternative and pnor 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 greater than 1 acre of wetlands or impacts to
more than 150 feet of any single jurisdictional stream In the event that mitigation is required,
the mitigation plan should be designed to replace appropriate lost functions and values The NC
Ecosystem Enhancement Program may be available for use as wetland mitigation
1 i l:utum documentation, including the 401 Water Quality Certification Application should
continue to include an itemized listing of the proposed wetland and stream impacts with
corresponding mapping
12 The NCDWQ is %cry concerned with sediment and erosion impacts that could result from this
project The NCDOT should i idress these conccros by describing the potential impat is that may
occur to the quat c c nvironmc its as d any mitiga ing i ictors that H +uld educe the nip -)act

13 The NCDOT is respectfully reminded that all impacts including but not limited to bridging, fill
excavation and clearing, and rip rap tojunsdictional 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
14 The 401 Water Quality Certification application will need to specifically address the proposed
methods for stormwater management More specifically stormwater should 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 (1P) 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 authonzation 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 appropnate 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
NCDWQ appreciates the opportunity to provide comments on your project Should you have any questions
or require any additional information, please contact David Wainwright at (919) 807 -6405
cc Brad Shaver US Army Corps of Engineers Wilmington Field Office
Chns Militscher Environmental Protection Agency (electronic copy only)
Travis Wilson, NC Wildlife Resources Commission (electronic copy only)
' Steve Sollod Division of Coastal Management
Mason Herndon NCDWQ Fayetteville Regional Office
File Copy

A��
AC IR
North Carolina Department of Environment and Natural Resources
Division of Coastal Management
Beverly Eaves Perdue
Govemor
MEMORANDUM
TO Melba McGee, Environmental Coordinator
NCDENR Office of Legislauve & Intergovernmental Affairs
FROM Steve Sollod, DCM Transportation Project Coordinator *'
CC Doug Huggett, DCM
Brad Shaver, USACE
Gregory J Thorpe, NCDOT
DATE October 19, 2011
SUBJECT State Clearinghouse Review
Dee Freeman
Secretary
Draft Environmental Impact Statement Comments
Proposed SR 1409 (Military Cutoff Road) Extension and Proposed US 17 Hampstead
Bypass, New Hanover and Pender Counties TIP Projects U-4751 and R 3300
Project Review No 12-0061
The North Carolina Division of Coastal Management ( DCM) has reviewed the Draft Environmental
Impact Statement of the above referenced project, which was submitted to the NC State CIearinghouse for
tntergovernmental review Comments on this environmental document were also requested by the NC
Department of Transportation ( NCDOT) and the US Army Corps of Engineers ( USACE) DCM is
responding to the NCDOT and USACE by copy of this memorandum We appreciate the opportunity to
review this document and provide comments relative to the NC Coastal Management Program
Upon review of the document we offer the following comments
S-7 Action Required by Other State and Federal Asencies
DCM has concluded that the proposed project will not impact a Coastal Area Management Act (CAMA)
Arcs of Environmental Concern (AEC) as defined by the rules of the NC Coastal Resources
Commission Therefore the proposed project will not require a CAMA Permit It is correctly stated
that the project will require a Federal Consistency Determination. As a point of clarification, the
applicant ( NCDOT) is required to evaluate the proposed project and certify to DCM and USACE that
the project is consistent with the NC Coastal Management Program This Consistency Certification
includes a review of the state's coastal program (including the applicable CAMA Land Use Plans) and
contains an analysis describing how the proposed project would be consistent, to the maximum extent
feasible, with the state's enforceable coastal policies as mandated by the requirements of Federal
Consistency (15 CPR 930) No federal license or permit shall be issued by a federal agency until the
requirements of Federal Consistency have been satisfied DCM will issue a public notice and circulate

eU-4751 and R 3300 2
Draft EIS Comments
the Consistency Certification with its accompanying supporting documentation to state agencies with
potential Interest in the project Upon an internal review of NCDOT s written analysis of how the
project Is consistent with the NC Coastal Management Program and the comments received, DCM will
either concur with NCDOT s Consistency Determination or find that the project is not consistent The
Final EIS should Include an analysis of the project under Federal Consistency (15 CFR 930)
4 5.311 Wells
Alternative M2 would Impact an additional two existing Cape Fear Public Utility Authority well sites
than alternative M1 M2 would also Impact several anticipated future Cape Fear Public Utility
Authority well sites The future well sites were selected based upon aquifer access, anticipated yields,
and areas which protect well heads from contamination It is estimated that up to six million gallons per
day of future New Hanover County water capacity could be lost If alternative M2 is selected Perhaps
Table 2 3, Comparison of Current Detailed Study Alternatives should Include the Public Water Supply
Wells feature to reflect the difference in alternatives M 1 and M2
2 4 2.2.1 Hampstead�Imical_Sectlons
DCM is concerned with the large amount of wetland impacts of the project The proposed alternatives
E H, O, and R, from the US 17 Wilmington Bypass to NC 210, are configured with six 12 -foot lanes
Based upon NCDOT's traffic projections, six lanes are required to accommodate future traffic volume in
this section. There is no Indication whether these projections accounted for seasonal fluctuation due to
beach traffic. Only four lanes are proposed for the section from NC 210 to the existing US 17 in order
to minimize RCW habitat Impacts Both of these sections are proposed with a 46 -foot median and 14
foot outside shoulders The proposed design includes 14 -foot inside shoulders for alternatives E-H, O,
and R, from the US 17 Wilmington Bypass to NC 210 If sic lanes cannot be reduced to four lanes to
reduce wetland Impacts, pediaps the medium and/or shoulder widths could be reduced According to
NCDOT's Roadway Design Manual, It appears that the use of a 22' width median with concrete bamer
on new location or widening projects may be used for those freeway projects that have significant
environmental constraints that prohibit or restrict the use of the 46' or wider median NCDOT's
Roadway Design Manual also appears to indicate that freeways may use 10 -foot shoulders or 12 -foot
shoulders when trick DHV exceeds 500 Perhaps the shoulder widths could be reduced The reduction
in median and/or shoulder widths can go a long way to reduce wetland impacts
4 6.2 Evaluation of Cumulative Effects
Reference is made that the use of Best Management Practices will mimmim adverse effects in area of
' environmental concern Rather than the term "areas of environmental concern , the term "surface
waters" or "water bodies ", should be used as a more accurate term as areas of environmental concern"
is terminology used by DCM as specially designated areas not occurring in this project s study area
1636 ManSmIce Center R*O NC 276991638 jr4atUMS; a Car
' Phone 9194n2293/ FAX [phone] hemd wwaiamiahmagementnel MEVWoDOft*JA oA*N

U 4751 and R 3300 3
Draft EIS Comments
S 1,_ 2 Other Agency Coordination
A list of federal state, and local agencies indicates with an asterisk ( *) which agencies provided
comments to the project scoping letter DCM is not indicated as having provided scopmg comments It
should be noted that DCM provided scopmg comments in response to the request for comments from the
NC State Clearinghouse for Intergovernmental Review Those comments are attached to this document
and should be included in the Final EIS
We hope that you find these comments helpful If you have any questions or concerns please contact me
at [phone] x 230, or via a mail at steve sollod@nodem eov Thank you for your consideration of
the North Carolina Coastal Management Program
1636 Md SONIM Center 1 Nc 27699 UM IV�Be Caro ina
Rwe:9*73i -MIFAX X-733 -1495 InW* www noo�sata MapemeMr41 �tCarolm
Ao Eqa OpM%"%A Arlon E WOW

.1
WDEWk
North Carolina Department of Environment and Natural Resources
Division of Coastal Management
Mdml F Eaft Govemor Charles S Jones, Director Wiliam G Ross Jr Secretary
MEMORANDUM
TO Melba McGee NCDENR
FROM Steve Sollod, DCM
DATE October 18, 2005
SUBJECT Military Cutoff Road Extension from US 17 (Market Street) to the Proposed 1 -140
in New Hanover County and the US 17 Bypass of Hampstead in New Hanover
and Pender Counties, WBS Element 401911 1 and 40237, TIP Projects U-4751
and R -3300, Project Review No 06 -0107
The North Carohna Division of Coastal Management (DCM) has reviewed the scopmg letter of
the above referenced project, which was submitted to the NC State Clearinghouse for
intergovernmental review We offer the following comments, which should be considered in
preparation of an environmental document.
' 1 A determination of consistency with the North Carolina Coastal Management Program may
be required for this project Because North Carolina's Coastal Management Program is
Federally approved, a number of activities are required to comply with the program s
enforceable policies even if those activities do not require Coastal Area Management Act
(CAMA) permits under State law This "Federal Consistency" authority exists under the
federal Coastal Zone Management Act It applies to any activity that is in the coastal zone
or affects any land use. water use or any natural resource within the coastal zone (even if the
f activity occurs outside of the coastal zone), of the activity is a Federal activity, requires a
Federal license or pernut, receives Federal money, or is a plan for exploration, development
or production from any area leased under the Outer Continental Shelf Lands Act. Such
' projects must comply with the key elements of North Carolina's Coastal Management
Program ]Federal Consistency requires that the applicant certify to the federal agency and DCM
that the proposed activity will be conducted in a manner that is consistent with the State s coastal
management program This consistency certification includes a review of the State's coastal
program and contains an analysis describing how the proposed project would be consistent
to the maximum extent feasible with the State's enforceable coastal policies as mandated by
' the requirements of Federal Consistency (15 CPR 930) and North Carolina Executive Order
#15 Information pertannnng to the consistency determination should be included in the
environmental document
i 400 Commerce Avenue Morehead City, North Carolma 26557 -3421
11 Phone [phone] FAX 252 - 247 -33301 Intemet www nccoastalmanagamentnet
i
An Equal oppoW* 1 Af ffmbve AcUm Em*w - 50% Re*W t 10% Post CMMW Papal

Page 2
2 All applicable CAMA Land Use Plans should be reviewed and the project evaluated against
the enforceable policies of these plans This evaluation is a part of the Federal Consistency
requirements and this information should be included in the environmental document
The proposed project may impact CAMA Areas of Environmental Concern (AECs) in the
project study area In this case a CAMA Major Development and/or Dredge & Fill Permit
may be required for the project. A formal DCM review of the project to determine
consistency with the States Coastal Management Program will not occur until a CAMA
Major Development Permit application is received At that time, the CAMA Major
Development Permit application will be circulated to the State agencies with an interest in
the proposed project for review and comment The consideration and incorporation by
NCDOT of the comments received during the NEPA/404 Merger Process into the final
project design should help to expedite the CAMA Major Development Permit application
review process
4 DCM's GTS based wetland inventory and mapping program provides wetland data that can
be used to improve wetland avoidance, minimization, alternatives analysts, impact
assessment, and mitigation site searches DCM's GIS based wetland maps and data may be
included by DOT within the environmental document for this project. The GIS based
wetland maps and data are available through DOT s Geographic Information Systems Unit
looted at the Century Center on Birch Ridge Road in Raleigh DCM's GIS based wetland
inventory and mapping program includes three wetland inventory and assessment tools
available for the coastal area.
a Wetland type data This data can be used early in the planning process to avoid and
minimize impacts to wetlands and specific wetland types to estimate project impacts
and to estimate mitigation needs
b Wetaand Functional Sigiificance data (NC CREWS_ This data can be used to refine
the road aligament to avoid the most ecologically significant wetlands that contribute
most to their watershed s health.
C Potential wetland restoration and enhancement site data This data can be used to
locate mitigation sites
We hope that you fund these comments helpful and that they will be addressed during planning
and preparation of the environmental document for this project. Dunng future interagency
project coordination and review DCM may have additional comments on the project, and may
place conditions on the consistency determination or CAMA permit to minimize any impacts to
coastal resources The information provided m this letter shall not preclude DCM from
requesting additional information throughout the interagency project coordination and review
process, and following normal consistency review procedures
If you have any questions or concerns please contact me at (919) 733 -2293 x 230, or via e-mail
at steve.sollod@ncmail net Thank you for your consideration of the North Carolina Coastal
Management Program

NORTH CAROLINA STATE CLEARINGHOUSE
DEPARTMENT OF ADMINISTRATION
INTERGOVERNMENTAL REVIEW
COUNTY NEW HANOVER F02 HIGHWAYS AND ROADS STATE NUME-R 12 -E- 4220 -0061
PENDER DATE RECEIVED 09/07/2011
i _ ,�,,� AGENCY RESPONSE 10/25/2011
,�
�,l REVIEW CLOSED 10/30/2011
MS RENEE GLEDHILL- EARLEY
CLEARINGHOUSE COORDINATOR I C-7
2la
DEPT OF CULTURAL RESOURCES .n►�
�lykYnri A r00"gr IRCE
i STATE HISTORIC PRESERVATION OFFIC _..___- ua� p l
MSC 4617 - ARCHIVES BUILDING
RALEIGH NC
REVIEW DISTRIBUTIONw +d��
CAPE FEAR COG
CC &PS - DIV OF EMERGENCY MANAGEMENT
i DENR - COASTAL MGT
DENR LEGISLATIVE AFFAIRS
DEPT OF AGRICULTURE ) � /
DEPT OF CULTURAL RESOURCES '�'°"'
DEPT OF TRANSPORTATION
PROJECT INFORMATION
i APPLICANT N C Department of Transportation
TYPE National Environmental Policy Act
Draft Environmental Impact Statement
DESC Military cutoff extension from US 17 (Market Street) to the proposed I -140 in New
Hanover County & US 17 bypass of Hampstead in New Hanover & Pender counties
i CROSS- REFERENCE NUMBER 06 -E- 4220 -0107
The attached pro3ect has been submitted to the N C State Clearinghouse for
intergovernmental review Please review and submit your response by the above
i indicated date to 1301 Mail Service Center Raleigh NC 27699 -1301
If additional review time is needed please contact this offyace at (919)807 -2425
AS A RESULT 0 = EVIEW THE FOLLOWING IS SUBMITTED NO_CO,MMENT � COMMENTS ATTACHED
SIGNED BY DATE
f
°C 2)11
WA 7
v
gip 12 za�t

