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20081579 Ver 1_More Info Received_20090313
DEPARTMENT OF THE ARMY US ARMY INSTALLATION MANAGEMENT COMMAND HEADQUARTERS, UNITED STATES ARMY GARRISON, FT BRAGG 2175 REILLY ROAD, STOP A FORT BRAGG, NORTH CAROLINA 28310-5000 REPLY TO ATTENTION OF March 13, 2009 Directorate of Public Works t)%- ISIR r= DD, MAR 1 3 2009 DENR - WATER QUALITY WETLANDS AND STORMWATER BRANCH Mr. Ian McMillan 401 Oversight/Express Review Permitting Unit 2321 Crabtree Boulevard Raleigh, North Carolina 27604 Dear Mr. McMillan: Enclosed are five copies of the additional information requested for Division of Water Quality Project Number #08-1579. This information request replies to the North Carolina Department of Environment and Natural Resources letter sent on February 25, 2009. If this information will suffice, please expedite the application process to impact protected streams and wetlands on the subject property. If you have any questions, please contact Mr. Erich Hoffman at (910) 432-4505 or erich.hoffman@us.army.mil. Sincer y, Gregory G. Bean Director of Public Works Enclosure xar aa+oc+ uann+ cwwu u.cwvr eue? °sYrwT M1Mll11il 91PPLY FOPIf CORPS OF Bge?D e ? e 107 87RF.AM NPACf NM e a i a I ° I _ \F` x - x 1 .1 II _ _ / b tl am- Z wrt ciao wnm wiarH usuur eoe? rsrv rwxntgx arv?x wxr mwt ac e+a?e awkaa omvnr DPADINO AND DRAINAf1E PLAN CULVERT W S 0 a Z rrnr ewm wmw riAar+A u. s.uurv eqr? omwcr awuma wnv rows NArs ar fl+amo A?? avvwxw remcr GRADING AND MANAGE PLAN CUWEftTiti v N Q A P m ? ? ( o Vl o 40 Mr, roar awoc aaani cwoiau uauvr enter csmcr w.arumox auvtr rota maro a ent?e - an+aauti osracr -Jill ?RADM(f AXD ORANN?sEPLAN CUIVERTM6 Ia ELEVATION IN FEET ABOVE USL Y Y S Y ------ --------------- - ---- 0 s g 8 + - ---------- ----- - - ----------- .-h L ------- --- -- 3i ELEVATION M FEET ABOVE MSL I ' +Q y I PoFf BIVLiO 1#gIN GIKKINA- U&YW( 8Yllegi p911tlf.T o ? OULVE"PROMLIM m i n ELEVATION IN FEET ABOVE MSL Y 'Fl Y ? q S Y ? y 8 n m Elm - ---- ------- --- ------- --- - --- ----- g g ELEVATION IN FEET ABOVE MSL $?1. .14 tiro ?n ? ?0 ca ;21 _ gig m m?v O m$ O O ELEVATION IN FEET ABOVE MSL Y Y S Y S 8 s R O? ------------ ELEVATION IN FEET ABOVE MSL O m ? ,> l In K Q\\ m ?. Z O RED ELEVATION IN FEET ABOVE MSL ELEVATION IN FEET ABOVE M& OFx 8 L" S w O $ 8 ? S S? o a Y Y i I I ? ? q S y S I o y S S p 8 pp 8 ELEVATION IN FEET ABOVE MSL C ' 2; I1 ELEVATION IN FEET ABOVE MSL NtR tttR ? O e S 8 - - -- --- ---- -- -- ------------- --------- - -- - ------ ------ Y ? E y C r v v ? g o S o ? N 8 ,I L N to ? 8 ?+ 2+ e a 8 8i 25 X y ? ELEVATION IN FEET ABOVE MSL 'i,. Q 'w eS ?w 8 m E S A? w ELEVATION IN FEET ABOVE MBL j A R Q w61 BOIa6 xon0' CNI/llN? USMIf 913?!®10MPoCf N?w+tl110M fiti0.Y Pob0 WIPS OF 8WMlY31 061175 CULVERT PROFRES a ELEVATION IN FEET ABOVE MSL Oo r.? w 6 w S Y g g C gY ;0 8 i i -? yy Ell 8 8 ELEVATION IN FEET ABOVE MSL ;? . U91 N? r g Ri Smni K ?Q x x a b^ ti .Pl?ll O ZLyi 3 Page 1 of 1 It- Subject RE: (UNCLASSIFIED) From "Klima, Danny J NWO" <Danny.J.Klima@usace.army.mil> Date Tuesday, March 10, 2009 17:55 To "Hoffman, Erich L Mr CfV USA IMCOM" <erich.hoffman@us.army.mil> Cc "Ott, Steven L NWO" <Steven.L.Ott@usace.army. mil> , lance.locklear@us.army.mil Erich, Attached is the revised map. As you can see, Area #1 and Area #4 are greater than 24% impervious. Area #4 actually doesn't drain into the wetlands, so I'm not sure if it is applicable. I will FedEx a full size drawing to Ian McMillan tomorrow morning. Thanks, Danny Klima, PE Omaha District U.S. Army Corps of Engineers --Original Message From: Hoffman, Erich L Mr CIV USA IMCOM [mailto:erich.hoffman@us.army.miQ Sent: Thursday, March 05, 2009 8:30 PM To: Klima, Danny J NWO Cc: Loddear, Lance A Mr CIV USA IMCOM Subject: (UNCLASSIFIED) Importance: High Classification: UNCLASSIFIED Caveats: NONE Dan, I talked with DWQ and the map you provided that depicts the 4 drainage areas with impervious surface square feet and pervious square feet needs to be determined just within the project site boundaries (e.g., construction Omits). Only account for the impervious surface area and pervious surface area within the project area. Then obtain a percentage of pervious surface are within the project area for each of the 4 drainage areas. The project boundaries must be dearly defined on the map. Please resend, thanks. Erich L. Hoffman, Senior Wildlife Biologist Directorate of Public Works Environmental Management Branch Fort Bragg, INC (910) 432-4505 (w) (910) 396-5830 (fax) "Don't think twice... say it on ICE!" http:Jtree.disa.mindex.cfm?fa=card&service?