20181638 Ver 3_More Information Received_20200323

SYnF.
Staff Review
Does this application have all the attachments needed to accept it into the review process?
(-- Yes C No
ID#* Version*
20181638
Is this project a public transportation project?* C Yes
r No
Reviewer List:* Sue Homewood:eads\slhomewood
Select Reviewing Office:* Winston-Salem Regional Office - [phone]
Does this project require a request for payment to be sent?*
C
Yes
No

Project Submittal Form
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mandatory questions are answered.
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Project Contact Information
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Project Information
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20181638 3
20170001(no dashes)
Project Name: MVP Southgate Project
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r No
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County (ies)
Alamance
Rockingham
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March 2020 401 Addendum Cover Letter - Final.pdf 200.93KB
Updated NC_JPA Final 3.23.20.pdf 1.32MB
Only pdf or krre files are accepted.
Describe the attachments:
Cover letter & Joint 401/404 Permit Application Addendum. Updated tables and map sets to be submitted in
April of 2020.
Sign and Submit
V By checking the box and signing box below, I certify that:
• I have given true, accurate, and complete information on this form;
• I agree that submission of this form is a "transaction" subject to Chapter 66, Article 40 of the NC General Statutes (the
"Uniform Electronic Transactions Act")
• I agree to conduct this transaction by electronic means pursuant to Chapter 66, Article 40 of the NC General Statutes
(the "Uniform Electronic Transactions Act');
o I understand that an electronic signature has the same legal effect and can be enforced in the same way as a written
signature; AND
• I intend to electronically sign and submit the online form."
Signature:
Submittal Date: Is filled in automatically.

MVP
SOUTHGATE
March 23, 2020
625 Liberty Avenue, Suite 1700 Pittsburgh, PA 15222
833-MV-SOUTH I [e-mail]
www.mvpsouthgate.com
Mr. David Bailey
United States Army Corps of Engineers -Wilmington District
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
SAW-2018-00887
Ms. Sue Homewood
North Carolina Department of Environmental Quality
Division of Water Resources
401 & Buffer Permitting Unit, Wetlands Branch
450 W. Hanes Mill Rd, Suite 300
Winston Salem, North Carolina 27105
RE: MVP Southgate Project, Rockingham and Alamance Counties, North Carolina
Addendum to Pre -Construction Notification for Nationwide Permit 12 (SAW-2018-00887)
Addendum to Application for Individual 401 Water Quality Certification; Authorization for
Buffer Impacts in Jordan Lake Watershed (DWR# 20181638)
Dear Mr. Bailey and Ms. Homewood:
Mountain Valley Pipeline, LLC ("Mountain Valley") is providing the enclosed Addendum to the Joint
Permit Application ("JPA") for the MVP Southgate Project ("Project"). The purpose of this Addendum
is to reflect updated construction methods that comply with the Jordan Lake Watershed rules without the
need for a Major Variance.
Mountain Valley is proposing to construct and operate the Project to provide timely, cost-effective access
to new natural gas supplies to meet the growing needs of natural gas users in the southeastern United
States. On February 14, 2020, Mountain Valley received the Final Environmental Impact Statement
(FEIS) from the Federal Energy Regulatory Commission (FERC), which reflected modifications that
were incorporated into the project based on the Draft Final Environmental Impact Statement (DEIS, July
2019), FERC reviews, and stakeholder / agency comments. Mountain Valley is now providing this
addendum to the JPA, which reflects those changes as well as additional impact minimization measures
designed to reduce Project -related effects on wetland, waterbody, and riparian buffers.
This addendum includes updated narrative information, with changes from the prior JPA highlighted in
grey throughout the text to simplify your review. Updated wetland, waterbody, and Jordan Lake buffer
impact tables will be submitted in April 2020 along with updated drawing sets.
Because these design modifications enable the project to fully comply with the Jordan Lake Watershed
rules, the Project formally withdrew the Major Variance application for Jordan Lake Watershed non-

perpendicular crossings on March 13, 2020. This Addendum reflects those changes along with the other
workspace and impact changes previously described.
Mountain Valley appreciates the opportunity to provide this information in support of its original request
for the Joint USACE Section 404/NCDEQ Section 401 authorization of the Project pursuant to
Nationwide Permit 12 dated November 30, 2018 and subsequent re -application on August 9, 2019. We
would like to propose a meeting with each of you by teleconference once you have had a chance to
review the information to facilitate addressing any questions or comments you may have on this
addendum. We will reach out to you next week to determine your timing preference for the meeting. In
the meantime, should you have any additional questions or require further information, please do not
hesitate to contact Alex Miller at 713-374-1599 or via email at alex.miller@nexteraenerg, .c�or reach
out to me at 561-691-7054 or via email at kathy.salvadorknexteraenergy.com. We look forward to
continuing to work with you on this project. Thank you for your continued consideration.
Sincerely,
Mountain Valley Pipeline, LLC
Kathy Salvador
Senior Director, Environmental Services
Attachments
CC: Todd Miller, Corps, NAO Travis Faul, MVP
Cory Chalmers, MVP
John Zimmer, TRC
Heather Patti, TRC
M MVP
SOUTHGATE