HCDEHR
North Carolina Department of Environment and Natural Resources
Office of Conservation, Planning, & Community Affairs
Beverly Eaves Perdue Governor Linda Pearsall, Director Dee Freeman Secretary '
000lh1 11i 2011 '
N1L,N10I1 kNDLNI
TO hlLIh I Me(mt, ill NR i m Ironmt-tu Il ( oordin-itor
I ROM f I Irr% I e iron N uur iI I it-iii iL,t- Pio�p un ,
SUlill ( I Drift 1 IS— Propo,t-d SR 1409 (Milit irN ( utotf Ro id) 1 \tLnsioti Ind Propost-d US 17
11 nllpstt--id Byp 1s. Netti i f-ino,.t-r Intl Pt-tlder eauntit-s
RI I I RI NC F 12 006 1
Ihis prolt-t.t likLl� %% III t- con.id<rthlt 1-11% 11`01111101111 nnpit-ts to Ntt-tl Inds AII(IIIIL habitat rut-
spt-t- it- Ind possthlt- n itur it 1rt--is M nn of tht-u imp ILLS .t ill iikt-I} bt- ueond ire is I r'sult of h ihit it
fripllt-tll uton through plIt-t-ment (11 t Inllnt-d lt-t-t-sS hIL -IIW1) through undc,�elopt-d I Intl% it is
unfortun Itt- th-it our Ptagrini and pt-th IPS most otht-r% In the Ut-p irtmt-nt Iiis not hwi eontaelLd for
Scopult. commt-nts no %ut-h It-tlt-r% ippt- -ir to ht- lilt- III(IL l In tht- tIOLU1llt-ill
i nehrit-d in.. t%%o to ips ,hou in` tht- ,ti.nilmint witur it %%ourt-t-s in %ht- proJt-et irt- i ill,- northt-rn It of of
tilt- prolt.ct — from -Ihout 1 11111L northt- W of SldburN Ro id to tilt. uinnt-t-tion a 1111 (IS 17 northt.-i%( of
I IvripsIL Id — nppenr% to ivoid sib. iilse Mt n ituril rL%ourLLS I ht- xNi -slern of the t%%O ilignments (rc.d on
I itmm S 1) ippt-lr% to bLtlt-r axoid 131 ikL S I% inn i (I&rLt-n pohI-on north of Sidhury Ro-id) ind Stdhun
Ro id S I% inmi (hl icl. liohuon saulh of Sidhur% Ro id) I his r...(1 illt-rn iii%t- also hLttt.r i%oids tht- 1(
DO intug,ition -irL is owiroon- hro%Nn pok,ons iloriL tilt- `N llmtn_ ton 1hpass) pa »Ins. Just to tht- at-st
01 (111-111 l he eonttnu Mon of %ht- rt-d routs. ,oath of Iht- «tlmui- ton 131pasa (blot- In1t- on r Lurt- S 1 )
-ilso clot % 7 bctt4r lob of IK►1din�1 %ipilii. lilt natur If %sources ill in (100.111L snort- L ttitt-rn purplt, routt- On
Iht- Itgurt-
In unrinrin tilt- mo%t ttt-stt-rn of the -onibint-d routt-% ylpt- irs to do %ht- ILISt Imp,tet, to ,itnific lilt
nattir it htritalt- -trt- i% rim ,pectt--1 Ind t.ontit-rt loan im-is I-IO%%L\t-r it 1% \t-l'\ import int that tht- N(
DO I t-onUnut- to umdttct St-eUon 7 -onuiil ifions tt ith tilt- US f tsh Intl Wildilk N,r.l,.t- rt g irding
potenti d nnpacts to I t-ttt-r illy lisiLd Stith I. 11% Red cool. itit-d Woodpecl.t-r (h((udct hr»t (1isi)
roughk it (oost stri it- (l i ttntac has uyx ► ►rlrJ(rh(r) Ind ( oolt-v s nit- ido\t rut. (Th(tht ti wn (ook i i) I.
mdit- ut-tl iil tilt- DI 1S
Pie ISe do not hestt Ise tit tint ICs Ilb- it 919 71 '� 8097 if \ou hat- qut-tilum5 or need further inform Ilion
Fnelu%urLs
1601 Mail Service Center Raleigh North Carolina 27699 1601 NOne Carolina
Phone [phone] \ FAX [phone] Internet www oneNCNaturally org atura���
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DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
DIVISION OF WATER RESOURCES
PUBLIC WATER SUPPLY SECTION
Inter Agency Project Review Response
Project Name t S %rm% Corm of L_nt_inurs Type of Project
Wilnunt ton Distrut
Comments provided by
'i Regional Program Person Ot t 6e-,
❑Q Regional Supervisor for Public Water Supply Section
(=i Central Office program person
Project Number
120061
County
New Hanover
Pender
Drift FmlronniLritil
lnln Ict siltenlent
Proposed Sit 1409
(Milit-trN Cutoff Rd)
Ftension and nronnsed
US 17 H imnste td 0� n Iss
Name Dli)r t BLi)O% -%% ilnttnL ton RO Date 09/09/2010
Telephone number 61 In 70 _�7aI �
Program within Division of Water Resources
Public Water Supply
❑ Other Name of Program
Response (check all applicable)
❑ No objection to project as proposed
❑ No comment
❑ Insufficient information to complete review
❑ Comments attached
See comments below
' LOCt tU +0 Nut IC_C I,OL � Cct., -)City e fxLi f'li 4 ,-c fx)Se C�, t�S
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i0C0h4'A Yon` Lf A Return to
' Public Water Supply Section
Environmental Review Coordinator for the
Division of Water Resources

DEPARTMENT OF ENVIRONMENT AND Protect Number I
NATURAL RESOURCES 120061 I
DIVISION OF WATER RESOURCES County
PUBLIC WATER SUPPLY SECTION New Hanover, Pender
Inter Agency Protect Review Response
Protect Name t S 1rrnn ( ores of LnLin«r% Type of Project Or ift I m iron M!1 trop rc(
Wilntrnuton Di%trict 5t Uemint Propocud SR
1409 (Milit in Cutoff Rd)
F%tension ind nropo,cd US
1714 imps teed BNnass
❑ The applicant should be advised that plans and specifications for all water system
improvements must be approved by the Division of Water Resources /Public Water
Supply Section prior to the award of a contract or the initiation of construction (as
required by 15A NCAC 18C 0300et seq ) For information contact the Public Water
Supply Section (919)
733 2321
❑ This protect will be classified as a non community public water supply and must comply
with state and federal drinking water monitoring requirements For more information the
applicant should contact the Public Water Supply Section [phone]
existing water lines will be relocated during the construction plans for the water line
relocation must be submitted to the Division of Water Resources Public Water Supply
Section Technical Services Branch 1634 Mail Service Center Raleigh North Carolina
27699 1634 [phone]
X❑ For Regional and Central Office comments see the reverse side of this form
Jim McRight PWSS 09/09/2011
Review Coordinator Section /Branch Date

Appendix D
Evaluation of Impacts to
Public Water Supply
Groundwater Wells

Evaluation of Impacts to Public Water Supply Groundwater Wells
US 17 Corridor Study, NCDOT TIP Project U -4751 & R -3300
New Hanover and Pender Counties
j� February 8, 2012
Introduction
State 1 ransportation Impio-, ement Program (STIP) projects U 4751 and R 3300 inN oh e the
construction of Militar) Cutoff Road Extension in New Hanover Count) and the US 17 Hampstead
B) pass in New HanoN er and Pender Counties Because the projects ma) share a common terminus
they are being evaluated together in a single en-, ironmental document A Draft Environmental
Impact Statement (DEIS) for the project was signed b) the North Carolina Department of
Transportation (NCDOT) and the US Arm) Corps of Engineers on Jul) 28 2011
In then No,, ember 15 2011 re-, iew of the DEIS and at NCDOT s December 15 2011 agenc)
coordination meeting (Concurrence Point 3 informational merges meeting) EPA expressed
concerns and indicated further re-, iew of the potential effects of the project on the local public water
supply is warranted
To further evaluate potential impacts to groundwater from the proposed project the following
anal) sis incorporated a re-, iew of existing literature and communications with representatives from
the Cape rear Public Utiht) Authority and the Public Water Supply Section of the NC Department
of En-, ironment and Natural Resources The intent of the re-, iew is to determine if the proposed
project is hkel) to result in impacts to the quanta) or quaht) of the Cape Fear Public Uttlit)
Authority s groundwater public water suppl) system
Project Description
For project U 4751 NCDOT proposes to extend Militar) Cutoff Road as a six lane divided roadway
on new location from its current terminus at US 17 (Market Street) in X "Vilmington north to an
interchange with the US 17 Wilmington Bypass (John Ja) Burne) Jr Freeway) Limited and full
control of access is proposed For project R 3300 NCDOT proposes to construct the US 17
Hampstead B) pass as a freewa) on new location The US 17 Hampstead B) pass ma) connect to the
proposed Military Cutoff Road Extension at the existing US 17 Wilmington By pass and extend to
existing US 17 north of Hampstead Full control of access is proposed for the US 17 Hampstead
B) pass The project area is shown in Figure 1 The current detailed stud) alternatives are shown in
Figure 2
The purpose of the US 17 Corridor Stud) project is to improve the traffic carrying capacity and
safety of the US 17 and Market Street corridor in the project area
Because of its location within a wellhead protection area the Military Cutoff Road Extension project
is the focus of this rep iew Militar) Cutoff Road Extension Alternatives M1 and M2 are new
location alternate-, es extending Military Cutoff Road from Market Street to the US 17 Wilmington
Bypass The Cit) of Wilmington adopted an official transportation corridor map for the proposed

extension of Mthtar} Cutoff Road on August 8 2005 Alternati-, e M1 follOR s the adopted coindor
m,ip alignment
AlternatiN e M1 begins at a proposed interchange at Military Cutoff Road and Market Street 1 he
alternate-, e extends north through -, ,icant Counts property between the two sections of Ogden
Park and residential areas Alternatii e 1\41 turns northwest and ends near Pl intation Road and
Crooked Pine Road at 1 proposed interchange with the US 17 Wilmington B) pass
approximatel) midwa) between 140 and Market Street
AlternatiN e M2 begins at a proposed interchange at Mihtar) Cutoff Road and Market Street
Alternatii e M2 follows the Alternau-, e M1 alignment for approximatel) two miles Alternatt-, e
M2 then turns northeast and extends through mostly undeN eloped property to a proposed
interchange with the US 17 Wilmington B) pass approximately one mile x, est of Market Street
Military Cutoff Road Extension incorporates to o typical sections
• hrouu the propoW intenhaiiSe at Market Street to appioxamately 0 9 male south of Torchwood Boulevard Six
lanes (three in each direction) with a 30 foot median and curb and gutter 'Iwo 12 foot inside
lanes and one 14 foot outside lane (to accommodate bic) cles) with two foot curb and gutter and
a ten foot berm are proposed in each direction
From approxivaately 0 9 male north of Tonh)vood Boulevard to the proposed interchange at the US 17
lVilmangton Bypass Six 12 foot lanes (three in each direction) with 14 foot outside shoulders (12
foot paved) A 46 foot median is proposed
A variable right of wa) width of 150 feet to 350 feet is proposed for Mihtary Cutoff Road
Extension
Public Water Supply
The Cape Fear Public Utility Authority (CFPUA) provides water for New Hanover County from
see eral sources including surface ,, ater groundwater and purchases from other s} stems Their 2010
Integrated Water Resources Master Plan indicates that total demand represented 28 percent of the
total a-, ailable water suppl) (all sources) in 2010 Future demand including the sale of water to
other s) stems is projected to represent 25 percent of the ai ailable suppl) in 2030 and 39 percent of
the available supply in 2060
The CFPUA has se-, eral existing and proposed well sites associated with their groundwater
nanofiltration water treatment plant (WTP) which was brought on line in 2009 and distributes water
to portions of northern New Hanoi er County The \V'I P is located adjacent to proposed Military
Cutoff Road Extension Alternatives M1 and M2 where they share an alignment just north of
Torchwood Boule-, and
The alignment shown on the official transportation corridor map for the proposed extension of
Military Cutoff Road adopted in 2005 was a factor in the selection of the CFPUA well sites
(personal communication Gary McSmith CFPUA) Roads are commonly found within wellhead
protection areas across the state Existing state rules and regulations are relied on to manage risks
associated with transportation infrastructure located within wellhead protection areas managed
through the non regulltor) approach (personal communication Gale Johnson NCDENR PWS)
2