_provider id=81449&site id= 249 >Fort Bragg's Interactive Customer Evaluation Website Classification: UNCLASSIFIED Caveats: NONE el rI .1 ?1 ? U m 9 $ a ? ,.. ? ._ .?, Hama amore uws•n wrnvo wm ""'?` NOn?""wmae uia W gig. aiv. 4' EM EM I f `n I t ?? • t L 42 FINAL FINDING OF NO SIGNIFICANT IMPACT GROW THE ARMY ACTIONS AT FORT BRAGG, NORTH CAROLINA On 12 October, 1999, the Secretary of the Army and the Chief of Staff proposed a new initiative to help ensure that the Army would remain an effective and relevant operational force in the 21" Century. The national security threats that the United States currently face are different from those confronted in the Cold War Era, and the Transformation of the Army initiative was intended to address these unconventional modern-day threats. The Army has completed the first I phases of this 30-year Transformation initiative and will continue to move toward a full-spectrum force that is best suited to meet the strategic security and defense needs of the changing 21" Century world. The U.S. Army Corps of Engineers, Mobile District, has prepared an Environmental Assessment (EA) which identifies, documents, and evaluates the environmental effects of the Army growth and restructuring actions at Fort Bragg. The EA has been developed in accordance with the National Environmental Policy Act of 1969 (42 U.S.C. 4321 et seq.) and implementing regulations issued by the President's Council on Environmental Quality (CEQ)' and Environmental Analysis of Army Actions, 32 CFR Part 651. The purpose of the EA is to inform decision makers and the public of the likely environmental consequences of the proposed action and alternatives. 1.0 PROPOSED ACTION Fort Bragg is one of several installations being considered to receive units and facilities as part of GTA. The Combat Support (CS) and Combat Service Support (CSS) units proposed at Fort Bragg would include conversion of the 1st Theater Sustainment Command to an Active Component unit; two Air Defense Artillery (ADA) Batteries; one Sustainment Brigade; one Explosive Ordnance Disposal Battalion with four Companies; one Military Intelligence Battalion; and other CSS units. As part of the Preferred Alternative for this proposed action, Fort Bragg would relocate its Ammunition Supply Point (ASP) and use the land at its existing ASP to provide space for future construction to support new growth at the installation, including facilities to accommodate the incoming 108th ADA Brigade. In order to accommodate these units and their missions, Fort Bragg's Preferred Alternative would decommission and relocate the existing ASP and construct facilities on the existing ASP site to house the incoming and growing units. This would accomplish several objectives, since buildable land on the installation is in short supply. Existing bunkers at the Fort Bragg ASP are in need of modernization and replacement, and encroaching development at the ASP perimeter, particularly the proposed 1-295 spur to the east, makes movement of the ASP highly desirable for reasons of safety and security. The proposed action at Fort Bragg would necessitate the construction of new facilities; the projects proposed to accommodate and support the GTA action are as follows: Project Number (PN) 67107 Brigade HQ Complex (EAB - 10811 ADA). Under PN 67107, the existing ASP would be decommissioned and relocated. The 108" ADA would then be relocated to the ASP site on Fort Bragg. The proposed project would include the construction of a 227,800 square foot (sf) Company Operations Building, a 164,500 sf Vehicle Maintenance Shop (VMS), a 15,400 sf Brigade Headquarters Building, a 36,400 sf Battalion Headquarters Building, 25,900 sf of Deployment Equipment Storage and a 13,800 sf Organizational Classroom. An additional 96,100 sf of supporting facilities at the relocated ASP would be required, including a surveillance workshop, material handling equipment building, guard building, inspection building, inert storage building, and an oil storage building. Privately-Owned Vehicle (POV) and additional paving requirements would equal 147,000 square yards (sy) of paving. I Council on Environmental Quality Regulations for Implementing the Procedural Provisions of the National Environmental Policy Act, .0 CFR Parts 1500--1508. PN 68773 Training Support Center. The facilities associated with this project include a 118,700 sf Training Support Center, including 34,200 sf of Training Aids Center/Admin space and 84,500 sf of General Purpose Storage., and a 4;000 st'Storage, Shed. PN 68798 Notional Barracks Complex. PN 68798 would require construction a barracks complex