ICI Mountain Valley
MVP Southgate Project
Pre -Construction Notification —
Joint Permit Application Addendum
U.S. Army Corps of Engineers —
Wilmington District (SAW-2018-00887)
North Carolina Department of
Environmental Quality,
Division of Water Resources
(2018-1638)
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TABLE OF CONTENTS
1.0
INTRODUCTION........................................................................................................................1-1
1.1
SCOPE OF THE JOINT PERMIT APPLICATION.......................................................1-2
2.0
PROJECT
DESCRIPTION...........................................................................................................2-1
2.1
PURPOSE AND NEED...................................................................................................2-1
2.1.1 Pipeline Facilities................................................................................................2-4
2.1.2 Additional Temporary Workspace......................................................................2-5
2.1.3 Access Roads......................................................................................................2-5
2.1.4 Aboveground Facilities.......................................................................................2-6
2.1.4.1 Meter Stations.....................................................................................2-6
2.1.4.2 Mainline Valves..................................................................................2-7
2.1.4.3 Pig Launchers and Receivers..............................................................2-7
2.2
CONSTRUCTION...........................................................................................................2-8
2.2.1 General Practices................................................................................................2-8
2.2.2 Typical Upland Pipeline Construction Procedures.............................................2-8
2.2.3 Typical Wetland Pipeline Construction............................................................2-12
2.2.4 Typical Waterbody Crossings...........................................................................2-14
2.2.5 Aboveground Facilities.....................................................................................2-25
2.2.6 Access Roads....................................................................................................2-25
2.3
RESTORATION............................................................................................................2-25
2.3.1 Pipeline.............................................................................................................2-26
2.3.1.1 Uplands.............................................................................................2-26
2.3.1.2 Wetlands............................................................................................2-26
2.3.1.3 Waterbodies.......................................................................................2-27
2.3.2 Access Roads....................................................................................................2-27
2.3.3 Aboveground Facilities.....................................................................................2-27
2.3.4 Contractor Yards...............................................................................................2-28
2.4
QUALITY ASSURANCE MEASURES.......................................................................2-28
2.5
SCHEDULE...................................................................................................................2-29
2.6
OPERATION AND MAINTENANCE.........................................................................2-29
2.7
FUTURE PLANS AND ABANDONMENT................................................................2-30
2.8
ROUTE ALTERNATIVES ANALYSIS......................................................................2-30
3.0
EXISTING
SITE CONDITIONS.................................................................................................3-1
3.1
WETLAND AND WATERBODY DELINEATION......................................................3-1
3.1.1 Wetlands.............................................................................................................3-1
3.1.2 Waterbodies........................................................................................................3-1
3.1.3 Preliminary Jurisdictional Determination...........................................................3-2
4.0
WETLAND
AND WATERBODY IMPACT ASSESSMENT....................................................4-1
4.1
WETLAND IMPACTS...................................................................................................4-1
4.1.1 Temporary Construction Impacts.......................................................................4-1
4.1.2 Permanent Conversion of Forested Wetlands to Non -forested Wetlands ...........
4-1
4.1.2.1 Permanent Fill for Access Road..........................................................4-2
4.2
WATERBODY IMPACTS..............................................................................................4-2
4.2.1 Temporary Construction Impacts.......................................................................4-2
4.2.2 Permanent Impacts..............................................................................................4-2
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4.3
RIPARIAN BUFFER IMPACTS....................................................................................4-2
4.3.1.1 Diffuse Flow Requirement..................................................................4-3
4.3.1.2 No Practicable Alternatives.................................................................4-4
4.3.1.3 Compliance with Performance Standards...........................................4-4
4.3.1.4 Impact Mitigation................................................................................4-7
4.4
IMPACT AVOIDANCE AND MINIMIZATION MEASURES....................................4-7
4.4.1 Stormwater Management and Diffuse Flow Plan .............................................4-10
4.4.1.1 Stormwater Management Plan ..........................................................4-10
4.4.1.2 Certified Local Government Stormwater Review.............................4-10
5.0 ADDITIONAL
SUPPORTING INFORMATION.......................................................................5-1
5.1
ENVIRONMENTAL DOCUMENTATION...................................................................5-1
5.2
VIOLATIONS.................................................................................................................5-1
5.3
CUMULATIVE IMPACTS.............................................................................................5-1
5.4
SEWAGE DISPOSAL...................................................................................................5-14
5.5
ENDANGERED SPECIES AND DESIGNATED CRITICAL HABITAT..................5-14
5.5.1 Consultation......................................................................................................5-14
5.5.2 Findings............................................................................................................5-15
5.5.3 Wildlife Species................................................................................................5-15
5.5.4 Aquatic Species................................................................................................5-16
5.5.5 Plant Species.....................................................................................................5-17
5.5.6 Conclusions.......................................................................................................5-18
5.6
ESSENTIAL FISH HABITAT......................................................................................5-18
5.7
CULTURAL RESOURCES INFORMATION.............................................................5-18
5.8
FLOOD ZONE DESIGNATION..................................................................................5-18
6.0 REFERENCES.............................................................................................................................6-1
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LIST OF FIGURES
Figure 1. Southgate Project Overview Map...............................................................................................1-3
Figure 2. Typical Pipeline Construction Sequence....................................................................................2-9
Figure 3. Dam and Pump Crossing Method Typical...............................................................................2-16
Figure 4. Flume Crossing Method Typical..............................................................................................2-17
Figure 5. Cofferdam Crossing Typical....................................................................................................2-19
Figure 6. Conventional Bore Typical......................................................................................................2-21
Figure 7. Horizontal Directional Drill Typical........................................................................................
2-24
LIST OF TABLES
Table 2-1 Major Regions, 8-digit HUC and 10-digit HUCs crossed by the Project ........................2-3
Table 2-3 Southgate Project Contractor Yards in North Carolina...................................................2-6
Table 2-4 Southgate Project Mainline Valve and Meter Station (Interconnect) Locations .............2-7
Table 2-5 Construction Schedule for Major Components of the MVP Southgate Project.............2-29
Table 5-1 Projects with Potential Cumulative Impacts....................................................................5-4
Table 5-2 100-Year Floodplain areas crossed................................................................................5-19
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LIST OF APPENDICES
Appendix A
North Carolina USGS 7.5-Minute Topographic Map Excerpts
Appendix B
North Carolina Alignment Sheets
Appendix C
Typical Construction Detail Drawings
Appendix D
FERC Upland Erosion Control, Revegetation, and Maintenance Plan
Appendix E
MVP Southgate Wetland and Waterbody Construction and Mitigation Procedures
Appendix F
Spill Prevention and Countermeasure Control Plan
Appendix G
Wetland and Waterbody Crossing Analysis
Appendix H
HDD Site Specific Crossing Plans
Appendix I
HDD Contingency Plan
Appendix J
FERC Final Environmental Impact Statement
Appendix K
North Carolina Wetland and Waterbody Delineation Report
Appendix L-1
Proposed Wetland Impacts by ID and Impact Type
Appendix L-2
Proposed Waterbody Impacts by ID and Impact Type
Appendix M
North Carolina Proposed Impact Drawings
Appendix N
Compliance Statement for NWP 12 Terms and Conditions
Appendix O
Water Resources Identification and Testing Plan
Appendix P
Unanticipated Cultural Resources Discoveries Plan
Appendix Q
FEMA Flood Zone Maps
Appendix R
MVP Southgate General Blasting Plan — March 2019
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LIST OF ACRONYMS AND ABBREVIATIONS
API
American Petroleum Institute
ATWS
Additional temporary construction workspace
BA
Biological Assessment
BMPs
best management practices
CEQ
Council on Environmental Quality
Certificate
Certificate of Public Convenience and Necessity
CFR
Code of Federal Regulations
Corps
US Army Corps of Engineers or USACE
DENC
Dominion Energy North Carolina
DOE
US Department of Energy
East Tennessee
East Tennessee Natural Gas, LLC
ECD
Erosion Control Device
EI
Environmental Inspector
E&SCP
Erosion and Sediment Control Plan
FERC or Commission
Federal Energy Regulatory Commission
EFH
Essential Fish Habitat
EFSO
Ecological Field Services Office
EPA
Environmental Protection Agency
ESI
Environmental Services Inc.
FEMA
Federal Emergency Management Agency
FWS
Fish and Wildlife Service
HDD
Horizontal Directional Drill
HDD Plan
Horizontal Directional Drill Fluid Monitoring, Operations, and
Contingency Plan
hp
horsepower
HUC
Hydrologic Unit Code
IPaC System
Information Planning and Conservation System
MLV
mainline valve
MP
milepost
NCDEMLR
North Carolina Department of Energy, Mineral and Land Resources
NCDEQ
North Carolina Department of Environmental Quality
NCDWR
North Carolina Department of Water Resources
NGO
non -governmental organization
NHD
National Hydrography Dataset
NHI
National Heritage Inventory
NMFS
National Marine Fisheries Service
NOAA
National Oceanic and Atmospheric Administration
NWI
National Wetland Inventory
NWP
Nationwide Permit
PCN
Pre -Construction Notification
Plan
Southgate Upland Erosion Control, Revegetation, and Maintenance Plan
Procedures
Southgate Wetland and Waterbody Construction and Mitigation
Procedures
Project
MVP Southgate Project
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psig
pounds per square inch gauge
PSNC Energy
PSNC Energy, a wholly owned subsidiary of SCANA Corporation
LR
Re -Route
SPCC Plan
Spill Prevention, Control, and Countermeasures Plan
The Project
Mountain Valley Pipeline, LLC
Transco
Transcontinental Gas Pipe Line Company, LLC
U.S.
United States
USACE
U.S. Army Corps of Engineers
USDOT
United States Department of Transportation
USFWS
United States Fish and Wildlife Service
USGS
United States Geological Survey
WQC
Water Quality Certification
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1.0 INTRODUCTION
Mountain Valley Pipeline, LLC ("Mountain Valley") is proposing to construct and operate the MVP
Southgate Project ("Southgate Project" or "Project"). The Southgate Project will provide timely, cost-
effective access to new natural gas supplies to meet the growing needs of natural gas users in the
southeastern United States ("U.S."). The Project is expected to be in service by late 2020 and is a separate
project from the 303-mile Mountain Valley Pipeline that is currently under construction.
The Southgate Project includes an approximately 0.5-mile-long 24-inch-diameter pipeline (H-605), 74.6
miles of 24- and 16-inch-diameter natural gas pipeline (H-650), a new 28,915 nominal horsepower ("lip")
compressor station (Lambert Compressor Station), meter stations and other ancillary facilities (e.g.
contractor yards and access roads) required for the safe and reliable operation of the pipeline. The
Southgate Project facilities will be located in Pittsylvania County, Virginia and Rockingham, Guilford,
Caswell and Alamance counties, North Carolina. A location map (Figure 1) illustrates the proposed
Project facilities.
The Project is regulated by the Federal Energy Regulatory Commission ("FERC" or "Commission")
pursuant to Section 7(c) of the Natural Gas Act and requires a Certificate of Public Convenience and
Necessity ("Certificate") to construct and operate. The FERC will conduct a full review of the Project under
its regulations in compliance with the Natural Gas Act ("NGA") and the National Environmental Policy
Act. On May 3, 2018, the Project requested approval from the FERC to initiate the Pre -filing review process
for the Project, and the FERC issued its approval of the request on May 15, 2018, under Docket No. PF18-
4-000. The Pre -filing review process allows for active participation by interested stakeholders early in
Project development while maintaining a coordinated schedule and helps to ensure the timely review and
determination on the Certificate application. The Project filed an application with the Commission for a
Certificate to construct, install, own, operate, and maintain the Southgate Project on November 6th, 2018
(FERC Docket No. CP19-14-000, Accession No. 20181106-5159).
On February 13, 2019, FERC issued a Post -Application Environmental Information Request #1, and the
Project provided a data response on March 5th, 2019. On April 231d, 2019, FERC issued a Post -Application
Environmental Information Request 92, and the Project provided a data response on May 13th, 2019. On
June l Ph, 2019, FERC issued a Post -Application Environmental Information Request 93, and the Project
provided a data response on June 21 st, 2019. On July 26th, 2019, the FERC issued their Draft Environmental
Impact Statement, and on February 14th, 2020 the Final Environmental Impact Statement was issued.
In addition to the FERC data requests and responses summarized above, the Project provided supplemental
filings to FERC on January 24th, 2019, March 28th, 2019, May 22nd, 2019, August 9th, 2019, October 22nd
2019, November 13th 2019, December 13th 2019 and January 22nd, 2020. The Project also provided
application addendums and responded to agency Requests for Additional Information (RAI's) on January
18th, 2019, February 9th, 2019, May 20th, 2019, August 9th 2019 (Re -Application), September 13'h, 2019,
October 30th, 2019 and March 13th, 2020.
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1.1 SCOPE OF THE JOINT PERMIT APPLICATION
In addition to the FERC Certificate, the Southgate Project will require several additional permits, clearances
and / or approvals to construct or operate the Project facilities. This addendum is intended to lay out the
adjustments made to the application as a result of the March 13, 2020 withdrawal of the variance
applications and to compile previously submitted information which was provided to the Division. The
application is limited to the portion of the Project within the State of North Carolina, and is being submitted
in support of requests for the following:
• Nationwide Permit 12 verification from the U.S. Army Corps of Engineers ("USACE")
Wilmington District for wetland and waterbody impacts under Section 404 of the Clean Water Act
(33 U.S.C. § 1344);
• 401 Water Quality Certification from the North Carolina Department of Environmental Quality
("NCDEQ") for activities in state surface waters and wetlands under Section 401 of the Clean
Water Act (33 U.S.C. § 1341), N.C. General Statue § 143-215.3(c), and Title 15A N.C.
Administrative Code § 021-1.0500 et seq.; and
• Riparian Buffer Authorization from NCDEQ under N.C. General Statue § 143-214.5 and Title 15A
N.C. Administrative Code § 0213.0262 et seq.
A separate Joint State/Federal Permit application is being prepared for the portion of the Project within
Virginia under USACE Action # NAO-2018-1574.
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Fran lt in
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Joint Permit Application Addendum
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Figure 1. Southgate Project Overview Map.
F9 Mountain Valley
Figure 7
Pra}ect Overview
November 2019
TRC
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2.0 PROJECT DESCRIPTION
2.1 PURPOSE AND NEED
The proposed Southgate Project is a new pipeline designed to (1) meet the growing needs of natural gas
users in the southeastern U.S.; (2) add a new natural gas transmission pipeline to provide competition and
enhance the reliability and resiliency of the existing pipeline infrastructure in southern Virginia and North
Carolina; and (3) provide southern Virginia and North Carolina with direct pipeline access to the Marcellus
and Utica gas regions in West Virginia, Ohio and southwestern Pennsylvania. The Project will enhance the
diversity of gas supply and create additional pipeline capacity in the region. The overall purpose and need
with respect to the single and complete project included in this preconstruction notification is to provide a
timely, efficient, and cost-effective means of transporting natural gas from the existing terminus of the
Mountain Valley Pipeline in Pittsylvania County, Virginia to the T-15 Dan River Interconnect in
Rockingham County and then on to the T-21 Haw River Interconnect in Alamance County, North Carolina,
so that that the natural gas may be distributed to local and regional end users via those interconnects.
In 2017, PSNC Energy (now Dominion Energy North Carolina [DENC]'), solicited interest from existing
and proposed interstate pipeline providers for additional natural gas transportation capacity. DENC is a
local distribution company primarily engaged in the purchase, transportation, distribution, and sale of
natural gas to more than 563,000 customers in North Carolina. DENC solicited interest because it requires
additional pipeline capacity to meet forecasted incremental demand on its distribution system. Over the
past four years, DENC has experienced a 15 percent increase in peak daily throughput on its system. This
trend will carry forward into the future, as DENC expects its design day requirements to increase an
additional 11 percent over the next five years. This past, present, and future demand growth on DENC's
system reflects, at least in part, the substantial population increase in North Carolina. North Carolina's
population is expected to increase by nearly 2 million people between 2020 and 2035.2
After consideration of other existing and proposed interstate pipeline providers, DENC committed to 300
million cubic feet per day ("MMcf/d") of firm transportation service to be made available by the Project.
Mountain Valley and DENC entered into binding long-term agreements in December 2017 that made
DENC an anchor shipper for the Project.3 In choosing the Southgate Project to provide its needed
incremental pipeline capacity, DENC cited numerous reasons, including transportation cost, supply cost,
supply diversity, reliability/resiliency, and operational efficiencies:
• DENC found the Southgate Project provides the best -cost transportation alternative available to
satisfy DENC's long-term interstate capacity needs.
' Following a January 2, 2019 merger, Dominion Energy, Inc. acquired PSNC and changed the company name to
Dominion Energy North Carolina.
z See North Carolina Office of State Budget and Management population projections, available at:
https://files.nc.gov/nco sbm/demog/countytotals_populationoverview.hbnl
3 Mountain Valley and DENC entered into binding agreements for the Southgate Project more than three years after
Mountain Valley entered the pre -filing process, and more than two months after the Commission issued its certificate,
for the 303-mile Mountain Valley Pipeline Project. While the Mountain Valley Pipeline Project is targeted to
commence service during 2019, Mountain Valley expects the Southgate Project to commence service in late 2020.
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The Southgate Project will provide DENC with a third direct interstate pipeline connection, which
will improve reliability and add resiliency to the interstate pipeline services DENC receives 4 The
addition of a third interstate pipeline diversifies risk by giving DENC multiple options on
geographically -diverse interstate pipelines. In the event of outages or constraints on one of the
pipelines serving the region, DENC would have access to the other pipelines to continue serving
its customers.
• The Southgate Project will provide DENC additional direct access to low-cost natural gas produced
in the prolific Marcellus and Utica shale regions.'
DENC will have more competitive and diverse options for natural gas supply. DENC will gain
optionality in selecting best -cost supply sources and will be able to take advantage of price
differentials across more gas supply regions.
The Southgate Project will provide a direct connection between DENC's distribution system and
the East Tennessee Natural Gas, LLC ("East Tennessee") pipeline system. DENC currently sources
gas from Saltville Storage and transports these volumes on the East Tennessee and Transcontinental
Gas Pipeline Company, LLC ("Transco") systems before delivery to DENC's distribution system.
The Project provides a primary receipt and delivery forward haul transportation path that offers
improved reliability as compared to the secondary -firm backhaul deliveries DENC currently
receives from Transco.
• The Southgate Project will provide DENC flexibility with deliveries from the intrastate Cardinal
Pipeline, which should avoid the need for DENC to acquire additional Cardinal capacity.
The Southgate Project allows DENC to avoid incremental capital investment for system upgrades.
The other pipeline alternatives considered by DENC would have required additional system
upgrades.
Mountain Valley and DENC have agreed to a minimum delivery pressure that is higher than
Transco's existing obligation. This should improve DENC's ability to conduct system planning
and enhance the operation of its system.
In addition to executing agreements that made DENC an anchor shipper for the Project, Mountain Valley
conducted an Open Season between April 11, 2018 and May 11, 2018 to determine interest from additional
shippers. Negotiations continue with interested shippers for the remaining capacity of the Southgate
Project. There are no plans to extend this pipeline from the proposed terminus of the T-21 Haw River
Interconnect at this time.
The Southgate Project is not designed to provide natural gas to any liquefied natural gas export terminal
and has no intention of seeking authorization under Section 3 of the Natural Gas Act to export natural gas,
nor does the contracted shipper have plans to transport gas to a liquefied natural gas terminal. The Project
terminates at an inland location more than 185 miles from the nearest coastal Virginia port, 155 miles from
4 In 2013, the North Carolina Utilities Commission recognized the need for competitive interstate pipeline capacity
alternatives in Docket No. G-100, Sub 91, Investigation Regarding Competitive Alternatives for Additional Natural
Gas Service Agreements. The Project will satisfy this need for a new competitive interstate pipeline consistent with
the expressed goal of the North Carolina Utilities Commission.
5 Mountain Valley and DENC also executed binding long-term agreements whereby DENC became a shipper on the
Mountain Valley Pipeline Project.
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the nearest coastal North Carolina port, and even farther from the nearest liquefied natural gas export
terminal. Accordingly, the Southgate Project does not have the physical ability to export natural gas. As
currently designed, gas transported on the Southgate system will be delivered into existing facilities in Eden
and Graham, North Carolina. The Project's anchor shipper, DENC, has committed to 300 MMcf/d of firm
transportation service and will use the gas it transports to serve its fast growing residential, commercial and
industrial markets in North Carolina.
Location
The North Carolina portion of the Project includes approximately 48.3 miles (64 percent) of the proposed
pipeline alignment. It originates at the Virginia/North Carolina state boundary in Rockingham, North
Carolina at milepost ("MP") 26.1 and ends at MP 73.2RR (RR: Re -Route) in Alamance County, North
Carolina, as shown on Figure 1. The route through North Carolina is described below and is depicted on
U.S Geological Society ("USGS") 7.5-Minute topographic excerpt maps provided in Appendix A.
From the Virginia/North Carolina border, at MP 26.1 in Rockingham County, the 24-inch-diameter pipeline
extends southwest approximately 4.3 miles to a proposed delivery interconnect (T-15 Dan River
Interconnect) located at approximate MP 30.4. From the T-15 Dan River Interconnect, the pipeline will be
a 16-inch-diameter pipeline and continue generally southwest for approximately 2.4 miles. East of the City
of Eden, North Carolina, the pipeline will turn to the southeast near MP 32.8 and continue southeast for
approximately 20 miles into Alamance County at (MP 52.6), east of the town of Wentworth and the City
of Reidsville. From the Alamance County boundary, the pipeline will continue southeasterly to MP 66.3,
where it will turn south and continue for approximately 6.8 miles to its delivery terminus (T-21 Haw River
Interconnect) located at MP 73.2RR approximately 2.5 miles southeast of the City of Graham, North
Carolina.
The North Carolina portion of the Project is located within the USGS designated 03-South Atlantic -Gulf
Region (USGS, 2018a). In North Carolina, the Project crosses the Roanoke River Basin and the Cape Fear
River Basin, three sub basins and five watersheds (NCDEQ, 2018b). Table 2-1 (below) identifies these
major regions and their respective sub -basins by 8-digit HUC and watershed by 10-digit HUC.
Table 2-1
Major Regions, 8-digit HUC and 10-digit HUCs crossed by the Project
Major Region
River Basin
County
Sub -basin
Watershed
(2-digit HUC)
(8-digit HUC)
(10-digit HUC)
Rockingham
Upper Dan
Cascade Creek -Dan River
3010103
301010309
Roanoke
Rockingham
Lower Dan
Hogans Creek -Dan River
03- South Atlantic-
3010104
301010401
Gulf Region
Rockingham/
Headwaters Haw River
Alamance
Haw 3030002
303000202
Cape Fear
Alamance
Haw 3030002
Back Creek -Haw River
303000204
Source: NCDEQ, 2018b
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Proposed Facilities
In North Carolina, the Project includes 48.3 miles of new 24-inch and 16-inch diameter pipeline, temporary
construction workspace, new and existing access roads, above ground facilities, cathodic protection and
contractor yards. These are depicted on the Project's alignment sheets (Appendix B) and are described
below. Typical construction details depicting the workspace for the proposed facilities in a variety of work
conditions are provided as Appendix C. Updated Table 2-2 (to be provided in April 2020) summarizes the
facilities by location and land requirements for construction and operation.
2.1.1 Pipeline Facilities
The pipeline will generally require a 100-foot-wide construction right-of-way (limit of disturbance) during
construction consisting of a 50-foot permanent right-of-way and 50 feet of temporary workspace. The
temporary workspace is necessary for worker safety, the safe travel of construction vehicles and equipment,
stockpiling soil, and installation of erosion and sediment controls. The proposed 100-foot wide construction
right-of-way is consistent with the Interstate Natural Gas Association of America's ("INGAA")
recommendations for a pipeline diameter of 18 to 24 inches. INGGA recommends the use of a 95-foot
baseline width and increasing or decreasing this baseline width for special conditions (Gulf Interstate
Engineering, 1999). The necessary construction workspace is largely dictated by the area required for the
safe operation and movement of equipment required to install the pipeline as well as the additional
workspace needed to install and maintain appropriate erosion and sediment controls. These workspace
requirements are not materially different for a 16-inch or 24-inch pipeline. See Appendix C for typical
construction workspace details.
The Southgate Project has reduced the construction right-of-way width at wetland and waterbody crossings
to 75 feet along the construction right-of-way, for a distance of 50 feet on each side of the crossing to
preserve upland and riparian buffer areas. The Project will implement a modified FERC Upland Erosion
Control, Revegetation, and Maintenance Plan ("Southgate Plan") (Appendix D) and a modified FERC
Wetland and Waterbody Construction and Mitigation Procedures ("Southgate Procedures") (2013)
(Appendix E), and its Project -specific Erosion and Sediment Control Plan ("E&SCP") that comply with
state -specific regulations to minimize impacts during construction. The Project is preparing a state -specific
E&SCP that will comply with North Carolina erosion control regulations and will incorporate all relevant
substantive provisions of General Permit — NCG01000.6 See Appendix C for typical wetland and
waterbody crossing details.
The pipeline is located parallel to and adjacent with an existing gas or electric transmission corridor for
approximately 18 miles (37 percent) of the proposed alignment in North Carolina. Where collocation with
existing utility right-of-way occurs, the Project has designed the workspace such that the construction right-
of-way for the new pipeline is located immediately adjacent to or partially within the existing pipeline right-
of-way wherever feasible. The Project is proposing to use up to 25 feet of temporary workspace within the
adjacent utility right-of-way where possible; however, final design and use of workspace within these areas
is dependent on successful negotiation with the easement owner(s). See Appendix C for typical
construction workspace details for construction with collocated facilities.
6 The Project is exempted from obtaining coverage under this permit for stormwater discharges by 33 U.S.C. § 1342(1).
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2.1.2 Additional Temporary Workspace
Additional temporary workspace "ATWS" areas will be required for construction activities requiring space
outside the standard 100-foot construction right-of-way. Construction activities that may require ATWS
include but are not limited to:
• Areas requiring extra depth of cover over the pipeline;
• Timber storage areas;
• Areas with unstable soil;
• Installation of erosion and sediment controls and other stormwater management facilities;
• Road and railroad crossings;
• Winch hills;
• Wetland and waterbody crossings;
• Conventional bores;
• Horizontal Direction Drills;
• Foreign pipeline crossings and interconnects;
• Foreign utility crossings;
• Areas requiring full -width topsoil segregation;
• Specific request of the landowner;
• Areas with steep side slopes, rock, or other difficult terrain;
• Pipeline access and truck turnarounds;
• Material storage, storage of excess spoil at crossings, parking, vehicle turning radius, or other
worker safety issues;
• Fabrication and staging areas; and
• Hydrostatic test water withdrawal and discharge locations.
The ATWS areas will be limited to the minimum size necessary to safely construct the pipeline and be
protective of the environment with respect to the existing conditions at the time of construction. ATWS is
located near wetlands and waterbodies in accordance with the setback requirements contained in the FERC
Procedures and in consultation with other federal and state agencies. If field conditions do not allow for a
minimum 50-foot setback from wetlands and/or waterbodies, the Project will request alternative measures
to the FERC Procedures. Proposed ATWS and ancillary sites required for the Project are shown on the
alignment sheets (Appendix B).
2.1.3 Access Roads
New or existing roads will be used to provide access to the pipeline right-of-way during construction and/or
operation of the Project. Access road widths will be the minimum necessary to provide access for
construction equipment while maintaining safe travel conditions. Access will be constructed such that the
length of the road minimizes impacts on waters of the United States and will be maintained as close as
possible to pre -construction contours and elevations. Temporary construction -related wetland or waterbody
impacts are proposed along 6 access roads in Rockingham. No permanent wetland impacts from access
roads are proposed and three will have new permanent culverted waterbody crossings. These impacts are
discussed further in Section 4.0. The locations of proposed temporary and permanent access roads are
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shown on the 7.5-Minute topographic maps (Appendix A, updated alignment sheets (Appendix B) and
updated Impact Sheets in Appendix M (to be submitted in April of 2020).
Contractor Yards
The Southgate Project has identified potential contractor staging yards for temporary use during
construction. They will be used to stockpile pipe and fabricate facilities, if needed. Additionally, they will
be used by the construction contractor to stage construction operations, store materials, park equipment,
and set up temporary construction offices. The contractor yards were selected due to their proximity to
existing roads, railways, and rail yards and primary open industrial/commercial land uses. Focus was given
to properties with limited streams, wetlands, and other sensitive habitats. Depending upon the condition of
these yards and their current use, some surface grading, drainage improvements, placement of surface
materials (e.g., crushed rock), and internal roadways may be required.
Five contractor yards are proposed along the North Carolina portion of the route. Minor construction -related
temporary impacts to wetlands and waterbodies are proposed for contractor yard 5. Table 2-3 details the
land requirements and current land use for contractor yards, and their locations are shown on the alignment
sheets (Appendix B).
Table 2-3
Southgate Project Contractor Yards in North Carolina
Contractor Yard Name
Location/County
Approximate Milepost
Existing
Workspace
Land Use a/
(acres)
CY-05
Eden, Rockingham
3.6 miles West of 28.3
Cl, OL
18.3
CY-08
Reidsville, Rockingham
2.9 miles West of 44.6
OL, Cl
11.5
24.9 (Forest
CY-25
Yanceyville, Caswell
12.3 miles East of MP 38.9
OL, FW
to be cleared
<0.01)
CY-26A
Swepsonville, Alamance
2.4 miles East of 71.7
OL
11.8
10.3 (Forest
CY-26B
Swepsonville, Alamance
2.4 miles East of 71.7
FW, OL
to be cleared
0.2)
a/ Existing Land Use: Cl = Commercial / Industrial; FW = Upland Forest / Woodland; OL = Upland Open Land; RD =
Residential; WL = Wetland
2.1.4 Aboveground Facilities
2.1.4.1 Meter Stations
Two downstream delivery points with the DENC system are proposed near MP 30.4 and MP 73.2. The
Project will install a meter (interconnect) station at both of these locations consisting of but not limited to
custody -transfer flow meter, pressure/flow regulator, over pressure protection, isolation mainline valves,
and associated instrumentation and controls at the proposed gas receipt and delivery points to measure the
flow of natural gas between the Project and the interconnect. Each interconnect will consist of one or more
meter runs located inside a fenced and gated site and will contain flow or pressure control. The metering
sites will be located as close as practicable to the actual intersection of the Project and the receipt / delivery
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facilities to keep the length of the interconnecting piping to a minimum. The locations of these facilities
are described in Table 2-4 and are shown on the updated alignment sheets in Appendix B (to be provided
in April of 2020). The meter stations will include upstream and downstream piping to connect to the pipeline
and third -party pipelines.
Table 2-4
Southgate Project Mainline Valve and Meter Station (Interconnect) Locations
Name
County
Approximate Milepost Location
LN 3600 Interconnect
Rockingham
28.2
T-15 Dan River Interconnect / MLV 4
Rockingham
30.4
MLV 5
Rockingham
42.2
MLV 6
Alamance
55.1
MLV 7
Alamance
68.7
T-21 Haw River Interconnect / MLV 8
Alamance
73.2 RR
a/ Mainline Valves ("MLV's") will be 30 feet by 30 feet in area and will be wholly contained within the permanent
right-of-way. Mainline valves at the T-15 Dan River Interconnect and T-21 Haw River Interconnect will be located
within the fence line of those facilities.
2.1.4.2 Mainline Valves
The Project will install mainline valves ("MLVs") at intermediate locations as necessary to meet operational
needs and the design and installation requirements described in 49 CFR 192.179(a) — Transmission Line
Valves that require minimum distances to the nearest valve based on pipeline location class. Table 2-4
identifies the location of MLVs. MLVs will be located within the permanent right-of-way of the pipeline.
With the exception of those located at pig launcher/receiver locations, MLVs will be buried with
aboveground extensions and equipped with valve actuators to allow for local or remote operation. Each
MLV will be contained within a fenced, gated, and locked area. None of the MLVs are located in wetlands
or waterbodies.
2.1.4.3 Pig Launchers and Receivers
The Project has incorporated launching and receiving facilities to accommodate in -line inspection tools
(smart pigs) for periodic internal inspections of the pipeline during operations. A pig launcher is proposed
at the origination point inside the Lambert Compressor Station fence line at MP 0.0 of the pipeline in
Pittsylvania County, Virginia. The corresponding pig receiver will be located at MP 30.4 in Rockingham
County, North Carolina at the T-15 Dan River Interconnect (meter station), and a second pig launcher will
also be located at this site. A second pig receiver will be located at the terminus of the pipeline at
approximate MP 73.2RR at the T-21 Haw River Interconnect near Graham, North Carolina. The locations
of these facilities are included on the updated alignment sheets located in Appendix B. No wetlands or
waterbodies will be affected by the construction or use of these Pig Launchers and Receivers.
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2.2 CONSTRUCTION
2.2.1 General Practices
Construction of the Southgate Project will follow industry -accepted practices and procedures and will be
done in accordance with applicable federal and state regulations and guidelines, as well as the specific
requirements of applicable permits. The Project developed its own Project -specific Erosion and Sediment
Control Plan ("E&SC") based on field conditions and state requirements that will outline best management
practices (`BMPs") to minimize impacts (Appendix E). The Project will train construction personnel in the
environmental restrictions and/or requirements applicable to their particular duties. The Project will provide
construction management personnel and environmental inspectors (" EIs") with the appropriate
environmental information/materials specific to the Project. The Project will handle any hazardous
materials stored or encountered during construction in accordance with the Project Spill, Prevention,
Control, and Countermeasures Control Plan ("SPCC") (Appendix F). Waste will be disposed of at an
approved, off -site facility.
The pipeline will be buried a minimum of three feet below the ground surface except for locations where
the pipe will be installed within rock. In those instances, the minimum depth of cover will be two feet. The
pipeline will be constructed of high strength carbon steel pipe manufactured in accordance with the
American Petroleum Institute's ("API") specification API 5L PSL2, Specification for Line Pipe. The
Project will protect the pipe from corrosion by a fusion -bonded epoxy coating and an impressed current
cathodic protection system during operation. Weld joints and other piping that are not factory coated will
be field -coated per applicable standards.
The Project is proposing to use two spreads to construct the pipeline. Spread 1 includes the H-605 pipeline
and the H-650 pipeline from MP 0.0 to MP 30.4 and Spread 2 includes MP 30.4 to MP 73.2RR. Generally,
construction of the proposed pipeline within each spread will follow a set of sequential operations as shown
in Figure 2. In this typical pipeline construction scenario, the construction spread proceeds along the
pipeline right-of-way in one continuous operation. The Project will coordinate the entire process in such a
manner as to minimize the total time a tract of land is disturbed and therefore exposed to erosion and
temporarily precluded from normal use. Appendix C includes typical construction details depicting various
construction scenarios. The following sections provide detailed descriptions of each proposed construction
method.
2.2.2 Typical Upland Pipeline Construction Procedures
The majority of the pipeline is in upland terrain and will be crossed via conventional overland construction
techniques for large -diameter pipelines. In this typical pipeline construction scenario (Figure 2), the
construction contractor will construct the pipeline along the construction right-of-way using sequential
pipeline construction techniques, including survey, staking and fence crossing; clearing and grading;
trenching; pipe stringing, bending and welding; lowering -in and backfilling; hydrostatic testing; clean-up
and restoration; and commissioning. Each step is briefly described in the following:
(a) Surveying
The initial step in preparing the right-of-way for construction will be the civil survey. A civil survey crew
will stake the outside limits of the construction right-of-way, the centerline location of the pipeline, highway
and railroad crossings, access roads, and any temporary ATWS, such as laydown areas or at stream
2-8 March 2020