According to the U S Geologic Suii e) the principal groundwater supply aquifers in New Hanover
Counts — the ,urficial Castle Ha) ne and Peedee — were formed from the late Cretaceous to
Quarternary aged geologic formations Approximatel) 30 percent of all freshwater used in New
Hano-, er County in 2005 was supplied from these three aquifers The CFPUA groundwater
nano filtration WTP wells draw from the Castle Ha) ne and Peedee aquifers The NC Di-, ision of
Water Resources website states that aquifer s) stems ale h) drauhcall) connected materials (sands
limestone and fractured rock) that pro -, ide water through a properly constructed well open to those
materials In the coastal plain an aquifer is t) picall) composed of one to se-, eral la) ers of eastward
thickening permeable sands or limestone split b) discontinuous cla) rich materials Confining
units consisting of clay rich sediments exist abo-, e and below an aquifer These confining units are
more continuous cla) lay ers and separate the aquifers The suificial or unconfined aquifer o-, erhes
all the confined aquifers in the coastal plain The Peedee and Castle Ha) ne aquifers form regional
aquifers
,sue/
✓ .. of
;r ,
r
Peedee Aquifer
The Castle Ha) ne aquifer is widel) used in the
eastern portions of the coastal plain at elevations of
65 to 1 103 feet a-, eraging 144 feet The Castle
Hayne aquifer ranges from 6 to 1 105 feet thick and
averages 164 feet thick The aquifer is composed of
limestone sand) limestone and sand and is
considered a semi confined aquifer It is the most
producti-, e aquifer in North Carolina Wells
t) picall) ) ield 200 500 gallons per minute but can
exceed 2 000 gallons per minute In addition to
supplying some industrial and agricultural usages a
number of municipal well fields are supplied b) the
Castle Ha) ne aquifer These municipal areas
include the City of Wilmington New Hanover
beach towns the New Hanover County water
s) stem Topsail Island and Surf City
3
The Peedee aquifer is present in the central
to southeastern portion of the coastal plain
at elegy ations of 114 to 1 849 feet
a-, eraging 164 feet The Peedee aquifer
ranges from 2 to 1 001 feet thick and
a-, erages 141 feet thick The aquifer is
composed of fine to medium sand and is
considered a confined aquifer Wells
t) pically ) ield up to 200 gallons per minute
The pink area shown in the figure to the
left shows the salt) extent of the Peedee
aquifer The green area shows the fresh
extent and the yellow area is the transitional
area between the salt) and fresh water
�..
%
.f S
r GNa11 �
DwUn ! ��
IV
" " ---
f �
! Castle Hayne Aquifer

Wellhead Protection Area
The proposed Military Cutoff Road Extension project is located within the wellhead protection area
established for the public water supply wells operated by the CFPUA 1 he NC Wellhead Protection
Guidebook states that a wellhead protection area is the part of the landscape both abo-\ e and below
ground which contributes water that will e-, entually reach the well By identi fy ing the contributing
area for the well strategies can be established to manage certain activities to significantly reduce the
chance the well might be contaminated
CFPUA s wellhead protection area was established during the preparation of their Wellhead
Protection Plan Each well was assigned an indi-, idual wellhead protection radius to idenufy the area
to be managed to reduce the likelihood of contamination of the well Methods to determine radu
for wells withdrawing from the semi confined Castle Hay ne aquifer and the confined Peedee aquifer
differed based on information pro-, ided b5 the North Carolina s appro-, ed Wellhe id Protection
Program Because there was considerable o-, erlap when the wellhead protection areas were
identified the outer boundary of the areas were smoothed and enlarged to encompass an area
approximatel3 equal to the combined areas of each indn idual wellhead protection area (see Figure
3)
Figure 4 sho\N s the location of the proposed project in relation to CFPUA s Wellhead Protection
Area 1 and existing CFPUA well sites With the exception of a portion of the proposed interchange
at Market Street for both alternati-, es and the northern quadrants of the Alternati-, e M1 interchange
at the US 17 Wilmington Bypass both Military Cutoff Road Extension Alternatives are located
within the wellhead protection area A portion of Hampstead Bypass Alternative U where it travels
along the existing US 17 Wilmington B) pass is also located in the wellhead protection area
Wellhead Protection Area 1 is approximatel3 7 712 acres in size The well sites shown in Figure 4
are depicted with a 100 foot buffer around the wellhead Regulations for public water supply wells
stipulate that the area within 100 feet of a well be owned or controlled b} the person supplying the
water (15A NCAC 18C 0203) The buffer allows the water supplier to protect the well lot from
potential sources of pollution and construct landscape features for drainage and diversion of
pollution 1 able 1 lists the existing CFPUA wells in the project area The table identifies the aquifer
each well draws from and the distance from the wellhead to the proposed Mihtary Cutoff Road
Extension slope stake boundary The wellheads located closest to Mihtary Cutoff Road Extension at
Site B (Well IDs 22 and B CH) are positioned at a higher eleN ation than the proposed roadway
grade
In addition to the existing wells CFPUA has plans to expand its infrastructure and add new wells in
the future These future well sites are depicted by an X on Figure 5 Military Cutoff Road
Extension Alternative M2 would cross existing and proposed water lines associated with the
proposed expansion area The CFPUA indicates that future well sites were selected based on aquifer
access anticipated yields and because the area is unde,, eloped which protects the well heads from
contamination
4

Table 1 Summary of CFPUA Wells in the Vicinity of Mtlttar5 Cutoff Road Extension (MCRE)
Well
Site
Well
ID
Well
Depth
(ft)
Aquifer
WHPP
Radius
(ft)
Yield
(gpm)
Closest
MCRE
Alternative
Distance from
Well head to
MCRE Slope
Stake Limits ft
P
8
160
Peedee
2000
600
M1 M2
807
Q
16
175
Peedee
3 000
500
M1 M2
1 855
B
22
170
Peedee
3 000
640
M1 M2
126
A
23
170
Peedee
3 000
600
M1 M2
1 490
M
28
175
Peedee
2000
750
M1 M2
544
N
29
175
Peedee
2000
7D0
M1 M2
781
O
30
175
Peedee
2000
570
M1 M2
1 006
A
A CH
95
Castle Name
2 965
600
M1 M2
1 490
B
B CH
80
Castle Ha) ne
3 097
640
M1 M2
126
C
C CH
105
Castle Hai ne
2 406
600
M2
1 402
C
I C PD
168
Peedee
3 000
570
M2
1 379
F
F CH
105
Castle Ha)ne
2 273
600
M2
764
F
F PD
170
Peedee
3 000
570
M2
770
G
G CH
90
Castle Ha} ne
2 440
500
M2
523
G
G PD
173
Peedee
3 000
570
M2
546
H
H CH
100
Castle Hat ne
2 471
600
M2
184
H
H PD
175
Peedee
3 000
570
M2
159
I
I CH
95
Castle Ha} ne
2206
400
M2
2 109
1
1 PD
175
Peedee
3 000
570
M2
2081
J
J CH
100
Castle Ha} ne
2 493
600
M2
546
J
J PD
175
Peedee
3 000
570
M2
573
K
K CH
100
Castle Ha) ne
2 713
200
M1 M2
1 187
K
K PD
175
Peedee
3 000
600
M1 M2
1 141
L
L CH
85
Castle Ha) ne
3 054
500
M2
810
L
L PD
170
Peedee
3 000
640
M2
790
Wellhead Protection Plan
The CFPUA developed a Wellhead Protection Plan (WHPP) in coordination with the
NC Department of Environment and Natural Resources Public Water Supply Section The
CFPUA finalized its plan in December 2009 The purpose of the WHPP is to manage the land areas
surrounding the wells in order to pre-, ent contamination of the public water supply The CFPUA s
WHPP is non regulatory and identifies strategies to manage the wellhead protection area for their
northern water system
i In addition to delineating the wellhead protection area the WHPP identifies potential contamination
' sources establishes wellhead protection area management actions describes an emergency
contingent} plan for alternative water supply sources describes an emergency response plan for
incidents that may impact water quality and outlines a public education program
1 5

A potential contaminant source (PCS) is any substance or acts-, it) that could ad-, easel) affect the
quaht) of the drinking water supply The PCS inventor} is a complete listing including mapped
locations of past and present land use actii ities within the wellhead protection area that threaten
groundwater quaht)
The CFPUA identified potential contaminant sources using guidance pro-, ided in the NC Wellhead
Protection Guidebook Ranking criteria were applied to each potential contaminant source to
identify oN erall risk to wells A risk ranking of lower moderate or higher was established for
potential contaminant sources b) totaling points assigned under se-, eral criteria including proximit)
quantity relative toxicity and likelihood of occurrence (see 1 able 2) Potential contaminant sources
with a combined ranking between 0 and 7 were considered a lower risk while those with a combined
ranking of 10 or higher were considered a higher risk
Table 2 Cape Fear Public Utiht) Authorit) Risk Criteria
Risk
Proximity to
Quantit y
Relative
Likelihood of
Well
Toxicity
Occurrence
Lower (1 pt)
> 1 500 feet
< 100 gal
Grease
Car Wash
< 100 lbs
Chloride
Cemetery
Funeral home
Main storage
Substation
Moderate (2 pts)
750 1 500 ft
100 2 000 gal
Pertoleum
AST
100 — 2 000 lbs
Fertilizers
Auto Repair
Sewage
Lift Station
Bacteria
Pesticide/ herbicide/
fertilizer appl /
storage UST (gas
station
Higher (3 pts)
< 750 feet
> 2 000 gal
Pesticides
Chemical Storage
> 2 000 lbs
Herbicides
Cleaners
Metals
Industr}
Sol-, ents
Mayor Road
Railroad
Major roads are included under the likelihood of occurrence category as a higher risk No existing
or proposed roads were included in the list of identified potential contaminant sources in the
WHPP The NC Wellhead Protection Guidebook includes freeways /state highwa) s as a moderate
risk
The Cape Fear Public Utility Authorit) 2011 Annual Report includes information on their
Emergenc) Management Plan
The Cape Fear Public Utiht) Authority abides b) state and federal emergency
management regulations for all hazards mitigation preparedness response and
recoN er) The program coordinator develops maintains and trains Authority
emplo) ees on the Emergenc) Response Plan and its associated Incident Action Plans
Proactively working to meet EPA s seventeen National Incident Management System
C.

' If a contaminant reaches groundwater within the well s) stem s contribution area the contaminant
can mo-, e with the groundwater into the well 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 substantiall) reduced As previousl) noted the CFPUA has delineated
a wellhead protection area for their northern water suppl) and developed management strategies in a
wellhead protection plan
Because the Peedee aquifer is semi confined and Castle Ha) ne aquifer is confined the) are less likely
to experience water quaht) impacts than surface waters or surficial aquifers (personal
communication Gale Johnson NCDENR PWS)
Water Supply
At the time of completion of the DEIS for the project it was expected that AlternatiN e M1 would
cross two CFPUA well sites and Alternative M2 would cross four existing well sites and a proposed
well site CFPUA estimated that a loss of access to the future sites could result in a reduction of up
to six million gallons per da) of anticipated future water supply
1 he alignments of both Alternatl-% es M1 and M2 ha-, e been modified since completion of the DEIS
Neither alternative will cross an) existing or future CFPUA well sites Although both Military
Cutoff Road Extension alternati-, es would cross potable and raw water lines an) impacted water
lines would be relocated as part of the project and returned to service The project will not decrease
the capacity of the existing and planned water supply infrastructure
The NC Division of Water Resources water budget for the NC Coastal Plain indicates a very small
percentage of rainfall infiltrates into the confined aquifer system Most rainfall is lost to
evapotranspiration runoff or infiltrates into the shallow ground water system that then discharges
to local ri-, ers and streams Using the impact boundary (slope stake + 25 feet) Military Cutoff Road
Extension Alternative M1 would encompass approximatel) 286 acres and Alternate-, e M2 would
(NIMS) compliance objecti-, es foi the water sector staff continues to refine emergency
preparedness b) pl inning and implementing standardized response and industry best
practice measure as recommended b) EPA FEMA and North Carolina regulatory
agencies
The Authority also participates on the New Hanover Counts Local Emergenc)
Planning Committee which plans for haz irdous materials response incidents within
the community We ha-, e also been active in planning and participating in community
'
wide drills and exercises with our state count) and city emergency response partners
'
Evaluation of Potential Impacts
Potential impacts to the CFPUA public water suppl) could occur through actions that would limit
the a-, ailabilit) of the water the s) stem pro-, ides or actions that compromise the safety of the water
supply through cont imination Impacts to the suppl) of water could result from direct impacts to
s) stem infrastructure or through actions that limit groundwater recharge Impen ious surfaces such
,is roads increase the amount of runoff during rainfall e-, ents and could both reduce groundwater
'
recharge and increase pollutant loadings Other potential impacts to groundwater qulht) are
accidental spills and wrecks on the proposed roadwa)
' If a contaminant reaches groundwater within the well s) stem s contribution area the contaminant
can mo-, e with the groundwater into the well 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 substantiall) reduced As previousl) noted the CFPUA has delineated
a wellhead protection area for their northern water suppl) and developed management strategies in a
wellhead protection plan
Because the Peedee aquifer is semi confined and Castle Ha) ne aquifer is confined the) are less likely
to experience water quaht) impacts than surface waters or surficial aquifers (personal
communication Gale Johnson NCDENR PWS)
Water Supply
At the time of completion of the DEIS for the project it was expected that AlternatiN e M1 would
cross two CFPUA well sites and Alternative M2 would cross four existing well sites and a proposed
well site CFPUA estimated that a loss of access to the future sites could result in a reduction of up
to six million gallons per da) of anticipated future water supply
1 he alignments of both Alternatl-% es M1 and M2 ha-, e been modified since completion of the DEIS
Neither alternative will cross an) existing or future CFPUA well sites Although both Military
Cutoff Road Extension alternati-, es would cross potable and raw water lines an) impacted water
lines would be relocated as part of the project and returned to service The project will not decrease
the capacity of the existing and planned water supply infrastructure
The NC Division of Water Resources water budget for the NC Coastal Plain indicates a very small
percentage of rainfall infiltrates into the confined aquifer system Most rainfall is lost to
evapotranspiration runoff or infiltrates into the shallow ground water system that then discharges
to local ri-, ers and streams Using the impact boundary (slope stake + 25 feet) Military Cutoff Road
Extension Alternative M1 would encompass approximatel) 286 acres and Alternate-, e M2 would