for the 108`h ADA at the current ASP on Fort Bragg. This facility would include a 399.000 sf Barracks Complex for enlisted unaccompanied personnel. The complex would also include 19.100 sy of Non-Organizational Parking and road improvements. PN 68818 Unit Operation and Maintenance Facility. PN 68818 would expand the ASP once it is relocated. The facility would include q 150,800 sf VMS, 26,500 sf of Deployment Equipment Storage, a 2,500 sf Oil Storage Building, and 161,200 sy of Organizational Vehicle Parking as well as an ASP. PN 68921 Unit Operation Facilities, Construction associated with PN 68921 would provide additional facilities for the 108"' ALA at Fort Bragg's existin' q ASP location. The primary buildings for the project would include 194,000 sf ofC;ompatrv Operations Facilities, a 33,600 sf Battalion Headquarters, and a 55,200 sf Brigade Headquarters. POV parking and Petroleum, Oil, and Lubricant (POL) Trick Company would be provided. PN 69353 Medical Clinic and ADWALT Dental Clinic. "This project would construct a new building to provide supplemental administrative space for offices and functions currently located within the hospital, in order to allow a medical and dental facility to be placed in the hospital proper. Once these functions are relocated to the new administrative offices, which would occupy approximately 69,700 sf adjacent to the existing hospital, the vacated space clinic space within the hospital would be filled with a medical clinic and a dental clinic; 60,000 sf of POV parking would be provided. 2.0 ALTERNATIVES CONSIDERED CEQ regulations require inclusion of the No Action Alternative. The No Action Alternative serves as a baseline against which the impacts of the proposed action and alternatives can be evaluated. Under the No Action Alternative, Fort Bragg would not implement the proposed action. Organizations presently assigned to Fort Bragg would continue to train at and operate from the post. No units would relocate frorn overseas locations. No new units would be established. Fort Bragg would use its current inventory of facilities. though routine replacement or renovations actions could occur, through normal military maintenance and construction procedures, as circumstances independently warrant. The No Action Alternative is evaluated in detail in this EA to provide the baseline prescribed by CEQ regulations. The U.S. Army considered and analyzed one other alternative, the "Preferred" Alternative. Under the Preferred Alternative, Fort Bragg would utilize the existing ASP at Pope Air Force Base (AFB) to accommodate components of the existing Fort Bragg ASP. Real property accountability at Pope AFB will transfer to the Army at Fort Bragg as part of BRAC. The construction of new ammunition storage bunkers at the Pope AFB ASP is the Army's Preferred Alternative for the location of the new Fort Bragg ASP. The Preferred Alternative would be implemented through the decommissioning of the existing ASP at Fort Bragg, which is outdated and being encroached upon by development. Once the ASP is decommissioned, its supplies and equipment would be moved up to new facilities at Pope AFB, once they are completed, Once movement of the ASP is complete, new construction would then take place at the Fort Bragg ASP site to accommodate incoming or expanding units at Fort Bragg under the proposed action. Other alternatives were considered, but not analyzed in the EA. These included (1) use of existing facilities at Fort Bragg, (2) acquisition of new property; and (3) leasing existing space off-base. These other alternatives were considered not feasible to implement the proposed action and ? ere therefore dismissed from further analysis. ENVIRONMENTAL ASSESSMENT GROW THE ARM FORT BRAGG, NC Prepared 4: CHRISTIE LOWREY NEPA Analyst Date: ©? Proponent: eREGORY G. BEAN Director of Public Works Environmental Review: F IS:AVID A. HEINS Chief, Environmental Division Date: LC- 'ae Legal Review: GARY LOXLEY COL, JA Acting Staff Judge Advocate d -) I Date: /V ? D"?y Date: /4' of ,4ploval: DAVID G. FOX Colonel, Special Forces Garrison Commander mss' Date: 7d v5s„+- Bragg concurred with and includes the appropriate corrections and wording. All DWQ comments, including those not accepted by Fort Bragg, are listed with the applicable Fort Bragg responses on the comment/response form. None of the comments made by DWQ would warrant a mitigated FNSI. Following the public review period, this final FNSI was prepared; signed by the Garrison Commander of Fort Bragg, and released to the appropriate local, state, and federal repositories. 