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IT Mountain Valley Joint Permit Application Addendum
PIPELINE ut USACE — Wilmington District and NCDEQ
SAW-2018-008887
crossings. The Project will contact the North Carolina 811 "One Call' system, and all known underground
utilities (e.g., cables, conduits, and pipelines) will be located and flagged. The Project will notify affected
landowners a minimum of 24 hours prior to surveying and staking of the proposed route, following
applicable state/federal guidelines.
(b) Clearing and Grading, and Fencing
After the right-of-way has been surveyed and easements have been secured (for the permanent and
temporary construction right-of-way, and any existing right-of-way if necessary), the Project will clear the
right-of-way of obstructions (e.g., trees and stumps, brush, logs, and large rocks) according to the Southgate
Plan, the Project -specific E&SCP and applicable regulatory approvals. The Project will clear the right -of -
ay to the width required for construction, but not more than specified on the pipeline alignment sheets
(Appendix B) and approved by applicable regulatory approvals. Merchantable timber will be stacked
outside of the work area alongside the edge of the right-of-way or ATWS (outside of jurisdictional wetlands
or waters). The Project will dispose of brush and slash through burning, windrowing, or chipping, in
accordance with applicable approvals and conditions.
(c) Trenching
The Project will excavate the pipeline trench with a track -mounted backhoe or similar equipment and only
use explosives when necessary in areas where rock substrates are at depths that interfere with conventional
excavation or rock -trenching methods. On actively cultivated agricultural tracts, at wetland crossings,
streams, and in residential areas, subsoil will be segregated and stockpiled separately from topsoil per the
Southgate Plan.
The Project will stockpile excavated soils along the right-of-way on the side of the trench (the "spoil' side)
away from the construction traffic and pipe assembly area (the "working" side). Where the pipeline route
is collocated adjacent to an existing infrastructure, the spoil will generally be placed on the same side of
the trench as the existing infrastructure.
(d) Pipe Stringing and Bending
New steel pipe for the pipeline will be procured and protected with an epoxy coating applied at the factory
or at a coating yard (the beveled ends will be left uncoated for welding) and shipped to strategically located
materials storage areas, contractor yards, or "pipe yards." The Project will transport the individual joints
to the right-of-way by truck and place along the excavated trench in a single, continuous line that is easily
accessible to the construction personnel on the working side of the trench (typically opposite the spoil side).
This will allow the subsequent lineup and welding operations to proceed efficiently.
The Project will deliver the pipe to the Project workspace in straight joints typically 40 to 60 feet in length.
The use of controlled internal diameter fittings, in addition to the bending of pipe, will be required to allow
the pipeline to follow natural grade changes and directional changes of the right-of-way. Prior to welding,
track -mounted hydraulic bending machines will bend selected joints in the field.
(e) Pipe Assembly and Welding
Following stringing and bending, the Project will place the joints of pipe on temporary supports adjacent
to the trench. The ends will be aligned and welded together by qualified personnel using multiple passes
for a full penetration weld. To ensure that the assembled pipe will meet or exceed the design strength
requirements, the completed welds will be visually inspected and tested for integrity using non-destructive
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examination methods such as radiography (X-ray), or ultrasound, in accordance with API 1104. Welds
displaying unacceptable slag inclusions, void spaces, or other defects will be repaired or replaced.
Following welding, the Project will sandblast the previously uncoated ends of the pipe at the joints and
cover them in epoxy. The coating on the completed pipe section will be inspected, and damaged areas will
be repaired prior to lowering in accordance with applicable industry standards.
(f) Pipe Lowering
The completed section of pipe will be lifted off temporary supports and lowered into the trench by side -
boom tractors or equivalent equipment. Prior to lowering the pipe, the Project will inspect the trench to
ensure that it is free of rocks and other debris that could damage the pipe or the coating. In rocky areas, if
the bottom is not smooth, a layer of soil or sand may be placed on the bottom of the trench to protect the
pipe using a padding machine or excavator with a "shaker bucket," which separates rocks from satisfactory
padding materials. Concrete -coated pipe or aggregate filled sacks (pipe weights) will be used if necessary
for negative buoyancy in areas prone to flooding or with a high groundwater table.
(g) Padding and Backfilling
After the pipe is lowered into the trench, the Project will backfill the trench. Previously excavated materials
will be pushed back into the trench using equipment or backhoes. Where the previously excavated material
contains large rocks or other materials that could damage the pipe or coating, clean fill will be used to
protect the pipe. Due to concerns about the acidity of fly ash and its potential impacts on cathodic
protection, fly ash will not be used as backfill material. However, limestone dust or sand, which is typically
basic and will often aid in the cathodic protection of the pipeline, may be used as backfill material. The
remaining fill of the trench will be the aggregate of the excavation material removed at the time of the
excavation. If additional fill is required, it will be either flowable fill or clean fill. After the subsoil is
placed in the trench, segregated topsoil will be placed in the trench above the subsoil. Following backfilling
in agricultural land, and open land, a small crown may be left to account for any future soil settling that
might occur. In wetlands, a crown will not be left to ensure restoration of ground and surface water
hydrology to pre-existing conditions. Excess soil will be distributed evenly on the right-of-way in
accordance with landowner and agency requirements, only in upland areas and only to meet the pre -
construction surface elevations.
(h) Hydrostatic Pressure Testing and Final Tie -In
Following backfilling of the trench, the Project will hydrostatically test the pipeline to ensure that it is
capable of safely operating at the design pressure. Test segments of the pipeline will be capped and filled
with water. Test water is anticipated to be procured from municipal sources. The water in the pipe will be
pressurized and held for a minimum of 8 hours in accordance with the U.S. Department of Transportation
("USDOT") Pipeline and Hazardous Materials Safety Administration Office of Pipeline Safety
requirements identified in 49 CFR Part 192 prior to being placed in service. Any loss of pressure that
cannot be attributed to other factors, such as temperature changes, will be investigated. Leaks detected will
be repaired and the segment will be retested.
The total estimated volume of water used for hydrostatic testing is proposed to be approximately 8,500,000
gallons. Each of the construction spreads will likely be broken down into smaller test sections. The
hydrostatic test has been designed such that the water should only need to be drawn from the identified
source once. From there, it will be transferred into the next test section, which has been chosen to be smaller
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than the first. By this method, no additional water will be needed within a construction spread, since the
large volume initially drawn will be transferred to increasing smaller sections that require less volume.
Test water will contact only new pipe, and no chemicals will be added to the test water unless otherwise
approved by FERC and applicable federal and/or state regulatory agencies. If a municipal water source
with chlorinated water is used for testing, addition of an approved dechlorinating agent may be required
prior to release depending on the release location. These measures will be implemented to ensure that
hydrostatic test water releases will not have the potential to cause or contribute to an exceedance of any
water quality standards, consistent with 15A NCAC 02H.0106(f). Upon completion of the test, the water
maybe pumped to the next segment for testing, or the water maybe released. The test water will be released
through an energy -dissipating device to a vegetated upland area. To the extent practicable, the Project will
release test water within the same watershed from which water was withdrawn, to an upland, well vegetated
area, directed through containment structures such as hay bale structures and filter bags. The release will
be monitored and the rate will be regulated using valves and energy dissipation devices to prevent erosion.
Once a segment of pipe has been successfully tested and dried, the test cap and manifold will be removed,
and the pipe will be connected to the remainder of the pipeline. No desiccant or chemical additives will be
used to dry the pipe. The Project will implement Section VII of the Southgate Procedures regarding
hydrostatic testing.
(i) Cleanup and Restoration
The Project will conduct post -construction restoration activities in accordance with the measures specified
in the Southgate Plan and Procedures as required. After a segment of pipe is installed, backfilled, and
successfully tested, the Project will final -grade the right-of-way, temporary ATWS, and other disturbed
areas, and construction debris will be disposed of properly. The Project will grade the surface of the right-
of-way disturbed by construction activities to match original contours and to be compatible with
surrounding drainage patterns, except at those locations where permanent changes in drainage will be
required to prevent erosion, scour, and possible exposure of the pipeline. The Project will return segregated
topsoil to its original horizons in agricultural areas and install temporary and permanent erosion and
sediment control measures where necessary, including silt fencing, diversion trenches, and vegetation. The
Project will also restore, to original or better condition, all private and public property impacted by the
Project such as fences, gates, driveways, and roads that have been disturbed by the pipeline construction.
2.2.3 Typical Wetland Pipeline Construction
The Southgate Project will cross wetlands in accordance with state and federal permit conditions and the
Southgate Procedures. Pending site conditions, the Project may request alternative measures to the
Southgate Procedures, and these would require approval by FERC prior to construction in these areas. In
accordance with the Southgate Procedures, fuel will not be stored within 100 feet of wetlands.
Hydrological conditions along the construction corridor in areas proposed for open ditch construction will
likely dictate the use of either open ditch lay or open ditch push/pull lay methods. Selection of the most
appropriate method will depend on site -specific weather conditions, inundation, soil saturation, and soil
stability at the time of construction. The conventional open ditch lay method will be the most frequently
used technique for installation of the pipeline in wetlands. The Project will use the push/pull method, as
described in the Southgate Procedures, in inundated or saturated wetland areas where groundwater
conditions preclude conventional construction. Selection of the push/pull method will be decided during
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construction by the construction manager or Project representative depending on the conditions at the time
of construction. Updated Appendix G (Wetland and Waterbody Crossing Analysis — to be provided in
April of 2020) provides a practicability assessment for wetland and waterbody crossing methods.
Practicable is defined as available and capable of being done after taking into consideration cost, existing
technology, regulatory requirements, and logistics in light of overall project purposes. The Southgate
Project will continue to consult with the USACE, USFWS, NCDEQ, NCDEMLR, and NCWRC on the
appropriate crossing method for each wetland. If the Project moves forward with an alternative crossing
method that is not practicable, it is due to the request of a regulatory agency that does not consider
practicability. Descriptions of the crossing methods are provided below.
(a) Unsaturated Wetland Crossings
When crossing unsaturated wetlands (wetlands without standing water or saturated soils), construction will
be similar to the typical upland construction described in Typical Upland Pipeline Construction Procedures
above, with some exceptions. Only one traffic lane will be provided for construction equipment. The
Project will use low ground pressure equipment if normal construction equipment causes rutting or mixing
of wetland topsoil and subsoil, or install temporary equipment mats to allow passage of equipment with
minimal disturbance of the surface and vegetation. Trees will be cut to grade, but stumps will only be
removed within 15 feet of the edge of the pipe trench, or where safety concerns dictate otherwise.
The Project will segregate the topsoil from subsoil in wetlands where hydrologic conditions permit this
practice, and all excavated material will be placed in an upland area if possible. All excavated material
stockpiled in wetlands will be placed on filter cloth, mats, or other semipermeable surface to prohibit mixing
with underlying material. Excavated soil material in wetlands will be stabilized with filter cloth to prevent
re-entry into wetlands or waterbodies and will not be stored in wetlands for more than 30 days after the
pipeline has been laid in the trench without permission from the USACE-Wilmington District. Segregated
topsoil will be placed in the trench following subsoil backfilling to restore the original contour.
The Project will install and maintain erosion control measures to minimize sedimentation within the
wetland. Trench plugs will be installed at the entry and exit points of wetlands and waterbodies to prevent
the modification of subsurface hydrology.
(b) Saturated Wetland Crossings
For the purposes of this report, saturated wetlands include wetlands with standing water, but not those
wetlands that are constantly or regularly completely submerged. Topsoil segregation will not be practical
in saturated wetlands. Otherwise, construction will be similar as described for unsaturated wetlands to
provide for anticipated widths of the pipeline trench and trench spoil areas. The Project will use low ground
pressure equipment (e.g., rubber tire excavator) or timber mats to facilitate equipment movement through,
and work within, the wetland. Equipment not associated with the pipeline construction within the wetland
will be allowed to pass through the wetland when there is no other reasonable access, as provided in the
FERC Procedures. The Project will use the push/pull lay method in inundated or saturated wetland areas
where groundwater conditions preclude conventional construction. Upon completion of construction, the
right-of-way will be restored and revegetated. Following construction, the Project will only maintain tree
clearing within 15' on either side of the pipeline centerline, and a 5' wide corridor on either side of the
pipeline centerline will be routinely mowed.
2-13 March 2020

