IMF Impacts on the Environment

Norfolk Southern is working with governmental agencies and the community to assess and minimize environmental impacts during construction and operation of the IMF.

Environmental Assessment

Norfolk Southern will have to complete the following permit/review processes prior to construction of the IMF:

Federal

• NEPA Review with a comprehensive Environmental Assessment.  This document will be available for public review before final permit approvals are given.
• Clean Water Act Section 10/404 Authorization
• Endangered Species Act Section 7 Consultation
• Clean Water Act/ Alabama Water Pollution Control Act NPDES Stormwater Permit for Industrial Activities
• Clean Water Act/ Alabama Water Pollution Control Act NPDES Permit for Construction Activity
• Clean Water Act/Alabama Water Pollution Control Act Stormwater Pollution Prevention Plan (SWPPP) and Erosion Control Plans
• NPDES Permit for Wastewater Discharge (if applicable)

State

• Clean Water Act Section 401 State Water Quality Certification
• Natural Heritage Inventory Listed Species Consultation
• U.S. EPA Clean Air Act Permit
• National Historic Preservation Act Section 106 Consultation

Biological Resources

The site is located in the headwaters of the Cahaba River.  NS has surveyed for protected species, including aquatic species such as mussels, and have found no threatened or endangered species on the site or within the area of impact. For aquatic species, in most areas, habitat did not seem to be conducive to supporting any threatened or endangered species.

Biological Resource Protection Measures include:

(1)   To the extent possible, avoidance of sensitive ecological areas and waterways;

(2)   Water quality protection measures (see below) will be employed to meet all state water quality criteria protective of biological resources and protected species;

(3)   Features such as bioswales are being considered for the IMF;

(4)   Additional studies are being conducted including aquatic habitat that may be affected by the project and the presence of protected aquatic species.

NS will be assessing additional opportunities for measures to address concerns regarding biological resources based upon community and governmental agency comment.

Wetlands and Water Resources

Wetlands are protected because of their ecological values.  Assessment of the site for waters and a complete assessment for wetlands that may be considered jurisdictional by the Corps of Engineers has been completed and location of potentially jurisdictional waters and wetlands has been identified. 

Wetland and Waterway Protection Measures include:    

(1)    Avoidance where possible and minimization for impacts to waters and wetlands;

(2)    Mitigation for  impacts that may occur, in accordance with Federal guidelines protecting waters and wetlands.

NS will be assessing additional opportunities for measures to address concerns regarding water and wetlands based upon community and governmental agency comment.

Water Quality

Water quality is important to protection of aquatic ecosystems.  Water quality is regulated under the Clean Water Act and Alabama Water Pollution Control Act. 

Water Quality Protective Measures include:

(1)   Avoidance of waterways where possible and minimization of waterway impact generally.  See Wetlands and Water Resources for mitigation and other protective measures;

(2)   During construction, installation of best management practices for control of runoff and sediment in accordance with the Federal Clean Water Act/Alabama Water Pollution Control Act NPDES permits.  These measures will include construction retention facilities, erosion control, outfall protection and armoring, and inspection and compliance measures. Discharges from the IMF will meet all conditions and limitations of NPDES permits;

(3)   IMF design will include waste and storm water management facilities such as retention or detention treatment facilities, oil/water separators, and other conditions and limitations in accordance with the Federal Clean Water Act/Alabama Water Pollution Control Act NPDES permits;

(4)    NS is considering use of innovative stormwater management such as vegetated systems or bioswales protective of area surface waters.

NS will be assessing additional opportunities for measures to address concerns regarding water quality based upon community and governmental agency comment.

Cultural, Archeological, and Historic Resources

A detailed assessment of potential occurrence of important cultural and related resources has been completed on the site. No cultural, archeological, or historically significant resources have been identified on the IMF site.  These results will be reviewed by the Alabama Historical Commission for their concurrence and included in the Environmental Assessment for public review.

Air Quality

Jefferson County is in a non-attainment area, meaning that the United States Environmental Protection Agency has identified the County as having violations of national air quality standards.  The IMF will not be permitted to interfere with attainment of these standards, which are established at levels that protect public health, including the health of “sensitive” populations such as asthmatics, children, and the elderly.

Air Quality Protective Measures include:

(1)   The IMF will use crane and hostler equipment that meet Tier 4 engine emissions requirements. Tier 4 engines have 45 to 90% lower emissions than the current generation engines that are in use today;

(2)   The IMF is expected to remove truck traffic from highways, reducing emissions associated with freight transportation;

(3)   NS is undertaking an analysis of air emissions that will be included in environmental documents.

Norfolk Southern will be assessing additional opportunities for measures to address concerns regarding air emissions based upon community and governmental agency comment.

IMF facilities have not been considered significant sources of emissions, and preliminary review of potential emissions indicates emissions will be very small and will not contribute to an exceedence of national air quality standard levels.  Norfolk Southern does not believe this facility will have an impact on air quality but understands community concerns and is performing an air quality study to review any potential impacts the IMF may have.