5.0 CONCLUSION Based on the EA, it nas been determined that inplen ientation o the proposed action will have no significant direct, indirect, or cumulative adverse effects on the quality of the natural or human environment. Because no significant environmental impacts will result from implementation of the proposed action, an Environmental Impact Statement is not required and will not be prepared. Date:CV406,9T David G. Fox COL, SF Garrison Commander r. ENVIRONMENTAL ASSESSMENT GROW THE ARMY FORT BRAOO, NC Prepared by. CHRISTIE LOWREY NEPA Analyst Date: -7- 'P, " d ? Proponent. ZREGORY G. BEAN Director of Public Works d "' `??? Date: Al ? Envirownentai Review: i r .I? l f. DAVID A. HE INS Chief, Environmental Division Date: /& ow, Legal Review. 9 GARY .LOXLEY COL, JA Acting Staff Judge Advocate Date: /4" 1)'f AM ovaf: i DAVID G. FOX Colonel, Special Forces Garrison Commander Date: z7 ?.a„a, tea' ©, * A rj? Michael F. Easley, Governor ©? QG William G. Ross Jr., Secretary r North Carolina Department of Environment and Natural Resources > --I Coleen I3. Sullins, Director Q `C Division of Water Quality July 18, 2008 MEMORANDUM TO: Melba McGee, Environmental Projects Officer DENR THRU: Dianne Reid, Supervisor Basinwide Planning Unit and SEPA Program 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 The Division of Water Quality has reviewed the subject project and has the following comments and concerns: 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 Barnett County system Please clarify. b. DWQ recommends that the adequacy of the drinking water projects be verified as well. c. 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 4.6.12, 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. d: DWQ recommends that Ft. Bragg closely cooperate efforts with Harriett County (and others, such as Fayetteville PWC) in the development of the infrastructure needed to provide for the increase in personnel- 2. DWQ recommends that the Army use pervious pavement in the extensive road system associated with the proposed developments. 3. Page ES-5, Section ES.5: Please correct that there are 5 criteria listed for screening project alternatives. 4. Page ES-7, Table ES.3, Surface Water/Wetlands a. Need to change rating of resource impact based on comment 10, below. b. Need to list wastewater effluent and drinking water impacts. 5. Page ES-9, Table ES.3, Utilities - Change this based on comments 4.a. and 10. 6. Please update the listing of water classifications on page 4-39, as necessary, based on the May 2007 Redbook Ott ://h2o enr state nc usiadminlrulesidocuments/redbook 1rnay07 full with cover.pffi. Nn` CarC31iI53 North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phoae (919) 733-7015 (919) 733-2496 f Customer Service I-977-623-6748 Internet: www ncwateraaality ore Location. 512 N. Salisbury St. Raleigh, NC 27644 ax An Equal oppodunitylAlBrmaM Action Employer - 50% RecydW 0% Post Cotimm Paper 7. Please confirm that the. citations for impaired waters on pages 4-39 and 4-44 are based on the Draft 2008 303(4) List (hq2 //h2o enr state nc usltmdl/documents/B.Draft2Q083Q3dList.udf). Also, please ensure that the project does not impact the 300-foot buffer of these areas cited on page 4-43. 8. Page 4-42: The third and fourth sentences of the second paragraph contradict one another. Please clarify whether any storm water enters the sanitary sewer system. 9. 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. 10. 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 Harnett 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/Wedands - 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. 11. Please clarify why increased energy demands and HVAC systems are discussed under the Stormwater System heading in section 4.12.2.2.3. Please contact me at 733-5483, ext. 555, if I can be of any additional help. Thank you. Cc: Danny Smith - RRO Belinda Henson -- FRO Appendix J.2 COMMENTIRESPONSE FORM - ENVIRONMENTAL ASSESSMENT GROW THE ARMY ACTIONS AT FORT BRAGG, NORTH CAROLINA The Division of Water Quality (DWQ) has reviewed the subject project and has the following comments and concerns: 1. DWQ Comment - 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 doomnents 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 Fort k3ragg Response -The GTA EA primarily accesses impacts from the GTA actions and personnel increases (2,195). The purpose of the GTA EA is only to address related actions and not Harnett County's actions, future projects or capabilities beyond any relationship to this Grow the Army analysis. Additional analysis of Harnett County activities is beyond the scope of this EA. 