IT Mountain Valley Joint Permit Application Addendum
PIPELINE,[ USACE — Wilmington District and NCDEQ
SAW-2018-008887
2.2.4 Typical Waterbody Crossings
The Southgate Project will conduct construction across waterbodies in accordance with the Southgate
Procedures and state and federal permit requirements. In accordance with the Southgate Procedures, fuel
will not be stored within 100 feet of waterbodies. Multiple variables were evaluated when determining the
appropriate crossing method (e.g., waterbody width, waterbody depth, riparian impact, available
workspace, sensitive species, duration to complete the crossing, safety, and cost) that would avoid or
minimize impacts to the greatest extent practicable. The normal trenching operations will skip the
waterbody crossing, stopping on each side near the top of bank. The Project will install the waterbody
section of the pipeline by one of the methods described below. In general, pipe will be bent and fabricated
as the work progresses along the right-of-way so that the excavation of the waterbody crossing is completed
prior to pipe installation by the tie-in crew.
Construction methods at each waterbody will vary based upon the characteristics of the waterbody
encountered and applicable regulatory approvals. Conventional crossing methods where there is
discernable flow (wet crossing methods) were not considered for any waterbody crossings because of
potential impacts to aquatic resources and water quality. Dry open cut crossings combine traditional trench
construction techniques with erosion and sediment control best management practices (silt fence, compost
filter socks, turbidity curtains, pumped water filter bags) and water management techniques (damming,
pumping, etc.) to install pipeline across waterways.7 The construction manager's decision whether to use a
dam and pump, flume, or cofferdam stream crossing method will be largely dependent upon the following
at the time of construction: width and depth of the stream, flow rate, flow velocity, weather forecast, and
anticipated time required to complete the crossing. As such, this decision is typically made just before the
installation begins with significant consideration given to the above factors.
Blasting for pipeline facilities grade or trench excavation and interconnect site development will be
considered only after all other reasonable means of excavation have been evaluated and determined to be
unlikely to achieve the required results. Before any blasting occurs, Contractor will complete a project/site-
specific blasting plan and provide it to MVP for review. No blasting shall be done without prior approval
of MVP. Appendix R (MVP Southgate General Blasting Plan) outlines blasting procedures for the
proposed pipeline route alignment and associated Project facilities.
Based on the data collected to date, trenchless crossing methods (i.e., conventional bore and HDD) have
been selected as the preferred crossing alternative for waterbodies that have known federally listed species
and where non -perpendicular crossings are needed within the Jordan Lake Watershed. More details on
trenchless crossing methods and why these waterbodies were selected are provided below. The planned
crossing method and practicability of the methods for each stream can be found in Appendix G (Wetland
and Waterbody Crossing Analysis). Practicable is defined as available and capable of being done after
taking into consideration cost, existing technology, regulatory requirements, and logistics in light of overall
project purposes. Prior to construction, any previously identified crossing conditions (mussel relocation or
time of year restrictions) will be satisfied. The Southgate Project will continue to consult with the USACE,
USFWS, NCDEQ, NCDEMLR, and NCWRC on the appropriate crossing method for each waterbody. If
It is possible to cross streams with discernible flow using a wet open cut method. The primary difference with the
wet open cut method is that the trench is cut through the stream without diverting the flow around the excavation. The
wet open cut method has not been considered for the Project as a crossing method. References to "open cuf' in this
application refer solely to the dry open cut method.
2-14 March 2020

