Public Comments for Public Notice File #NRS18.096, Proposed Bridge Replacement Project, Milepost 00N113.2, McKenzie, Carroll County, Tennessee
Meghan Ploch, Tennessee Department of Environment & Conservation, Division of Water Resources, Natural Resources Unit, William R. Snodgrass Tennessee Tower, 312 Santa Rosa L. Parks Avenue, 11th Floor, Nashville, Tennessee 37243
Dear Ms. Ploch:
Environmental Review, Inc. has reviewed the Public Notice and document for this project and has the following comments:
1) The Public Notice for this project is inadequate. Only the file number of the project is shown in the header of the public notice and a description of the project is absent from the header. Please reissue the Public Notice with a revised header including a descriptive title for example Proposed Bridge Replacement Project, Milepost 00N113.2, McKenzie, Carroll County, Tennessee .
2) The Aquatic Resources Alteration Permit Application cover letters’ Attachment 1 Form CN-1091 Section 8 presents the estimated sequence of construction activities however assessments for hazardous substances is absent. Please require assessments for hazardous substances associated with the treated wood railroad ties (heavy metals, and polynuclear aromatic hydrocarbons (PAHs), semivolatile organic compounds (SVOCs); lead associated with lead-based paint (LBP) if present, pesticides associated with vegetation control at the abutment locations; and PAHs in soils associated with the exhaust fumes from the locomotives at the abutment locations.
3) Section 8, estimated sequence of construction – this section should describe how the soils and/or sediments in the creek below the bridge will be tested for the same suite of hazardous substances including metals, PAHs, and SVOCs.
4) Section 8, estimated sequence of construction – this section should describe how, in the event that assessments for hazardous substances are found at levels which represent a concern for human health and the environment, soil, water, and sediment management plans will be prepared which describe the procedures for handling and disposal, and a worker health and safety plan.
5) Section 8, estimated sequence of construction – this section should include a plan which describes how the old railroad ties will be managed as treated wood waste.
Sincerely yours, Tom Price-Director, Environmental Review, Inc. 1792 Rogers Ave, San Jose, CA 95112, www.envreview.org