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. Fort Bragg Response - The Fat does not state that Harnett. County is "currently" capable of handling the increases in personnel from the GTA actions. In fact, Harnett County's capability is not even mentioned in 4.111.2. The EA analysis was based on a planned project to construct a water treatment plant to service the water needs of Harnett County which will have adequate rapacity to support Fort Bragg following the watedwastewater privatization. The Harnett County construction is proposed regardless of the GTA projected personnel increases. The Harnett County Wastewater project being analyzed in the EA that DWQ mentioned in the comment provides gees( detail on the capability of Hamett County utilities to absorh all foreseeable personnel loads. Not only will the restructuring of water and wastewater treatment in the area more than meet the post-GTA needs of Fort Bragg, but should greatly improve overall water quantity and quality in the region. Fort Bragg will no longer draw water fiom the Lower Little River and its effluent will be treated in the most modem plant in the region. b. DWQ recommends that the adequacy of the drinking water projects be verified as well. Fort Bragg Response - The EA, at 4.12.1.1, demonstrates adequate driuldng water capacity. c. DWQ cannot adequately comment on the impacts associated with the "Associated needs and infastructure 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 (soil), 4.14.4.6 (water), and 4.15 (mitigation) be amended to include the effects of installing the necessary water; wastewater, and other such infrastructure to support Bragg's growth. Fort Bragg Response - Analysis of these media is included as part of the project and concluded that as long as applicable Fort Bragg, state and federal permit requirements/regulations are met, there will be no negative impacts. d. DWQ recommends that Ft. Bragg closely cooperate efforts with Harnett County (and others, such as Fayetteville PWC) in the development of the infirastructure needed to provide for the increase in personnel. Fort Bragg Response - Brenda Audetxe, UP Contracting Officers Representative, has monthly meetings with Harnett County/PWC who will be maintaining their water/wastewater lines on/off-post. Fort Bragg currently pays ONUS to maintain Fort Bragg's watedwastewater infrastructure (failing and new) to state and federal standards and contract quality assurance processes ensure that ONUS complies with applicable laws and regulations. 2. DWQ Comment - DWQ recommends that the Army use pervious pavement in the extensive road system associated with the proposed developments. Fort Bragg Response - DWQ recommendations will be considered as the projects are developed and we will try to meet sustainability goals. 3. DWQ COMMENT - Page ES-S, Section ES.5: Please correct that there are S criteria listed for screening project alternatives. Fort Bragg Response - Concur. Correction will be noted on the Farata Sheet included in Appendix j. 4. DWQ Comment - Page ES-7, Table ES.3, Surface Water/Wetlands a. Need to change rating of resource impact based on comment 10, below. Fort Bragg Response - Do not concern' with DWQ opinion that there would be significant impacts due to the increase in water needs or wastewater treatment loads, based on Harnett County and PWC's commitments to Fort Bragg. No changes in analysis or conclusion are necessary on this subject. b. Need to list wastewater effluent and drinking water impacts. Fort Bragg Response - We do not see an impact as we stated in 4.a, above. 5. DWQ Comment - Page ES-9, Table ES.3, Utilities - Change this based on comments 4.a. and 10. Fort Bragg Response - Fort Bragg does not see the impacts projected by the State as stated in 4.9-, above. As concluded in the Draft EA, no changes to the final FNSI are necessary. 6. DWQ Comment - Please update the listing of water classifications on page 4-39, as necessary, based on the May 2007 Redbook (httyIlh2o enr state nc gs/admin/rules/documents/redbook Imav07 full with cover.ndf) Fort Bragg Response - Concur. Correction will be noted on the Errata Sheet included in Appendix J. 7. DWQ Comment - Please confirm that the citations for impaired waters on pages 4-39 and 4-40 are based on the Draft 2008 303(d) List (httn•//h2o enrstate nc us/tmdVdocuments/B Draft2008303dDst.ndf). Also, please ensure that the project does not impact the 300-foot buffer of these areas cited on page 4-43. Fort Bragg Response - Source verified and citations are correct as stated in the EA. 8 DWQ Comment - Page 