IT Mountain Valley Joint Permit Application Addendum
PIPELINE ut USACE — Wilmington District and NCDEQ
SAW-2018-008887
the Project moves forward with an alternative crossing method that is not practicable, it is due to the request
of a regulatory agency that does not consider practicability.
The Project will require construction activities parallel to and within 10 feet of the top of bank of several
waterbodies. Mountain Valley is planning to install crossings that are not perpendicular (i.e., not between
75 degrees and to 105 degrees) using the conventional bore technique. The Project requests authorization
from NCDEQ to perform these necessary construction activities.'
(a) Conventional Crossing
The Project will cross intermittent or ephemeral waterbodies with no discernable flow at the time of
construction using the conventional crossing methods, unless otherwise required, if the Environmental
Inspector verifies that water is unlikely to flow between initial disturbance and final stabilization of the
feature. Conventional crossing requires the least amount of time to complete pipeline installation and
restore the waterbody, the least amount of ground disturbance, and is the most cost effective.
Trench spoil will be segregated and placed on the bank above the high-water mark for use as backfill. A
prefabricated segment of pipeline will be laid horizontally across the waterbody bed past the high banks on
each side of the waterbody before raising in elevation to the normal trench level. If necessary, the pipeline
may be weighted with concrete weights, and/or aggregate filled sacks to obtain sufficient negative
buoyancy.
Compaction percentage of backfill will be equal to or above that of the adjacent undisturbed areas. Trench
plugs consisting of sandbags or foam may also be used to keep backfill from sloughing in toward the center
of the waterbody. The Project will restore waterbody banks to their original grades and remove and dispose
of excavated material not required for backfill at an upland site. The Project will follow the Southgate
Procedures to limit water quality and aquatic resource impacts during and following construction. The
Project will schedule construction activities so that the pipeline trench is excavated immediately prior to
pipe laying activities.
(b) Dam and Pump Crossing Method
The dam and pump method involves installation of temporary dams upstream and downstream of the
proposed waterbody crossing. The temporary dams will typically be constructed using materials such as
sandbags and synthetic sheeting. Following dam installation, all fishes will be removed from within the
structure prior to completely dewatering, appropriately sized pumps will be used to dewater and transport
the stream flow around the construction work area and trench. Pumps will be placed within secondary
containment. Intake screens will be installed at the pump inlets to prevent entrainment of aquatic life, and
energy dissipating devices will be installed at the pump discharge point to minimize erosion and streambed
scour. See Figure 3 below for a typical dam and pump design. Trench excavation and pipeline installation
will then commence through the dewatered portion of the waterbody. Following completion of pipeline
installation, backfill of the trench, and restoration of stream banks, the temporary dams will be removed,
and flow through the construction work area will be restored. This method is generally only appropriate
for those waterbody crossings where pumps can adequately transfer the stream flow volume around the
8 AlthoughNCDEQ's Water Quality General Certification (No. 4133) does not expressly apply to this application for
an individual 401 Water Quality Certification, the Project is using its conditions as guidance for developing this
application.
2-15 March 2020