encompass approsimatel) 303 acres Based on the size and confined natures of the Castle Hai ne
and Peedee aquifers and Cl-PUA data on a-, ailable water suppl) -, ersus demand the proposed
project is not expected to affect the iechaige of the aquifers or the amount of water available for
withdraw als from existing public water suppl) s) stem wells
Water Quality
Accidental Spills
Accidental spills due to traffic accidents or other causes probably represent the greatest potential
impact of the proposed project on the water supply wells The potential for an accidental spill in the
Well I lead Protection Area is probabl) not greater -,vith construction of the project as seN eral major
roadu a) s including the US 17 Wilmington B) pass and Market Street alread) exist in the \hell Head
Protection Area The concern with this project is that a major roadwa) will now be closer to some
wellheads than current conditions
E-, en though the project is constructing a major roadwa) close to wells contaminants from a spill
hkely could be contained and remo-, ed before reaching the aquifers the wells are drawing from due
to the semi confined and confined natures of the aquifers 1 he Contingency Plan component of the
WHPP identifies emergency agencies to be contacted in the e-, ent of a major oil or chemical spill It
includes both short term (less than 48 hours) and long term plans to determine if contamination has
occurred and identifies alternate water sources to be used until it has been determined the s) stem is
free of contamination and in compliance with standards go-, erning public water supplies
Stormwater Runoff
As noted pre-, iousl) there are two ty pical sections associated with the proposed Mihtar) Cutoff
Road Extension project The first typical section includes curb and gutter and as such would
incorporate a stormwater cony e) ante s) stem The second t) pical section includes a shoulder
section which would incorporate vegetated ditches to cone) runoff
The NC Wellhead Protection Guidebook ranks stormwater discharges as a higher risk potential
contaminant source Literature indicates that highway stormwater does occasionally contaminate
groundwater with minor amounts of metals and petroleum compounds I'hese chemicals are
typically present at extremely low concentrations and tend to be localized around the right of way
In addition the application of road salt and de icing chemicals can be a concern to groundwater
quaht) particularly in areas that have appreciable snowfall or use surficial aquifers as a water suppl)
source The NC Wellhead Protection Guidebook ranks road salt storage areas as a higher risk but
does not address the application of road salts during winter weather The NCDOT Division 3
Maintenance Engineer indicates road salt applications occur infrequend) in the project area The
a-, erage annual snowfall (including pellets and ice) in Wilmington o-, er the last 50 y ears is two inches
The Division plans for one application of road salt to major arterials used for commerce at
approximatel) 250 pounds per lane mile per ) ear

Stormwatei ponds included in the
CFPUA \VHPP are issessed as
lower risk potential contaminant
sources Mihtar) Cutoff Road
Extension Alternate es M1 and M2
ma) affect four ponds judged to
have the appear ince of stormw iter
ponds during surface water
delineations for the project Two
of those ponds BPE and BPI' Ire
located in the CFPUA s wellhead
protection area
1 he proposed project is expected
to impact 0 75 acre of pond BPE
Pond BPE is a stormwater pond
permitted bj the NC De ision of Water Quaht) (NCDWQ) in February 2007 Pond BPE is
,issociated with a high density subdivision dex elopment Nest Bay Phase V The WHPP does not
include a data sheet for the West Baj Phase V stormwater pond hkel) because it was not
constructed at the time of the potential contaminant source review A data sheet is included in the
WHPP for a West Ba) Phase IV stormwater pond which is not impacted b} the project
Estimated impacts to pond BPF are 0 41 acre The pond was ev iluated during the review of
' potential contaminant sources for the CFPUA WHPP and is listed on the data sheet as a stormwater
pond for Courtney Pines Phase III The NCDWQ issued a stormwater permit for a low density
deN elopment with a curb outlet s3 stem for the Courtney Pines Phase III de-, elopment in July 2004
' The permit does not cite requirements for the construction or maintenance of a stormwater pond
for the low density development
' NCDO1 will likely be required to replace any stormwater storage capacity lost due to project
impacts to permitted ponds It is not expected that project effects to these ponds will adversely
affect the water suppl) Due to the semi confined and confined natures of the aquifers in this area
cry little of the runoff from the proposed roadway would reach the aquifers
Avoidance and Minimization of Potential Impacts
' The CFPUA has identified their wellhead protection area and adopted a wellhead protection plan
The wellhead protection plan includes an emergency contingency plan addressing the steps to be
taken should a major oil or chemical spill occur For soil or groundwater contamination incidents
' occurring within the wellhead protection area CFPUA will contact State agencies responsible for
oN ersight to track compliance with the acti-, ities and the schedule of remedi ition efforts
NCDOT will coordinate with the Cape Fear Public Utiht) Authority on the potential inclusion of a
sign on Mihtary Cutoff Road Extension notify ing drivers they are travelling through a water supply
area If CFPUA is in fa-, or of erecting such a sign it could include the instruction "Spill Response
Dial 911" in case of accidental highway oil or chemical spills

The Militar) Cutoff Road Extension design has been reN ised so that a minimum distance of 100 feet
is maintained between the slope stake limits and existing «ellheids No wells would be isolated or
relocated is a result of the project An) impacted water hnes would be relocated as part of the
project
Appropriate measures will be taken to a-, old spillage of construction materials and control runoff
Such measures Nvill include an erosion and sedimentation control plan pro-, isions for disposal and
handling of waste materials and stodge stormwater management measures and appropriate road
maintenance measures NCDOT s BestManagementPiaaauev for Protection of Surface Vatery (BMP PS \�
and Sedimentation Control guidelines will be enforced during the construction stages of the project
Summary and Conclusion
It is not uncommon to find ioads within wellhead protection areas The proposed Mihtar� Cutoff
Road Extension project is located within the wellhead protection area established for the public
water suppl) wells operated by the Cape Fear Public Utiht) Authority Military Cutoff Road
Extension will be located a minimum of 100 feet awa) from existing a ellheads and in most cases
much greater distances The CFPUA was aware of the proposed project during the construction of
the nanofiltration groundwater water treatment plant and located wells with the Military Cutoff
Road Extension official transportation corridor map alignment in mind
Groundwater supplying the CFPUA wells originates from both the confined Peedee aquifer and the
semi confined Castle Ha) ne aquifer The geologic nature of these aquifers affords a lex el of
protection not associated with surficial aquifers or surface water supply sources
Impacts to the availability of the water supply are not anticipated as a result of the proposed project
The project is not expected to decrease the capacity of the existing and planned water suppl)
infrastructure or the source aquifers
The CFPUA maintains a Wellhead Protection Plan to manage the land areas surrounding their wells
in order to prevent contamination of the public water suppl) The plan includes emergenc)
response and contingenc) plans for incidents that ma) impact water quaht) Stormwater runoff
associated with the proposed Mihtar} Cutoff Road Extension will be directed to grassed swales or a
stormwater con-, e3 ance s) stem and awa) from wellheads
The proposed project is not expected to result in impacts to the quanut) or quaht) of the CFPUA s
groundwater water supply wells
10

Literature Review and References
G1pe Fear Public Utility Authorit} Wilmington NC
• Wellhead Protection Plan for Cape Fear Public UtilitS Authority PWS ID # 04 6D 232
December 2009
• Final Well Head Protection Plan Indi-, idual Well Head Radii Location M1p (Prehr iinary
Drawings) August 2009
• Proposed Well Head Protection Plan Indi-, idual Well Head Radii Location Map (Prehmnnary
Drawings) June 2009
• Figure 1 Raw Waterlines and Well Sites (Prelnmmnar) Drawing)
C1pe Fear Public Utnht} Authority website (www cfpua org)
* 2010 Water QuahtS Report * 2011 Annual Report * Capacit) Management Program
Johnson Gale NCDENR Public Water Supply Personal communication January 23 2012
McCormick Rankin Corporation Highway 69 Route Planning Stud) Februar} 2008
(www highwa) 69 ca /highway69 /northto522)
McSmith Gars Cape Fear Public UtthtS Authority Personal communication January 23 2012
NC Department of En-, ironment and Natural Resources Division of Water Resources
' (ww"v ncwater org /Education_and_'I ethnical —Assistance /Ground—Water)
* Basic HydrogeoloM Ground Water Aquifers & Confining Beds
* North Carolina Aquifers Castle Ha) ne and PeeDee Aquifer Maps
* Local Water Suppl) Plans S) stem Information CFPUA — Wilmington (www ncwater org/
Water_ Supply _Planning /Local_Water_Suppl) _Plan /)
' NCDENR Public Water Supp15 Section (PWS) Source Water Assessment Program (SWAP)
(www ncwater org /pws /swap /)
* Approx ed Local Wellhead Protection Plans (10/25/2011) to North Carolina
' * Learn about Your Drinking Water Source
* NC Wellhead Protecuon Guidebook
* Source Water Assessment and Protection in North Carolina
' * Sources of Potential Groundwater Contamination
* Source Water Assessment Program
* NC SWAPinfo Viewer (swap deh enr state nc us /swap_app /viewer htm)
' North Carolina General Assembll Statues (www ncga state nc us)
* NC General Statutes Article 10 Chapter 130A North Carolina Drinking Water Act
' * NC General Statutes Article 21 Chapter 143 Water and Air Resources
NC High Country Council of Governments Final High Country Water Resource Plan 2010
' (www regiond org /planning /FINAL_WA1 ER—RESOURCE—PLAN pdf)
11

National Groundwater Association Numerical Ins estigation of Road Salt Impact on an Urban Nell
M L Bester E O Frind J W Molson and D L Rudolph 2005 (info ng-,va org /gwol/
pdf/061681221 pdf)
NOAA National Climate Data Center (lwf ncdc noaa go-, /oa /chm ite /online /ccd /snowfall html)
State of California Public Utilities Commission Memorandum Potential Groundwater Impacts
from Proposed Southern California Edison Jul) 2009 (www cpuc ca gov /Environment/
info /esa /sjxxl /O_comments /018 pdf)
SRF Consulting Group Inc April 2004 Stud) Report for Anal) sis of Highway Storm Water
Runoff Impacts to Potable Groundwater Aquifers St Croix Ri-, er Crossing (www dot state mn us/
metro /projects /stcroix /pdfs /sdeis /Tech %20Memos / Groundwater/ Groundwater pdf)
Surface Transportition Board Poit MacKenzie Rail Extension 1 inal Ens ironmental Impact
Statement March 2011 (www stbportmacraileis com/pdf/final/individual—chapters/
4-3—Groundwater pdf)
US Department of Transportation Federal Railroad Administration
En-, ironmental Assessment Memphis Regional Intermodal Faciht) Jul) 2010
Administrative Action Finding of No Significant Impact Norfolk Southern Railway Compan)
Memphis Regional Intermodal Faciht)
US Geological Sun e) Scientific Investig itions Reports Effects of Highway Deicing Chemicals on
Shallow Unconsolidated Aquifers in Ohio — Final Report August 2004 (pubs usgs gov /sir /2004/
5150/pdf/SIR2004_5150 pdf)
US Geological Sun e3 NC Water Science Center Distribution of Tr insmissii it) and Yield of the
Surficial Castle Hayne and Peedee Aquifers in Northern New Hanover County NC
(pubs usgs gov/of/2011/1205/)
U S Department of Agriculture Forest Service Technology & Development Program Measuring
Effects of Roads on Groundwater Fn e Case Studies January 1999 (www stream fs fed us /water
road /w r pdf /groudwatercases pdf)
US Go-, ernment Printing Office 42 USC 300g 1 National Drinking Water Regulations
(www gpo gov /fdsys /pkg /USCODE 2010 tide42 /pdf /USCODE 2010 tide42 chap6A
subchapXII partB sec300g 1 pdf)
US Em ironmental Protection Agenc) («v epa go-,)
Safe Drinking Water Act (www epa go-, /lawsregs /laws/ sdwa html)
Safe Drinking Water Act Enforcement (www epa gov /compliance /civil /sdwa /)
33 U S C 1251 et seq Federal Water Pollution Control Act (epw senate go-, /water pdf)
World Bank Technical Paper No 376 Edited b) Koji Tsunokawa and Christopher Hoban Roads
and the Environment. A Handbook (siteresources worldbank org /INTIRANSPORT/
Resources /336291 1107880869673/covertoc pdf)
12