4-42: The third and fourth sentences of the second paragraph contradict one another. Please clarify whether any storm water enters the sanitary sewer system. Fort Bragg Response - According to Herman Crawford, Stormwater/Oil Water Separator Program Manager, the referenced sentences regarding the storm drain system: "is designed to be completely separate from the sanitary sewer system. Stormwater exposed to possible contamination at equipment maintenance shops is routed through grit chambers and oil/water separators prior to discharge to sanitary sewers." is incorrect because not all storm water in a vehicle maintenance facility is routed thru a grit chamber and separator. The majority of it flows into storm inlets which flow to ditches, creeks, streams. Only water used to wash vehicles and/or equipment or triple rinse POL cans is routed thru grit chambers/separators. This water then goes to the sanitary sewer system. This paragraph will be revised per the above comments and will be included in the Errata Sheet in Appendix J.. 9. DWQ Comment - Page 4-6 1, 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. Fort Bragg Response - Per Erich Hoffman, Natural Biologist, the impact wetland acreage for the GTA projects will be quantified and qualified through the permitting process by the USACE - Wilmington District. 10. DWQ Comment - 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 Harnett 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. Fort Bragg Response - Do not concur with DWQ opinion that there would be significant impacts due to the increase in water needs or wastewater treatment loads. Fort Bragg's conclusions are based in the fact that by the occupancy date of the first proposed GTA project, Harnett County will have constructed a wastewater treatment plant to handle current and future needs (for foreseeable growth). This undertaking is independent of the personnel increases analyzed in this EA. Due to increased technologies with the new plant and proposed water sustainability measures, the increase in personnel from the GTA actions should not increase the water demands or wastewater loads beyond the limits of the new plant capabilities (or NPDES permit limits). Through a redundancy of efforts, Harnett County and PWC will each provide 8 MGD flow to Fort Bragg, for a total of 16 MGD which far exceeds the current need or any possible expected need given a projected increase of only 2,195 personnel; into a current soldier population exceeding 43,000 personnel (5.2% increase). Based on an average usage standard of 92 gallons per person per year, the additional personnel increase from the GTA actions would result in an additional 202,000 gallon load in excesses of current treatment levels. Additionally, BRAC actions will reduce number of personnel at Pope AFB from approximately 6,600 to 2,710 (59% decrease). Pope AFB currently utilizes Fort Bragg's water supply and wastewater treatment plant. Since Fort Bragg's current plant treats approx 6 MGD with capabilities of 20 MGD, the combined efforts of Harnett County and PWC will be more than adequate to handle the water/wastewater needs of Fort Bragg. No changes in analysis conclusion will be made. As concluded in the Draft EA, no changes to the final FNSI will be made. 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." Fort Bragg Response - We continue to believe that there will be no significant impacts associated with GTA. No changes to the final FNSI are necessary in light of the unchanged conclusions reached by the EA. • 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." Fort Bragg Response.- The "wet" utility systems will have more than enough capacity to serve the needs of the GTA personnel increases by the time the first GTA personnel begin to be stationed at Fort Bragg. No changes to the final FNSI are necessary.. • Table 5.1 • Page 5-3, Surface Water/Wetlands - that there will be no significant effect from the proposed project: Fort Bragg Respnaee - No impacts because there is no new information that indicates a need to change the Fort Bragg impact conclusion (see above). Page 5-5, Wastewater System - that there will be no significant effect from the proposed project. Fort Bragg Response - No impacts because there is no new information that indicates a need to change the Fort Bragg impact conclusion (see above). 11. DWQ Comment - Please clarify why increased energy demands and HVAC systems are discussed under the Stormwater System heading in section 4.12.2.2.3. Fort Bragg Response - Section reviewed Correction will be noted on the Errata Sheer included in Appendix