IT Mountain Valley Joint Permit Application Addendum
PIPELINE ut USACE — Wilmington District and NCDEQ
SAW-2018-008887
work area and there are no concerns about the passage of sensitive aquatic species. This crossing method
generally minimizes the duration of downstream turbidity by allowing excavation of the pipeline trench
under relatively dry conditions.
0 FT TOP OF BANK 55 0 FT
�t1 IFlD STREAM
07) BED SILT FENCE
CTYPJ
—1%0 FT FL13W 10 FT
S MIK MIN.PILE I rLE
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TRENCH BAR
N I-- BREAKER — — — — —
(T1fP,)
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CCEsa T�I dNE
LESS
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Figure 3. Dam and Pump Crossing Method Typical
(c) Flume Crossing Method
The flume crossing method will consist of temporarily directing the flow of water through one or more
flume pipes placed over the area to be excavated (See Figure 4). This method will allow excavation of the
pipe trench across the waterbody completely underneath the flume pipes without disruption of water flow
in the stream. Stream flow will be diverted through the flumes by constructing two bulkheads and using
sand bags or synthetic dams to direct the stream flow through the flume pipes. If necessary, dewatering
pumps may be used to pump excess water to ensure stream flow is adequately moved past the work area.
If used, dewatering pumps will be placed within secondary containment. Intake screens will be installed at
the pump inlets to prevent entrainment of aquatic life, and energy dissipating devices will be installed at
the pump discharge point to minimize erosion and streambed scour. The Project will remove bulkheads and
flume pipes following completion of pipeline installation, backfill of the trench, and restoration of
2-16 March 2020