J0 s
A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
o < ATLANTA FEDERAL CENTER
61 FORSYTH STREET
l4( PROI CG 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
� N
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
intemet Address (URL) http / /www epa 90V
Recycled/Recyclable Printed with Vegetable 09 Based Inks on Regded Paper (Minimum 30 A Posiconsumer)
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)
� N
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
intemet Address (URL) http / /www epa 90V
Recycled/Recyclable Printed with Vegetable 09 Based Inks on Regded Paper (Minimum 30 A Posiconsumer)

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(d),epa gov or (919) 8564206 or [phone] Thank you
Sincerely '
Heinz J Mueller
Chief NEPA Program Office '
w /Attachment
Cc S McClendon, USACE '
B Wrenn, NCDWQ

L11
I�I
ATTACHMENT A
Supplemental Report dated 2/8/12 on Public Water Supply Impacts
US 17 Hampstead Bypass/Mthtary Cut -off Road Extension
Pender and New Hanover Counties, N C
TIP Project 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 6 lanes 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 Sunnly
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 M1 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 major
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)
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 M1 and M2 Alternatives 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 "Von 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 Major 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 (WPAI = 7,712 acres)
14 The following statement is confusing "No existing or proposed roads were included in the
list of identified potential contaminant sources in the WHPP CFPUA may have been unaware
of the scope, location and timing of the proposed MCRE as some concept of this proposed
protect 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 M1 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 nsk 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
r.
II

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 Sunvly
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 M 1 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 M1 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 Ouality
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 drawing from" 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 M1 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, peinutted
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 matenals 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 project 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 ora /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

M
ENGINEERS & CONSULTANTS
MEMORANDUM
To U 4751 & R 3300 Merger 1 cam Members
FROM Liz Kovasckitz Mulke3 Engineers and Consultlntti
DATE Mai 1 2012
SUBJECT Addendum Ind ReN isions to the February 8 2012 Evaluation of Lnpacts to Public Vatei
Supply Groundwater Wells US 97 Corridor Study N CD O T TIP Proleds U 4 751 e
R 3300 Pender and New Hanover Counties
At the December 15 2011 Concurrence Point 3 informational meeting the merger team requested
additional information on potential public water suppl) impacts prior to LEDPA concurrence In
response to the request supplemental information was provided to the merger team on Februar) 9
2012 in a report titled E-, alultion of Impacts to Public Water Supply Groundwater Wells US 17
Corridor Stud) NCDOT Projects U 4751 & R 3300 (Evaluation) EPA provided comments on
the E-, aluation on February 28 2012 A cop) of the E-, aluation EPA s February 28`h comments
and this memorandum are included in Appendix D of the Ma) 17 2012 Concurrence Point 3
merger meeting packet
The following supplemental information and revisions are provided in response to EPA s February
28`h comments on the Evaluation and serve as an addendum to the original Evaluation document
Project Description
Comment EPA notes that the right of way width is variable from 150 feet to 350 feet EPA
requests that the variable right of wa) width be depicted on preliminary designs for MCRE's Ml
and M2 Alternatives at the next Merger meeting
Response Military Cutoff Road Extension design displays will be provided at the CP3 merger
meeting
Public Water Suvvly
Comment 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 major roadwa) s
that are found within wellhead protection areas be pro-, ided to support this vague claim Wellhead
I protection areas generally tend to be located in under eloped areas and not in areas with existing
"higher risks"
Response GIS data indicate that 110 of the 130 wellhead protection areas in North Carolina are
intersected by a major roadway (NC US or Interstate Route) Of those 110 wellhead protection
areas approximatel) 61 percent are tra-, ersed by two or more major roads approximately 35
M 11 67511 T n.. R.nD C NC 275 B P❑ Bo 33127 Rn H NC 27636 PH 1119 1151 1912 1s 919 1151 191B WWI Nu N 0"

percent are crossed b) three or more major roads and about 12 percent are crossed b) four or
more major loads
There are 226 wells located within 750 feet of less of a major road -,tithin the 130 wellhead
protection areas Of those 73 wells are located within 200 feet or less of a major road and 22
wells are located within 125 feet or less of a major road
Wellhead Protection Area
Comment Table 1 pro-, ides the CFPUA wells in the -, tcirnt) of MCRE and relei ant data (Well
Site /IS# Aquifer WHPP radius )field MCRE Alternati -, e 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 hunts for the proposed multi lane MCRE The
NCDOT right of wa) would potentiall) be closer to the wellheads Slope stakes information
w ould not appear to meet the criteria required to determine the 100 foot buffer per State
regulations
Response A column showing the distance from the right of wa) to wellheads was added to the
table Refinements to the design ha-, e resulted in an increase in the distance to slope stake limits
than what was previously included in the table in the Evaluation document with the exception of
Well Site L Well ) telds were corrected for Well no s 22 and 23
Comment 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
Response See previous response
2

T1ble 1 Summary of CFPUA Wells in the Victnit� of Mihtar5 Cutoff Road Extension
3
Distance from
Distance from
Well
Well
Well
WHPP
Yield
Closest
Wellhead to
Wellhead to
Site
ID
Depth
Aquifer
Radius
(gpm)
MCRE
MCRE Slope
MCRE Right of
(ft)
(ft)
Alternative
Stake Limits (ft )
Way Limits (ft)
P
8
160
Peedee
2000
600
M1 M2
807
776
Q
16
175
Peedee
3 000
500
M1 M2
1936
1958
B
22
170
Peedee
3 000
900
M1 M2
126
118
A
23
170
Peedee
3 000
1 000
M1 M2
1 762
1 749
M
28
175
Peedee
2000
750
M1 M2
568
524
N
29
175
Peedee
2000
750
M1 M2
797
764
O
30
175
Peedee
2000
570
M1 M2
1 006
974
Castle
A
A CH
95
2 96D
600
M1 M2
1 6D4
1 641
Ha) ne
Castle
B
B CH
80
3 097
640
M1 M2
134
123
Has ne
Castle
C
C CH
105
2 406
600
M2
1 402
1 333
Ha) ne
C
C PD
168
Peedee
3 000
570
M2
1 379
1 309
Castle
F
F CH
105
2 273
600
M2
764
727
Has ne
F
1i PD
170
Peedee
3 000
570
M2
770
744
Castle
G
G CH
90
2 440
500
M2
523
471
Has ne
G
G PD
173
Peedee
3 000
570
M2
546
494
Castle
H
H CH
100
2 471
600
M2
184
152
Has ne
H
H PD
175
Peedee
3 000
570
M2
160
128
Castle
I
I CH
95
2206
400
M2
2 109
2095
Ha} ne
I
I PD
175
Peedee
3 000
570
M2
2081
2067
Castle
J
J CH
100
2 493
600
M2
546
521
Ha) ne
J
J PD
175
Peedee
3 000
570
M2
573
548
Castle
K
K CH
100
2 713
200
M1 M2
1 334
1 304
Hayne
K
K PD
175
Peedee
3 000
600
M1 M2
1 272
1 241
Castle
L
L CH
85
3 054
500
M2
805
784
Has ne
L
L PD
170
Peedee
3 000
640
M2
789
763
3

Wellhead Protection Plan
Comment The CFPUA Risk Criteria lists 'Major Road in the higher risk category undei
likelihood of occurrence The sources of pesticides herbicides metals and sol-, ents of sufficient
quantity that are less than 7:)0 feet from a well are considered higher risk with the Major 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)
Response See response to the first comment under I --,, aluation of Potential Impacts below
Comment The following statement is confusing 'No evivi ng orpropored moadr mveme included mn the last
of identified potential tontammnant sounev i1i the VJ-1PP CFPUA may ha-, e 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 feasibiht) stud) from the earl) 1990 s NCDOT did not identif the
potentially impacted «ellhead sites for MCRE alternatii es Ml and M2 earlier in the
NEPA /Section 404 Merger team process during the de-, elopment of reasonable corridors
Response The statement was noting the WHPP did not list specific roads as potential contanunant
sources CFPUA was aware of the proposed road
Comment 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
BI pass or other project study area roadwa) s 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 `,1PA1 is probabl) alread) 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 e-, ents could gread) acerbate spill cleanup efforts and allow
contaminants to spread at a significant distance from the source
Response See response to the first comment under E-, aluation of Potential Impacts belo«
Evaluation of Potential Impacts
Comment Without the additional information from NCDOT concerning truck traffic
percentages potential volumes of hazardous materials and the t) pes of hazardous materials
currently utilizing US 17 Wilmington B) pass 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
Response A total of 41 roads are located within 750 feet of existing wellheads in the CFPUA
WHPA Man) are prig ate or residential roads Truck traffic data for roads eN aluated in the traffic
forecast which are located within 750 feet of existing wellheads is shown in the table below A -, er)
small section of the southeast quadrant of the Hampstead B) pass Alternatt-, e O interchange is
within 750 feet of existing wells but was not included in the anal) sis Although the) are not within
750 feet of existing wells data for US 17 /US 17 Business (Market Street) between Gordon Road
and Futch Creek Road and for US 17 Wilmington B) pass are included for comparison
m

n
1 Table 2 Forecasted Truck Trlffic (2035) for Military Cutoff Rd Extension and Area Roadways
2035
Using traffic -, olumes and truck percentages from the 2035 forecast the total number of trucks
Roadways
(duals and TTSTs) was calcul -ited According to the TH \VA publication FH \VA HOP 08 058
Total Forecasted 2035 Truck
Traffic Incident Management in Hatiardoils Matenalc Spillc in Incident Clearance 2009 the US DOI
Within-450
estimates th it se-,en percent of all trucks are carrying hazardous material This percentage was
Traffic
applied to the total number of trucks forecasted for e ich roadwa) to estimate the total number of
Feet oaf
trucks carry ing hazardous materials on the selected roads in 2035 for both Alternatives M1 and M2
1 Table 2 Forecasted Truck Trlffic (2035) for Military Cutoff Rd Extension and Area Roadways
'Numbers presented are from the Tratfic Forecast for All +ILH / All +K
Numbers presented are from the Traffic Forecast for 1\12 +0
3FHVIA s PETRA Pro Reference Mannaf the classification duals includes buses camp and recreation vehicles and
motor homes
5
2035
Estimated Number of Trucks
Roadways
AADT
Total Forecasted 2035 Truck
Carrying Hazardous Materials
Within-450
% Duals, % TTST
Traffic
7% of Total Number of Trucks
Feet oaf
Existing
M11,�6
M22
Mil
M22
Wellhead
Ml i
M2 2
Duals
TTST
Duals
TTST
Duals3
TTST
Dual83
TTST
Plantation
5200
5200
156
156
8 400
9 400
52 84
52 94
11 18
46
11 20
47
Road
252
282
31
31
Putnam
5 000
5 000
100
100
5200
5200
50 52
50 52
7
4
7
4
Drive
104
104
21
21
ood
3800
3800
76
76
5 800
5 800
38 58
38 58
5 8
3 4
5 8
34
BI-, d
BI-, d
116
116
(2 1)
2 1
Mihtar5
44000—
4500 —
1 760
1 320
1 800
1 350
123
126
Cutoff Road
53 400
54 000
2 136
1 602
2 160
1 620
150
92 112
151
95 113
Extension
4 3
4 3
Other Brea
Roadw�a ,s
US 17 Bus
(From
35 600
34 600
1 424
712
1 384
692
100
Gordan Rd
63 800
66 000
2 552
1 276
2 640
1 320
179
50 89
97 185
4892
to Futch
(4 2)
(4 2)
Creek Rd
US 17
41 600
40 600
1 248
832
1 218
812
Wilmington
90 000
86 000
87 189
58 126
85 181
57 120
2 700
1 800
2 580
1 720
B ass
(3 2)
(3 2)
'Numbers presented are from the Tratfic Forecast for All +ILH / All +K
Numbers presented are from the Traffic Forecast for 1\12 +0
3FHVIA s PETRA Pro Reference Mannaf the classification duals includes buses camp and recreation vehicles and
motor homes
5

