20081579 Ver 1_Other Agency Correspondence_20090311

A*PF11 6r® NR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
March 11, 2009
TO: Melba McGee, Environmental Projects Officer, DENR
THRU: Alan Clark, Section Chief
Ac-
Planning Section
FROM: Hannah Stallings, SEPA Coordinator
Basinwide Planning Unit and SEPA Program
SUBJECT: Cumberland, Hoke, Moore, Harnett, and Lee Counties
Ft. Bragg - Grow the Army EA; DENR#08-0386, DWQ#13993
Dee Freeman
Secretary
The Division of Water Quality (DWQ) has reviewed the information provided via email from Christie Lowery, NEPA Analyst at Ft.
Bragg. We noticed that Ft. Bragg issued a Finding of No Significant Impact (FNSI) for this project without addressing many of our
comments. We will not request a retraction of the FNSI. However, DWQ wishes to highlight that the wastewater infrastructure needs
of Ft. Bragg do not currently exist and that some additional environmental review and permitting steps must be taken before the
infrastructure would be available to serve the influx of troops and personnel the base is expecting.
As was pointed out in our July 18, 2008, memo, Ft. Bragg does not currently have a connection to Harnett County's South Regional
WWTP. (Unresolved issues from this memo are attached for reference.) Also, this facility has not been expanded to addres's the
regionalization with Ft. Bragg (and Spring Lake). While the EA for the South Regional WWTP expansion and regionalization effort
was submitted in February 2009, DWQ has concerns that the interagency review process for this document could be a prolonged due
to 1) the potential for the wastewater conveyance structure to impact federally-listed species in both Harnett and Cumberland Counties
and 2) the presence of two historic properties within close distance to the WWTP (Ellerslie and Thorbiskope are both on the National
Register of Historic Places).
It is DWQ's experience that high-profile projects such as these that have the potential to impact natural and cultural resources, both
directly and indirectly, and take a considerable amount of time to complete interagency review. DWQ is aware that the US Fish
Wildlife Service, NC Wildlife Resources Commission, and State Historic Preservation Office could request negotiation meetings with
impacted parties and project proponents to arrive at a conditional concurrence with the South Harnett WWTP expansion. Also, please
keep in mind that Harnett County will also have to resolve any other outstanding agency comments on its WWTP expansion and
regionalization efforts prior to a FNSI.
DWQ will handle the environmental reviews and permitting actions as quickly as possible; however, for planning purposes, we
believe that it is important that Ft Bragg be fully aware of the interagency review process for the WWTP expansion and the potential
for time delays and uncertainties associated with this process.
Please contact me at 919-807-6434, if I can be of any additional help.
Cc: Brian Sexton - Marziano & McGougan
Chuck Wakild - DWQ
Danny Smith- DWQ, RRO
Belinda Henson - DWQ, FRO
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N, Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
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Excerpts from July 18, 2008, memo Ft. Bragg
1. The Environmental Assessment states that "To enable implementation of the GTA recommendations, the Army proposes to
provide necessary facilities to support the changes in force structure at Fort Bragg. This environmental assessment (EA) analyzes
and documents environmental effects associated with the Army's proposed action at Fort Bragg." Clarification is needed on
whether this EA will account for all impacts associated with expected growth at Ft. Bragg.
a. While Section 4.12.1.2 on page 4/109 says that Harnett County is currently capable of receiving wastewater flows from the
base, the draft EA submitted by Harnett County and the attached May 14, 2008, correspondence from the County state the
South Central Harnett W WTP must be expanded to receive flows from Ft. Bragg and a wastewater collection system must be
established between Ft. Bragg and the existing Harnett County system. Please clarify.
b. DWQ cannot adequately comment on the impacts associated with the "Associated needs and infrastructure would include
electric service, water, sewer, paving and site improvements" because the specific impacts of installing this infrastructure are
not provided. It is requested that sections 4.6.2.2, 4.14.4.6, and 4.15 be amended to include the effects of installing the
necessary water, wastewater, and other such infrastructure to support Bragg's growth.
c. DWQ recommends that Ft. Bragg closely cooperate efforts with Harnett County (and others, such as Fayetteville PWC) in the
development of the infrastructure needed to provide for the increase in personnel.
2. Page ES-7, Table ES.3, Surface Water/Wetlands
a. Need to change rating of resource impact based on comment 5, below.
b. Need to list wastewater effluent and drinking water impacts.
3. Page ES-9, Table ES.3, Utilities - Change this based on comments 2.a. and 5.
4. Page 4-61, Section 4.82.2., Wetland Habitat: Please state the acreage of wetlands that will be converted and/or otherwise directly
impacted by the portions of the proposed project.
5. Section 4.12.2.2.2 on page 4-117 states that "Wastewater system requirements from implementation of the Preferred Alternative
would increase measurably, but would not be adverse and there would be no significant effect ... and Harnett County has
adequate capacity available to meet the future wastewater treatment needs." However, the EA defines impact on the wastewater
system on page 4-1115, stating that "Impacts would be considered potentially significant if the proposed action or alternatives
would require more wastewater treatment capacity than could be reliably provided by the wastewater treatment system,
potentially leading to the discharge of effluents in excess of standards, or if regulatory limitations on the wastewater treatment
plant would potentially be exceeded." Since Hamett County must expand one of its treatment facilities to accept flows from
Bragg and Pope (see attached email from Harnett County's consulting engineer) and a collection system must be established to
transport these flows, it would seem that Section 4.12.2.2.2 would consider impacts to be significant. Please clarify.
Also, please consider changing the following statements:
¦ Section 4.15 on page 4-138 that there are "no significant impacts associated with the proposed action."
¦ Section 4.15 on page 4-141 that "The implementation of the Preferred Alternative would result in an increased use of utility
systems and services in the Cantonment areas and local communities; however, these impacts are not considered significant or
adverse impacts because each utility systems have the capacity to meet these increased demands; therefore no significant
mitigation measures are required."
¦ Table 5.1
o Page 5-3, Surface Water/Wetlands - that there will be no significant effect from the proposed project.
o Page 5-5, Wastewater System - that there will be no significant effect from the proposed project.