IT Mountain Valley PIPELI
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
waterbody banks. This crossing method generally minimizes the duration of downstream turbidity by
allowing excavation of the pipeline trench under relatively dry conditions.'
I
y
ER8'.SI0N OONTftOL
9 I k}
MCGaJRES TO BE
LOCATED BELOW
A.-PROACH AREAS
1
.,
WATER
b FLUME LL PIPr = ' ..' _ FLOW
1
IiC
XCAVATED TRENCH
I
TROL
BI=W
EAS
1
CREEK E"K
A
WATER L �c - FL
�—
WAT R
CREEK BOTTOM
_ PRoa_a�PELIHe �
SECTION
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CREEK EIANK CREEK HANK
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WATER WALL
FLUI.IE
PIPE
PR POSED
SECTION "B-B"
Figure 4. Flume Crossing Method Typical
9 The difference between the dam and pump and flume crossing methods is based on how streamflow is temporarily
diverted around the work area to allow trenching and pipeline installation to occur in dry conditions. Streamflow
conditions at the time of construction generally dictate which method is preferable. However, they are not considered
true crossing "alternatives" because there is no material difference in the relative water quality impacts between the
two methods
2-17 March 2020

IT Mountain Valley Joint Permit Application Addendum
PIPELINE,` USACE — Wilmington District and NCDEQ
SAW-2018-008887
(d) Cofferdam Crossing Method
The cofferdam crossing method may be used for crossing channels 10 feet or wider where the dam and
pump and flume methods will be inadequate to safely convey the volume of streamflow around the crossing
and will be designed so as not to prevent the flow of the stream. A cofferdam will be constructed within
the construction right-of-way (e.g., using cofferdam products), enclosing approximately half the streambed
in a semi -circle. The cofferdam seals tightly to the streambed to minimize water from entering the
construction area. Pumps are used to remove water from within the cofferdam and to keep water out of
excavations. This water is pumped to the upland area adjacent to the crossing and is released through
pumped water filter bags places behind silt fence or similar devices. All earth disturbance will occur in the
dry area behind the cofferdam. The pipe will be installed, and the disturbed area backfilled and stabilized.
Sediment barriers at the waterline will be installed and functional before the cofferdam is removed.
Following construction, banks will be stabilized with either riprap or vegetation. The cofferdam is then set
up from the opposite bank and extends far enough to include the tie-in point in mid -stream. The remainder
of the pipe is installed, and the tie-in weld is made. Clean up follows the same procedures described above.
See Figure 5 below for an example.
2-18 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
EXISTING STREAM WIDTH W
1/2 W
(MIN.
RIPRAP OR OTHER
NON— ERQpIBLE A WATER IAL A
W
�P) TRENCHLINE o
W
m
AGGREGATE OR
FLOW - SAN D o
FILTER CLOTH
PLAN DEwATERINC DEVICE, SEE STD_ do SPEC_ 3.26
P 1111 TER
* (E
MINI
BE
WIDTH (W) OF THE
STREAM.
W
SECTION A -A
Figure 5. Cofferdam Crossing Typical
PERIMETER
CONTROLS
2-19 March 2020

IT Mountain Valley Joint Permit Application Addendum
PIPELINE,` USACE — Wilmington District and NCDEQ
SAW-2018-008887
(e) Conventional Bore Crossing Method
Waterbodies crossed by the Southgate Project that are directly associated with or adjacent to roads or
railroads and/or those located within the Jordan Lake Watershed that are non -perpendicular may be crossed
via conventional bore. Utilizing this method will limit extent of the disturbed area is required in the Jordan
Lake buffer rules for utility, non -electric projects that include non -perpendicular crossings of streams and
other surface waters (15A NCAC OsB.0267(9), n.4) Where roads or railroads are to be crossed using a
horizontal or conventional boring machine, the waterbody will typically be included within the length of
the bore to avoid the need to excavate a bore bit in the waterbody. Some elevated or channelized
waterbodies, such as irrigation ditches, may also be successfully bored, depending upon the groundwater
level in the area. This crossing method avoids instream disturbance and therefore is proposed for crossings
where consultation with the USFWS and NCWRC indicated sensitive aquatic species could be present:
Cascade Creek, Wolf Island Creek, and Deep Creek. In addition, non -perpendicular crossings within the
Jordan Lake Watershed using the conventional bore method to further minimize riparian impacts are
identified in updated Appendix L-2 (to be provided in April 2020).
To complete a horizontal or conventional bore, two pits will be excavated, one on each side of the feature
to be bored. A boring machine will be lowered into one pit, and a horizontal hole will be bored to a diameter
equal to the diameter of the pipe (or casing, if required) at the depth of the pipeline installation. The pipeline
section and/or casing will then be pushed through the bore to the opposite pit (See Figure 4). If additional
pipeline sections are required to span the length of the bore, they will be welded to the first section of the
pipeline in the bore pit before being pushed through the bore.
Issues which must be considered during evaluation of conventional bore for potential use during crossing
of waterways and wetlands include:
• Worker safety, especially when high groundwater poses risk to stability of bore pits.
• Significantly more workspace required due to the boring machines, drill string and pipe storage and
storage of spoil from the bore pits (as much as 900 cubic yards for a 20-foot deep pit). Topography
in stream valleys significantly reduces (or eliminates) the amount of space available.
• Groundwater must be managed due to proximity of the bore pit to the feature being bored.
• Bore pits situated on a slope, the depth of the upslope wall of the pit will increase quickly creating
the need for additional surface disturbance and associated workspace as the pit walls must be graded
(laid back) for worker safety.
• Geology may hinder or eliminate the potential use of conventional bore due to the hardness of rock
encountered, the presence of varying different materials in the bore path (i.e. large boulders in sand
and gravel) or changes in bedding thickness.
• Disturbance of riparian buffer associated with workspace and excavation of bore pits.
2-20 March 2020