The US Department of Transportation Pipeline Ind Hazardous Materials Safet) Administration
( -,v-,vw phmsa dot go-, /hazmat /hbrar) /data stats /incidents) Ten Year Incident Summary Reports for
Accident/ Derailment Incidents show there were 95 reported incidents in North Carolina between
2002 and 2011 Ninet) of the incidents occurred while in transit Of these onl) two (2 2 %)
occurred in or around Wilnrungton Both incidents occurred on 3 a Street near downtown
Wilmington
A review of the Geotechnical Report (NCDO 1 2009) and various databases including
) ellowpages com and manta com (an online business director)) indicates the following t) pes of
businesses that could be transporting hazardous materials in the Wilmington area gas stations
Hazardous Waste Transporters lestimated from Hazardous Waste Generators /Transporters — as
defined b) the Resource Consen ation Reco-, er) Act (RCRA) Dig ision of Waste Management
Hazardous Waste Section October 2008] a nuclear rod assembl) plant oil and gasoline distribution
facilities paper mills /manufacturers chemical plants and numerous marine construction and repair
businesses The following obsen ations are made based on the location of the businesses their
proximity to major roadway s and the likelihood the) would utilize roads within 750 feet of the
CFPUA wellheads (see Figure 1)
Sei eral gas stations are located on Market Street howei er none are located on roads within 7D0
feet of the wellheads Since most of these roadwa) s are residential streets it seems unhkel) that
trucks deh-, ering gasoline would use them It is possible that trucks delivering fuel to the gas
stations would use Military Cutoff Road Extension
Of the eight (estimated) hazardous waste transporters none are located on an) of the roadwa) s
within the 750 feet of the wells Half are located on N College Road It seems hkel) that
vehicles from these facilities would use I 40 /College Road for east west tray el or US 17 for
north /south tra-, el The NCNG (NC National Guard) Wilmington Operations Center is located
on Military Cutoff Road so it is possible that trucks from that faciht) would travel on Mihtar)
Cutoff Road Extension
• The nuclear rod assembl) plant (GE Hitachi Nuclear Energy Inc) is located west of I 40 on
Castle Ha) ne Road near the 1 140 interchange Because of the faciht) s proximity to I 140 I 4C
and US 117 it seems unhkel) that its trucks would use Mihtar) Cutoff Road Extension or other
roads within 750 feet of the CFPUA wells
• Oil and gas distributors are located throughout Wilmington It is possible that some of the
distributors could make fuel dehN eries to homes using roadways within 750 feet of existing
wellheads including Mihtar) Cutoff Road Extension
A paper manufacturer Gennex Inc is located near US 17 and Gordon Road This faciht)
appears to be a fairl) small operation from aerial mapping A Georgia Pacific facility is located
west of US 117/US 74 on Randall Parkwa) near Kerr Avenue Based on their relate-, e
proximities to US 17 it seems likely that both facilities would use this roadway for travel
However based solely on their locations it seems that the one located near US 17 and Gordon
Road would be more hkel) to use Military Cutoff Road Extension than the other facility which
is well south of the project

Figure 1 Hazardous Mateiills 1 ransporters in the Project Vicirut} Potentially Utthzing Roads within
750 feet of CFPUA Wells Near Mrhtai5 Cutoff Road Extension
I
5
Legend
C ty Bound ry • Ch m I Pla t
�._ R d • Gas St t
• Hezmat Tm
Wep Head • Nuclea R d Assrt
embly Pla t
} �\ O Well Head 750 Suffe • M m C St ho d R pa
/' • 01 d Gas Dud but o F 0d
-� U Well Head Prot dwn Area O P Ip d Pape
\ \� Alternatives
lMest /E st MC210 West /East o1NC210
�Adematwe M1 �Alt m Iry E H
�Allem try M2 Alt m tw R
TT� OWMAlt matn O �>rAft m W U e
ri
7
0
—J-
2 \
�0 0
C'o \
li
fr

• Se-, eral chemical plants are located in the Wilmington area all near major routes such as I 40
US 17 Wilmington B} pass US 17 Business US 117 US 74 /US 76 or US 421 Three facilities
are located in proximity to the Military Cutoff Road Extension or Hampstead 135 pass and it is
possible the) would utilize Mihtar) Cutoff Road Extension to transport materials to and from
their facilities Additional detail for these three facilities is provided below
o Southeastern Chemical located at 2936 On ille Wright Wa) is approximately fi-, e miles
north -test of the Gordon Road /Military Cutoff Road intersection Nearb) major roads
include US 17 Wilmington B) pass I 40 and US 117
o Coastal Chemical and Paper (204D Corporate Dri-\ e) is located approximately four miles
northwest of the Military Cutoff Road /Gordon Road inteisection so it is possible that trucks
from this facility would use Mihtar) Cutoff Road Extension Nearb) major roads include I
40 and the US 17 Wilmington B) pass
o Elementis Chromium located at 5408 Holly Shelter Road is located approaimatel) one mile
from I 40 It is possible that trucks from this faciht) would use Military Cutoff Road
Extension to go south on Market Street HoweN er it seems more hkel) trucks would remain
on 140
• Numerous marine construction and repair facilities are located throughout the project area A
cursory rep iew of their addresses indicates it is possible that shipments to and from
approximatel) six facilities would hkel) use Milhtary Cutoff Road Extension
The Hazardous Materials Uniform Transportation Safety Act (HMUTSA) of 1994 sets forth a
number of requirements for the transport of hazardous materials According to Transportation
Research Board Publication Cretena for Hzghavay Routing of Hatiardouv Matena1v (TRB 1998) one
requirement is that shippers must use routes designated for such transport Depending upon the
state various criteria are considered when designating a route for hazardous materials transport In
addition to such criteria as population density roadway type traffic i olumes and accident statistics
location of sensitive environments is also considered in the designation of these routes Other
considerations must be gi-, en when making such a decision including the effect on commerce cost
to transporters consistent) of routes and the effect on other regional and local roadw i) s
Comment EPA understands the general assessment concerning impervious surfaces However
the long term increase in pollutant loadings from major 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 e-, entually migrate o-, er time through the soil and
geological strata into deeper aquifers Depending upon rainfall pH and other environmental
factors (e g Bioaccumulation from wood) plant species) the soil t) pes etc this leaching can be
a source of groundwater contamination The wells at the greatest risk based upon proximity are
also relatiN el) shallow (e g Well B CH is 80 feet deep and that is not generally considered to be a
'deep well)
Response NCDOT has coordinated with Mr Gale _Johnson of the NCDENR Public Water Suppl)
(PWS) Section regarding the NC Wellhead Protection Program standard practices and potential
mitigation measures for roads within wellhead protection areas In addition to email and phone

J
Comment The comment Other potential impacts to groundwater quality are accidental spills and wrecks on
theproposed roadway [multi lane expresswa)J" 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 freewa) and expressway facilities in the project stud) 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
1 he proposed interchange along US 17 Wilmington B) pass /I 140 connects the proposed US 17/
Hampstead Bypass freewa) with the MCRE 6 lane expressway Truck drivers including those
hauling hazardous materials are under time pressure to make deh-, cries Pro-, iding multi lane
high speed facilities does not potentiall) reduce the number of accidents but does potentiall)
increase the sex erity and en-\ ironmental consequences from accidents
Response Wlvle future crash rates for a specific faciht) cannot be predicted a comparison of
statewide total crash rates show that urban multi lane do ided facilities with partial control of
access (such as the proposed Military Cutoff Road Extension) ha-, e lower total crash rates than
urban facilities with no control of access (such as portions of existing Market Street /existing
US 17) the 2008 2012 statewide total truck crash rate for urban multi lane di -, ided facilities with
partial control of access is also less than the statewide total truck crash rate for urban facilities
with no control of access
9
contact a meeting w is held on April 3 2012 to discuss the proposed project in relation to the
CFPUA WHPA In addition to Mr Johnson from P\VS meeting participants included the USACE
and NCDOT representati-, es from PDEA Roadw i3 Design Hy drauhcs and Roadside
En-, ironment it
During the meeting Mr Johnson noted North Carolina has -in EPA ippro-, ed -\ oluntar Wellhead
Protection Program administered b3 the PWS Section for the protection of public drinking water
supplies relying on groundwater Local jurisdictions adopting a Wellhead Protection Plan can
choose a regulator) approach such as zoning or a non regulator) - ipproach that relies on existing
State programs already in place Mr Johnson noted that most local public water suppl) s) stems rel)
heavily on existing rules and iegulations that are in place to protect the water suppl) and chose to
take a non regulator approach Local jurisdictions der elop their voluntary plans to pro-, ide
additional measures be) and the regulator requirements He noted there are other water systems
with completel) unconfined wells with nearby roads
Mr Johnson stated that the 100 foot buffer regulation is a non negotiable requirement No new
sources of potential contamination can be located within the 100 foot buffer and the area within the
buffer must be owned and controlled b3 the local operators
Based on the discussion at the April 3 2012 meeting it was determined that there are no design
elements such as hazardous spill catch basins that need to be added to the project Minimization
for the proposed project would potentilll) be signing and additional education regarding the water
suppl) area for emergenc) responders
In order to ensure that tap water is safe to drink EPA prescribes regulations which limit the amount
of substances in water pro-, ided b) public water suppl) s) stems CFPUA conducts regular
monitoring of o-, er 150 substances in accordance with federal and state laws
Comment The comment Other potential impacts to groundwater quality are accidental spills and wrecks on
theproposed roadway [multi lane expresswa)J" 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 freewa) and expressway facilities in the project stud) 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
1 he proposed interchange along US 17 Wilmington B) pass /I 140 connects the proposed US 17/
Hampstead Bypass freewa) with the MCRE 6 lane expressway Truck drivers including those
hauling hazardous materials are under time pressure to make deh-, cries Pro-, iding multi lane
high speed facilities does not potentiall) reduce the number of accidents but does potentiall)
increase the sex erity and en-\ ironmental consequences from accidents
Response Wlvle future crash rates for a specific faciht) cannot be predicted a comparison of
statewide total crash rates show that urban multi lane do ided facilities with partial control of
access (such as the proposed Military Cutoff Road Extension) ha-, e lower total crash rates than
urban facilities with no control of access (such as portions of existing Market Street /existing
US 17) the 2008 2012 statewide total truck crash rate for urban multi lane di -, ided facilities with
partial control of access is also less than the statewide total truck crash rate for urban facilities
with no control of access
9

The proposed posted speed limit for 1V41litarj Cutoff Road Extension is 45 mph The posted speed
limit for existing Market Street /existing US 17 -, aries from 45 mph to 5D mph
While accidents can happen dn-, er training requirements and regulations specific to the transport
of hazardous materials are included among the hedeial Motor Carrier Safety Administration and
the Pipeline and Hazardous Materials Safety Administration regulations intended to ensure the
safety of truck transportation (49 CFR Parts 130 171 173 177 381 384 390 399 etc)
Comment The statement is noted "If the contributing area for the well is identified and
management strategies are set in place to manage certain icti-, ities the possibility that the well
might become contaminated can be substantiall) reduced' Please identify these specific
management strategies that will be set in place to manage certain ictii ities' that will substantially
reduce the well from being contaminated that is located 126 feet from the slope stakes of the new
MCRE expresswa) CFPUA has developed management strategies in a WHPP NCDOT needs
to identify how the higher risk to the N PA -,vtll be minimized as the CFPUA did not identify an
existing 'Major roadwa) in their finalized WHPP NCDOI should identify what spill response
capabilities that the CPF'UA possess including the equipment pei sonal protectr% e 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 wa) 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 alwa) s have local spill cleanup contractors aN ailable and that it
t) picall) takes hours (and e-, en da) s) for cleanup personnel and equipment to arri-% e on scene
Response The CFPUA s contingent) and emergenc) management plans are examples of
management strategies identified in the Wellhead Protection Plan Regulator) setback requirements
and education/ outreach are others The de-, elopment of a contingency plan is a requirement of the
public water supply program An emergenc) management plan is required for appro-, al of the
public water suppl) system
Mr Johnson with the NCDENR PWS Section has indicated the CFPUA should include the
proposed Military Cutoff Road Extension in their next Wellhead Protection Plan update Mr
Johnson noted changes would be programmatic rather than design related The update could
include mitigation and points of contact for spill response The CFPUA Emergency Management
Plan also ma) need to be updated to recognize Military Cutoff Road Extension Mr Johnson stated
an example of a possible update to the CFPUA s Emergent) Management Plan and /or Wellhead
Protection Plan would be the inclusion of a strateg) to educate the local fire department about the
location of the proposed Military Cutoff Road Extension within the wellhead protection area and
the importance of response times for potential hazardous spill accidents Mr Johnson said the
primary goal would be to keep any materials from entering the distribution s) stem and a wa) to
isolate the potentiall) affected well
As noted abo\ e education and a contingent) plan that detailed safeguarding the s) stem through
well isolation are components of the CFPUA s Wellhead Protection Plan A cop) of the Plan will be
electronicall) distributed to merger team members
As noted in their 2011 Annual Report CFPUA abides b) state and federal emergenc) management
regulations for all hazards mitigation preparedness response and reco-, er) The report notes
Proacti-, el) working to meet the EPA s seventeen National Incident Management S) stem (NIMS)
compliance objectiN es for the water sector staff continues to refine emergenc) preparedness b)
10

I
I,
planning and implementing standardized response and mdustrs best practice measures as
recommended bs EPA FEMA and North Caiohna regulators agencies Eric T Hatcher
Emergency Management Coordinator for CFPUA provided additional information regarding their
Emergency Management Plan
• CFPUA has multiple inventors lists of their critical equipment If these wis an event the
scope of which exceeded their normal equipment resources they have contractors and local
and state wide emergency aid agreements in place CFPUA has categorized their Emergency
Response Teams per NIMS /ANX\VA standards
0 CFPUA has an internal notification list that consists of their emergency response partners
stakeholders and regulators agencies they would notify depending on the situation
(NCDENR PWSS media EPA DHS NCWaterNX7ARN) Many of the numbers are non
public numbers personal home and cell numbers etc They also have a Critical Customer
iM List hospitals doctor s offices large industrial users
The fact that control of access is proposed for Mihtars Cutoff Road Extension should not present
I� any issues for spill response
Comment The statement on Page 7 concerning the Peedee and Castle Hayne aquifers is
contradictory to the characterization on Page 3
Response Page 7 E-, aluation of Potential Impacts section third paragraph is corrected to
note the Peedee aquifer is confined and the Castle Hayne aquifer is semi confined
Water Sunuly
I�
Comment 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 sere ice Please provide additional details on these temporary
impacts
Response NCDOT will coordinate with CFPUA on utility impacts resulting from the proposed
project Both Mihtary Cutoff Road Extension alternatives would cross potable and raw water
lines associated with the CFPUA s nanofiltration water processing plant Any required relocation
of water lines and associated infrastructure would be completed as part of the project
Disruptions to service can typically be avoided or limited to a few hours when the final
connection from the old line to the new line is made There may be a period of low pressure in
the new line until pressure can build back up Final construction plans include utility
construction plans for water and sewer infrastructure operated by public utilities CFPUA has
indicated they can work with planned outages
I
Comment 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
nM1 and M2 EPA requests copies each of the preliminary designs in a readable scale for M1 and
11II M2 and the original locations of the impacted existing wellheads and the future wellhead sites
0 11
J

Response A cop) of the Military Cutoff Road Extension prehminary design with the location of
existing Cl PUA wells will be brought to the CP 3 meeting A Displa) map showing potential
future well site locations will also be pro-, ided
Comment From the prehminary 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 M1 and
M2 A noise wall was also proposed along the subdivision that was pre-, iously not being directl}
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
Response Where the Military Cutoff Road Extension design was shifted to avoid the wells the
following changes in impacts resulted wetland impacts were reduced by 65 acres for M1 and 26
acres for M2 stream impacts were reduced by 677 feet for M1 and 627 feet for M2 there were
three additional residential displacements for both M1 and M2 impacts to forested areas
increased by three acres for both M1 and M2 and impacts to the 100 foot well buffer were
eliminated A Design Noise Report will be prepared for the selected alternative
Water Quality
Comment Regarding the section on Accidental Spills EPA does not concur with the assessment
provided The assessment is not supported by any actual data or analy sis and includes the
following phrases 'probabj iepresents ' isprobably notgreater" and "likely could be contained and removed
before reaching the aquifers the welly are drawing f om" EPA requests a copy of the WHPP Contingency
Plan for review as the NCDOT is relying on the ChPUA s contingency planning efforts to
address the higher risk of contamination created by the revised alignment location for the M1 and
M2 Alternatives
Response The assessment included quahtati-, e conclusions based on available information A
copy of the CFPUA WHPP which includes short term and long term contingency plans will be
emailed to the merger team The Incident Action Plans (IAPs) provided by CFPUA are attached
to this memo It should be noted that the wells closest to the proposed Military Cutoff Road
Extension are on the Nano Water Treatment Plant property CFPUA personnel would therefore
be able to react within minutes of a spill
Comment Regarding the section on Stormwater Runoff the comment concerning the higher risk
potential as a contaminant source from stormwater discharges is noted "literature indicates that
highway stormwater does o6casionaly i ontaminate groundwater with minor amounts ( ?) of metals and petroleum
compound These chemicals are Opualy present at extremely low concentrations and tend to be localitied around
the rzgbt 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
releN ant factors to support this postulated assessment on risk
Response Reference studies with the identified specific parameters were not found The quoted
statement is attributed to an April 2004 report titled Analysis of Highway Storm Water Runoff
Impacts to Potable Groundwater Aquifers prepared by the SRF Consulting Group Inc for the
12

St Croix Ri-, ei Crossing Stakeholder Water Resources Stud) Group 1 his article used data from
Wisconsin and Minnesota 1 he report can be found at
hap / /www dot state mn us/ metro /projects /stcroix /pdfs /sdeis
/Tech %20Memos /Groundwa ter/ Groundwater pdf Another 2004 report titled Highwa) Runoff
in Areas of Karst Topograph) b) Bridget Donaldson for the Virginia Transportation Research
Council can be found at http / / -,v,,v,,v -, irginiadot org /-, trc /main/ online reports /12df /04 1713 Pdf
1 he Ground Water section in the 2011 CFPUA Annual Report indicates there have been no
® Notices of Violation and CFPUA has been compliant with all required testing
Avoidance and Minimization of Potential Impacts
Comment NCDOT is essentially requiring CFPUA to perform a-, oidance and minimization
measures to protect the WPA using the emergent) contingent) plan NCDOT is not proposing
an) hazardous spill catch basins in 1% ulnerable areas of the \N/PA to potentiall) catch contaminated
storinwater or accidental chemical spills NCDOT is not proposing an) special storm water basins
for collecting t) pical roadwa) runoff and pollutants
Response The NCDENR PWS Section has expressed the opinion and the CFPUA has agreed that
specific design elements such as hazardous spill catch basins would not be an appropriate
rrnnimization measure for the wellhead protection area The recommendation of the PWS Section is
that NCDOT assist with pro-, iding training to first responders in dealing with hazardous materials
spills in the wellhead protection area
Prior to the completion of the final environmental document for the project NCDOT will meet
with the CFPUA local fire departments and other appropriate agencies to discuss additional
protection measures for the WPA Measures requiring NCDOT participation will be identified in
the project commitments
Comment EPA does not support a ' NCDOT Spill Response Dial 911 sign To report chemical
spills hazardous materials transporters and other responders are required to can 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
Response Mr Eric T Hatcher Emergent) Management Coordinator for CFPUA in a phone
conversation made the following statement If there is a spill or potential contamination incident in
the protected area the best thing is for folks to call 911 or the 24 hour CFPUA emergent)
number In New Hanover County 911 is the central dispatch for all law enforcement fire EMS
agencies We work closely with them and they would notif) us The NCDENR PWS Section has
also indicated it would be beneficial to include signage to make the public aware the) are tra-, eking
through a water suppl) area Hazardous materials transporters and first responders will know who
to contact in response to 911 calls
Comment 'Appropriate measures' to a-, oid 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 project Ver) specific contract/ contractor requirements
regarding re fueling equipment (e g Diesel and gasoline powered equipment) in the V PA during
construction is one possible measure that should be considered The location or siting of
13

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 W iter Education Partnership
See http / /-,v-,v\v nccwep org /help /did 3 ou know php for the citation
Response NCDOT has Standard Spegfualionv that require the proper handling and use of
construction material Well locations and a 100 foot buffer around the wells will be depicted on
final constructions plans for Mihtar5 Cutoff Road Extension The Special Pro-, isions within the
final design plans will include a requirement for the contractor s to educate their employ ees that
project construction is occurring within a wellhead protection area
14

IAP C 1A - Threat of or Actual Contamination to Water System
POSSIBLE STAGE
IAP Summary
This Incident Action Plan applies to the intentional introduction of a contaminant into the water system
The contaminant could be introduced at any point within the system including raw water treatment
facilities distribution system including distribution pipes finished water storage or pump stations The
adversary may or may not give notice of the contaminant or provide the location Contamination may
have actually occurred or it may be a hoax
Initiation and Notification
1 Initiate this IAP if any of the following has occurred
Security Breach (including for example)
• Unsecured Doors
• Open Hatches
• Unlocked /Forced Gates
• Alarm Triggered
Witness Account (including for example)
• Suspicious Activity
• Trespassing
• Breaking and Entering
• Tampering with Equipment or Property
Direct Notification by Perpetrator (including for example)
• Verbal Threat
• Threat in Writing
Notification by Law Enforcement (including for example)
• Suspicious Activity
• Threat made to Water System
Notification by News Media (including for example)
• Threat Delivered to News Media
• Media Discovers Threat
Unusual Water Quality Parameters (including for example)
• Changes in pH chlorine residual or turbidity
• Unexpected monitoring or sampling results
• Strange odor color or appearance
Customer Complaints (including for example unexplained or unusually high complaints of)
• Odor
• Color or Appearance
• Taste
Public Health Notification (including for example)
• Victims in Emergency Rooms and /or Clinics
• High Incidence of Similar Health Complaints in one Local Area
Use this IAP if you receive any incident warning) indicating possible contamniation of your water system
If you have evidence that coi roborates the war nnrg or rf collective information indicates that contannnation is hAely GO TO
IAP 1 B — CREDIBLE STAGE
If there is confirmed evidence and /oi definite e information that the watei system has been contaminated GO TO IAP 1C—
CONFIRMED STAGE

IAP C 1A - Threat of or Actual Contamination to Water System
POSSIBLE STAGE
Initiation and Notification
2 Notify ORC or [ESMD] immediately upon discovery of any of the above Threat Warnings
The mdrn idual who first notices or recen es the tlu eat war nmg should contact the ORC immediately by whatever means of
communication may be available
Equipment Identified
Equipment Location
This equipment is mailable to assist in the execution of this AP
Specific Activities
I Assess the Problem
A Complete the following Threat Warning Report Forms according to the type of Threat Warning
received (Section VIII of ERP)
• Security Incident Report Form
• Witness Account Report Form
• Phone Threat Report Form (to be filled out during actual phone call)
• Written Threat Report Form
• Water Quality / Consumer Complaint Report Form
• Public Health Information Report Form
B Complete Threat Evaluation Worksheet (Section VIII of ERP)
C Evaluate Threat Evaluation Worksheet and determine if threat is Possible
If YES perform Response Steps 1 — 8 below
If NO return to normal operations
Threat Warning Report Forms help document organize and summar rze information about a secm rry incident The individual
mho discovers the incident warning the ORC or another designated individual may complete the form Only the form that
corresponds to the type of threat warning needs to be completed Completion of the form should not distract emergency
responders fi om mor e urgent matters
Threat Evaluation Worksheets help organize information about a threat warning that will be used dm mg the Threat
Evaluation Process The individual responsible for conducting the Tin eat Evaluation (e g the ORC) should complete this
worksheet

IAP C 1A - Threat of or Actual Contamination to Water System
POSSIBLE STAGE
II Isolate and Fix the Problem
1 Notify local law enforcement
2 Notify State Drinking Water Agency
3 Do not disturb site if location could be possible crime scene Consult Maintaining Crime
Scene Integrity Form in Section VIII
4 Alert staff and emergency response personnel about threat
5 Consider containment / isolation elevating chlorination and /or discharge of suspect water
6 Evaluate spread of suspect water and potential impact on public health
Notification phone numbers can be obtained fi om the Organization Contact List in the Appendices as well as from Section
III Dof the ERP
The immediate operational response actions ai e pt imai ily intended to Irma exposto e of customers to potentially
contaminated water
See EPA Toolbox Module 2 Section 3 3 2 for guidance on containing contaminants and evaluating moi ement of potentially
contaminated water through distribution systems
III Monitoring
7 Initiate Site Characterization Activities
• Define the investigation site
• Designate site characterization team members
• Conduct preliminary assessment of potential site hazards
• Approach site and conduct field safety screening to detect any hazards to the
characterization team
• Search for physical evidence (discarded containers etc )
• Investigate records from CCTV cameras
• Look for environmental indicators (dead animals or fish dead vegetation unusual odors or
residues)
• Perform rapid field testing of the water
• Collect water samples according to sampling plan
Site Chat actei ization is intended to gathei critical information to support the ct edible stage of threat evaluation
If signs of a hazard are evident dun ing the site approach the team should halt their approach and immediately inform the
ORC of their findings The site may then be turned over to the KAZMAT Team
The ORC may determine the thi eat is credible basedpi elmnnary information before the site chat acterization has been
completed
IV Recovery
and Return to Safety
8 Determine if threat is credible
If YES initiate AP 1 B
If NO
• Return to normal operations
• Store water samples for (enter predetermined time period here)
You should detet mine whether or not the threat is ci edible within 2 to 8 hours (preferably within 2 hours) fi om the time
the threat is deemed possible depending on the effectiveness of the containment sit ategy
If the tht eat is not deemed ci edible the samples obtained during site character ization should be stored in case the situation
changes and analysis is determined to be necessaty

IAP C 1A - Threat of or Actual Contamination to Water System
POSSIBLE STAGE
V Report of Findings
9 File incident reports
The Utihty [Security Director] should file an inter nal report for the Utthty s files and also pi ovide unfoi matron as requested
to Local Law Enfoi cement
VI AP -IA Revision Dates

IAP C 1 B - Threat of or Actual Contamination to Water System
CREDIBLE STAGE
IAP Summary
This Action Plan applies to the intentional introduction of a contaminant into the water system The
contaminant could be introduced at any point within the system including raw water treatment
facilities distribution system including distribution pipes finished water storage or pump stations
The adversary may or may not give notice identify the contaminant or provide the location
Contamination may have actually occurred or it may be a hoax
Initiation and Notification
A Initiate this AP if there is credible evidence that the water system has been contaminated
• Additional information collected during the investigation corroborates the threat warning
• Collective information indicates that contamination is likely
• Signs of contamination are observed during site characterization
• Additional water quality data shows unusual trends that are consistent with the initial data
and corroborate the threat
• A pattern of customer complaints emerges
• Previous threats and incidents corroborate the current threat
B Notify ORC or [ESMD] immediately upon discovery of credible evidence of threat (if not already
notified)
C Initiate ERP
D Initiate partial or full activation of the Emergency Operations Center (EOC)
Perform internal and external notifications according to ERP
If thei e is confirmed ei idence and /or definitive information that the water system has been contaminated GO TO AP IC —
CONFIRMED STAGE
The individual who first notices or i eceives the credible evidence should contact the ORC immediately by whatever means
of communication may be available
The ORC will decide whether to initiate the ERP on a pai tial or full basis The ORC will also decide when and to what
extent to activate the EOC
Notification phone numbers can be obtained from the Organization Contact List in the Appendices as well as from Section
IIIDof the ERP
The [Information Officer] [IOJ is the only one authorized to make notifications to outside agencies
Equipment Identified
Equipment Location
This equipment is available to assist in the execution of this AP
Specific Activities
I Assess the Problem
1 Assess results of previous sample analysis
2 Perform additional site characterization at primary sites as needed
Perform site characterization at any new investigation sites

IAP C 1 B - Threat of or Actual Contamination to Water System
CREDIBLE STAGE
II Isolate and Fix the Problem
3 Perform actions to estimate the contaminated area and predict movement of contamination
4 Take actions to isolate portions of system containing suspect water See ERP Section VIII for
System Shut Down Plan
5 Issue Boil Water Do not Drink or Do not Use orders and Press Releases as appropriate
See Section VIII A 1 of ERP for Press Release Forms
6 Initiate Alternate Water Supply Plan (ERP Section III G) to provide alternate water supply for
customers and fire protection as necessary
The contaminated ai ea can be estimated using hydi antic models consumer complaints public health agency i epoi is
water quality data or other ai ailable nfoi matron The estimate may define additional locations whet e site
character ization should be perfoi med
III Monitoring
7 Continue to monitor water quality in suspect parts of system by manual sampling rapid field
testing or automated means
IV Recovery and Return to Safety
8 Determine if threat is Confirmed
If YES Initiate AP 1 C
If NO
• Verify that water is safe
• Notify public that water is safe
• Notify outside agencies that water is safe
• Return to normal operations
• Store water samples for (enter predetermined time period here)
It may take sei eral days to collect sufficient ei idence to confirm a contamination incident depending on the type of
iiifoi nation used for confirmation (Some microbiological analytical procedm es may take sever at days)
If the flu eat is not deemed conf r med the samples obtained dm ing site characterization should be stoi ed in case the
situation changes and an analysis is deteimned to be necessary
V Report of Findings
E File incident reports
The Utility [Security Director] should file an inter nal i epoi t rot the Utility s files and also pi ovide infoi matron as
requested to Local Law Enforcement and other outside agencies
VI IAP -IB Revision Dates

IAP C 1 C - Contamination to Water System
CONFIRMED STAGE
IAP Summary
This Action Plan applies to the intentional introduction of a contaminant into the water system The
contaminant could be introduced at any point within the system including raw water treatment
facilities distribution system including distribution pipes finished water storage or pump stations
The adversary may or may not give notice identify the contaminant or provide the location
Contamination may have actually occurred or it may be a hoax
Initiation and Notification
A Initiate this IAP if there is confirmed evidence that the water system has been contaminated
1 There is analytical confirmation of the presence of one or more contaminants in the water
system
2 The preponderance of the evidence confirms that a contamination incident has occurred
• There is a security breach with obvious signs of contamination along with unusual water
quality and consumer complaints in the vicinity of the security breach
• Additional findings (laboratory analysis field observations) of continued site
characterization activities add to other credible evidence of contamination
• There is information from public health officials area hospitals or 911 call centers
indicating a problem with the water supply
• Law enforcement agencies have discovered crucial evidence or apprehended a suspect
that helps confirm that the water has been contaminated
• Specific information on a number of potential contaminants can be used in conjunction
with other available information to narrow down the number of contaminant candidates
If there is no confirmed evidence and no definitive rnfoi matron that the water system has been thi eatened of contaminated
GO TO IAP C IB — CREDIBLE STAGE
It may take sel eral days to collect sufficient evidence to confirm a contamination incident and the i equired time will
depend on the type of information used for confu matron (some microbial analytical pi ocedures may take sel ei al days)

IAP C 1C - Contamination to Water System
CONFIRMED STAGE
Initiation and Notification
B Notify ORC or [ESMD] immediately upon discovery of confirmed evidence of contamination (if not
already notified)
C Initiate full ERP activation
D Initiate full activation of Emergency Operations Center (EOC)
E Engage other organization as needed (drinking water primacy agency public health agency
response agencies law enforcement)
F Perform internal and external notifications according to ERP
The individual » ho fnist becomes aware of the confirmed el idence should contact the ORC i intediately b) is hatevei means
of communication may be ai ailable
the ORC will decide tit hethei to initiate the ERP on a par tial of full basis The ORC will also decide when and to what
extent to actuate the EOC
Notification phone number s can be obtained fi onn the Organization Contact List in the Appendices as ii ell a s fi on? Section
III Dof the ERP
The [Information Officer] [PIO/ should male the notifications to the outside agencies
Equipment Identified
Equipment Location
This equipment is available to assist in the execution of this IAP
Specific Activities
I Assess the Problem
Assess results of previous sample analysis and attempt to identify the contaminant
1 Confirm the identity of the contaminant
Effeem e implementation of i esponse actions depends on positive identification of the contaminant and knowledge of
contaminant pi opei ties including public health protection strategies and selection of treatment technologies
2 Perform a full characterization of the contaminated area including contaminant properties
contaminant concentration profiles and characteristics of the impacted area
3 Evaluate the likely direction and extent of future movement of the contaminant within the
distribution system
4 Evaluate all available information about the contamination incident
If information from site chat actei ization acm sties indicates that the contaminant impacts water quality in a cei tam niannei
(i e consumes free chlorine of imparts a cei tarn odor to the water) the contaminant specific information may facihtate
tentative identification of a contaminant and determine the analytical approach that should be used to positively identify
the specific contaminant Sources of contaminant information include
http //w %w bt cdc ov/a en�t/aeenthstchem asp
http / /www cdc gov/atsdr /index html
http / /www xaterisac on Q/
EPA Water Contaminant Information Tool (WCIT)

IAP C 1C - Contamination to Water System
CONFIRMED STAGE
II Isolate and Fix the Problem
5 Take actions to isolate portions of system containing suspect water See ERP Section VIII for
System Shut Down Plan
6 Shut down system if obvious or confirmed contamination warrants
7 Issue Boil Water Do not Drink or Do not Use orders and Press Releases as appropriate
8 Initiate Alternate Water Supply Plan (ERP Section 3) to provide alternate water supply for
customers and fire protection as necessary
9 Revise public health response measures and public notifications as necessary
The contaminated area can be estimated using hydrauhc modes consumer complaints public health agency r eports water
guahty data or other ai arlable information The estimate may define additional locations when e site char acter ization
should be performed
III Monitoring
10 Continue sampling and analysis to monitor the status and extent of the contamination and to
verify that containment strategies are working
IV Recovery and Return to Safety
11 Consult with appropriate officials to develop a Remediation and Recovery Plan
a Evaluate options for treating contaminated water and rehabilitating system components
b Select treatment and rehabilitation technology /approach
c Develop strategy for disposal of contaminated residuals
d Develop sampling and analysis plan to verify remediation
e Develop communications and public relations plan
12 Implement Remediation and Recovery Plan
a Verify that water is safe by performing additional sampling and analysis to confirm the
progress of system treatment and remediation
b Notify public that water is safe
c Notify outside agencies that water is safe
d Return to normal operations
e Store water samples for (enter predetermined time period here)
Remediation and recovery actn rues will likely be planned and implemented by a number of agencies The first step of the
process is to establish the roles and responsibilities of each organization
The samples obtained during site char acterrzatron and monitoring should be stor ed in case the situation changes and
further analysis is determined to be necessary

IAP C 1C - Contamination to Water System
CONFIRMED STAGE
V Report of Findings
G File incident reports with internal and external agencies as required
The Utility [Security Director] should file an intef nal i epoi t for the Unhty s files and also pros tde information as
i equested to outside agencies
VI AP -IC Revision Dates

C 21 IAP Significant Event in Drainage Area
IAP
This Incident Action Plan applies to a known or suspected incident in which harmful
Summary
contaminants will or may end up in the sewers stem
Initiation
1 Initiate this IAP if it is known or suspected that a
This Incident Action Plan is
pantuculauly applicable to
and
harmful substance may be introduced or end u in the
Y p
wastewater systems with
Notification
sewer system through an incident in the drainage area
combuued sanitary and
Report of a potential or real incident may originate from
storm sewers but
• Discovery of a harmful substance by a worker who
hazardous matcru ds could
observes contamination or smells strong odors
cater the CFPUA
collection system via open
• A report from a customer who has had an
manholes
accidental discharge
If this is a small incident
• A report from the law enforcement or the fire
that can be contained of
department notifying the wastewater system that
do erted activate
operational response
there is a real or potential discharge into the
pioceduues such as shut
system
down ou isolation of
• Awareness of an incident such as a tanker truck
affected system
spill in which a potential discharge into the
components
drainage system is suspected
If this is a large scale
incident in which the
• Detection of a harmful substance in the system via
population is at risk to
monitoring equipment and /or alarms
explosion orfurefuonu the
2 Notify the ESMD Director and /or the Emergency
seu er system contact the
Response Coordinator
local emergency response
authorities to coordinate
3 Make other internal notifications as necessary
response containment and
evacuation of other
4 Consider activation of the ERP and EOC
population protection
5 Direct the Public Information Officer to make external
operations Activate the
notifications as necessary
agency Emergency
Operations Center and be
6 If the substance is known immediately refer to the
prepared to assist the
MSDS to determine safety precautions and
emergency responders
flammability
If the identity of the
7 Call 9 1 1 if the harmful substance has the potential
substance is known check
for fire and /or explosion
with the nnanu factmeu a
on line resources such as
www chemtrec com
www msdsonitne com
If an evacuation is ou dei ed
by public safety officials
coot dinate all operations
with the Incident
Commander to ensure the
safety of the public and
response workers
Equipment
Equipment
Location
Thus equipment is available
Identified
to assist in the execution of
this AP
Self Contained Breathin

C 21 IAP Significant Event in Drainage
Area
Apparatus SCBA
Personal Protective Equipment
PPE
Sampling Equipment
Specific
Activities
I Assess
1 Identify the harmful substance(s) and assess the potential
Determine who the oieiall
the Problem
for contamination and damage
Incident Commande, for
the incident is Follow the
a If the substance presents a risk to workers check
commands and dnection of
with safety professionals and /or MSDSs to
the Incident Commander to
determine health risks and appropriate safety
piotect,iorkers and the
precautions for responders
public
b Determine if the substance is flammable
Obtain eApei t consultation
explosive corrosive or radioactive If yes then
from public and prnate
respond with the highest level of protection for
resources as needed to fully
workers and the public Avoid any source of
assess the impacts of
ignition for flammable and explosive Avoid
incident ifcontannnat,on
contact for corrosive and radioactive
does occur
2 Assess the quantity of substance that has or may be
introduced into the system
3 In conjunction with local emergency responders
determine the level of emergency and immediate actions
necessary to protect workers the public and the system
4 Provide updated status reports to the Incident
Commander
5 If this is an accidental discharge from a known customer
or entity and NOT AN INTENTIONAL INCIDENT
coordinate protection and response actions with the
source entity
II Isolate
6 Immediately prevent further introduction of harmful
Utility workers should only
and Fix the
substances at the source If it is not possible for
become involied in
Problem
wastewater personnel to stop the source request
response activities for
assistance from local state or federal emergency
which they are properly
response agencies
trained
7 If the substance has entered the system determine the
Notify other response
agencies such as H,4ZMAT
likely pathway and if possible isolate the substance or
Teams and City or County
divert it from critical and sensitive facilities such as
Emergency Response
treatment plants and settling ponds
Teams ,f wastewater
8 If unable to divert the contaminated wastewater
system personnel are not
determine if dilution or chemical treatment
able to contain the hazard
or safely operate the
countermeasures are possible and if so treat or dilute
system
the substance

C 21 IAP Significant Event in Drainage Area
9 If unable to divert treat or dilute
a Take all possible measures to protect the public and
the wastewater system
b Notify treatment plant operators that the substance
may be present in the plant influent
c Notify the appropriate regulatory agencies if there is
a chance that permit violations may occur
d Shut down part or all of the wastewater system if
necessary
III
10 Monitor wastewater quality in suspect parts of system by
The corrtammated area can
be estimated using
Monitoring
manual sampling or automated means if available
hydraulic models
11 Instruct plant operators to increase monitoring /sampling
wastewater quality data o,
at the head works and throughout the plant
other available information
The estimate may define
12 Provide monitoring /sampling results to the [Incident
additional locations where
Commander] for evaluation
sampling should be
performed
If then e is a risk of
explosions in the sex et
system the local HAZMAT
team may conduct
monitoring and sampling
IV
13 Obtain professional expert support regarding
Remediatron and recovery
acm itres will likely be
Recovery
decontamination and system restoration
planned and implemented
and Return
to Safety
14 Decontaminate system per instructions from fire and
by a number of agencies
The the
health officials and /or decontamination experts
first step of process
is to establish the roles and
15 Develop strategy for disposal of contaminated liquid and
responsibilities of each
solids streams
organization
16 Restore operations according to system specifications
and start up
17 Assess workers for residual health impacts
18 Assess the situation for the possibility of repeat
occurrences and increase security system integrity or
controls at the source
19 Cooperate with investigators if this was an intentional
action
V Report
20 File incident reports with internal and external agencies
p g
The ESMDDirector should
file an internal repot t for
of Findings
as required
the utility s files and also
provide information as
requested to outside
agencies
VI AP-

C 21 IAP Significant Event in Drainage Area
WW-7
Revision
Dates

P E N Q E R
133
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