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Joint Permit Application Addendum
USACE—VW|mingtonDistrintandNCDEC>
8AVV-2018-008887
PLAN VIEW
7LLHOLEF
MACHINE
Ell F
FigureG. Conventional Bore Typical
2'21 K4arch2O2O

IT Mountain Valley Joint Permit Application Addendum
PIPELINE,[ USACE — Wilmington District and NCDEQ
SAW-2018-008887
(f) Horizontal Directional Drilling Crossing Method
Horizontal directional drilling ("HDD") is a method that allows for trenchless construction across an area
by pre -drilling a hole below the depth of a conventional pipeline lay and then pulling the pipeline through
the pre -drilled borehole (See Figure 5). Currently, the Project is proposing an HDD at the Dan River and
Stony Creek Reservoir crossings. The HDD was selected at the Dan River due to crossing length, depth of
the river, fluctuation of water levels, and threatened and endangered species concerns. The Stony Creek
Reservoir HDD was selected due to the length of crossing, depth of the reservoir, and to limit impact on
the recreational uses of the waterbody. Equipment will not be required to cross either the Dan River or The
Stoney Creek Reservoir to complete an HDD. HDD Site -specific Plans are provided in Appendix H.
The HDD method has been in use since the 1970s as a means to install pipelines across rivers and at shore
approaches to mitigate for construction activities within a waterbody. Pipelines up to 60 inches in diameter
have been successfully installed using this method. The length of pipeline that can be installed by HDD
depends upon topography, soil conditions, geology, and pipe diameters and is limited by available
technology and equipment sizes.
Typically for HDD crossings, electric -grid guide wires will be hand -laid across the land surface along the
pipeline right-of-way to help guide the drill bit along the predetermined HDD route. In thickly vegetated
riparian areas, a swath approximately two to three feet wide may be hand -cleared across the land surface
for the placement of guide wires to monitor the track of the drill alignment, resulting in minimal ground
and vegetation disturbance. This may occur over the pipe or temporary access may be utilized if it does
less harm to the vegetation. Following guide wire installation, a directional drilling rig will be set up and a
small -diameter pilot hole will be drilled along a prescribed profile.
Electromagnetic sensors located on the tip of the drill bit will follow an electromagnetic field created by
the guide wires along the prescribed path. Where guide wires cannot be used, bit tip positioning sensors
will be used to guide the drill bit. In either case, once the pilot hole is completed, it will be enlarged, using
reaming tools to provide access for the pipe. The reaming tools will be attached to the drill string at the
exit point of the pilot hole and then rotated and drawn back to the drilling rig, thus progressively enlarging
the pilot hole with each pass.
During this process, drilling fluid consisting of water and bentonite clay (typically a 97:3 mixture) will be
continuously pumped into the hole to remove cuttings and maintain the integrity of the hole. Bentonite clay
is classified as a non-toxic/non-hazardous substance. Due to the unique characteristics of bentonite, the
slurry is capable of absorbing 10 times its own weight in water and swells up to 19 times its dry volume.
The combined bentonite and water mixture serves the following purposes: lubricate and cool the drill head;
seal and fill the porous space on the circumference of the drilled hole; form a cake -like substance to help
prevent the walls of the drill hole from collapsing inward; and suspend the cuttings for removal through the
drilling process. Water for HDDs is anticipated to be obtained from municipal sources. If necessary,
additional potential sources of water for HDDs may include other municipal systems, groundwater supply
wells, and/or approved surface waters. Additional additives that are approved by agencies may be needed
dependent upon viscosity readings. These additives will be determined by a mud engineer on site. The
Project will only use additives for HDDs that are certified for conformance with NSF
International/American National Standards Institute Standard 60, Drinking Water Treatment Chemicals —
Health Effects, which provides assurances that the product is safe for use in drinking water (NSF
International, 2018). These fluids will comply with state and federal requirements. HDD fluid will be
disposed of per the HDD Contingency Plan (Appendix I). Water containing mud, silt, drilling fluid, or other
2-22 March 2020

IT Mountain Valley Joint Permit Application Addendum
PIPELINE ut USACE — Wilmington District and NCDEQ
SAW-2018-008887
materials from equipment washing or other activities, will not be allowed to enter wetlands and waterbodies.
The bentonite used in the drilling process will be either disposed of at an approved disposal facility or
recycled in an approved manner. Once the hole has been sufficiently enlarged, a prefabricated segment of
pipe will be attached behind the reaming tool on the exit side of the crossing and pulled back through the
drill hole to the drill rig, completing the crossing. The Project will dispose of all HDD cuttings and fluids
at approved disposal facilities.
The primary advantage of the HDD method is that there is minimal planned disturbance of the surface
between the entry and exit points of the HDD (limited to the temporary deployment of telemetry cable and
water pipe), provided there is reasonable access to the entry and exit points for the drilling rig and fluids
handling equipment. Where the HDD and the adjacent right-of-way are in or near parallel alignment, the
pull section will be pre -fabricated within the construction right-of-way to the greatest extent practical;
minimal ATWS will be required for this pull section. In areas where pullback space is limited due to
topographic constraints, adjacent resources, encroachment, or other utilities, the pullback string may be
broken into several segments for assembly during the pullback activity. However, the process of breaking
an HDD in multiple pullback sequences significantly increases the amount of time the bore pits and
associated disturbance exist due to the time required for welding the seams mid -pull. This in turn can also
increase the potential for failure of the HDD due to pipe failure and borehole caving. Potential failures can
be avoided or mitigated by conducting geotechnical analysis prior to construction or by making appropriate
adjustments during operation of the HDD equipment.
In addition to the potential for an inadvertent return, the minimum bend radius of the pipe must also be
considered in design. Based on the conservative industry practice of calculating a bending radius using the
formula of 100 feet times a multiplier equivalent to the pipe outer diameter in inches for a HDD, for example
the allowable bending radius for 24-inch steel pipe is 100 feet times a multiplier of 24, which equals 2,400
feet. The bend radius will affect the catenary, or the curve formed where the pipe is hanging at the pullback
point. Topography, bend radius, and entry/exit angles will all be factors in the catenary height from the
ground. A pipeline depth of at least 25 feet below waterbodies for HDD construction will also be employed
based on minimizing the potential for inadvertent returns.
At a minimum, any HDD below a waterbody would be at least 2,400 feet long and therefore require 2,400
feet of straight stringing space without introducing additional risks. Additional factors to consider when
selecting the HDD crossing method practicality include significantly higher costs, duration to complete the
crossing, increased safety concerns, and increased workspace. Because of the complexities and variables
described above, HDD is not an appropriate crossing alternative for all waterbodies.
2-23 March 2020

IT Mountain Valley
- 1 -.:XwA- Y 375'
0 E I] S
❑ -
i
�I
it}
EUUIPIAENT-
1. SPOIL 7ATAMR. C x 20'
2. SWREh'. 9' x 12'
J. EIESUP: B' X 8'
4. 61UD RIG 6' x 25'
't:PPL1` TRBJLER= 0' x 25'
_. EriNY, Pir-. a' x 20'
1. °T'JRAGE 30' x 30'
8, VDICLE PARKING 15' X 50'
S. POWER UNIT- 5' x 1E1'
1D- MLL WIPE: 30' X 30'
11- CRME: a' x d'
12. DrdW%G MG- 8' X 45'
13. S F7,F' TRAILER: 8' Id 25'
ENTRY
PAINT
ODNCEPTUAL
PIPE PROFILE
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
OPPRcANATay 37,N
0
1"R =:El ❑ n n
IU
19�
Mkl,
EOLIPNENr:
1- SPCIL CONTAINER! 8' x 20'
2. SHANR. K X 12'
3. OE51ILTER; 8' Y 8'
4- MLa IdG: 8' x 25'
5. SUPPLr TRAILER! 8: x 25'
6. ExR PIT. 56 x 10'
B. Lf}ECLE %RMNG: 15' x $p'
SL OEWATEVIk':: UNT: 8' x 70'
10. PIPE TH410t B' X 4-9
PLAN
WATER80E1T
REOUIRED DEPTH
" FILE
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Figure 7. Horizontal Directional Drill Typical.
POINT
2-24 March 2020

IT Mountain Valley Joint Permit Application Addendum
PIPELINE,[ USACE — Wilmington District and NCDEQ
SAW-2018-008887
2.2.5 Aboveground Facilities
Construction activities and storage of construction materials and equipment will be confined within the
designated workspace areas associated with the aboveground facilities. Debris and waste generated from
construction will be disposed of as appropriate. Disturbed surface areas will be restored in a timely manner.
The facilities will be constructed in accordance with the Project construction standards and specifications
as more generally described in the paragraphs that follow.
The compression, piping and other equipment will be shipped to the sites by truck. The equipment will be
offloaded using cranes and/or front-end loaders. The equipment will then be positioned on the foundations,
leveled, grouted where necessary, and secured with anchor bolts, as required. Non -screwed piping
associated with the aboveground facilities will be welded, except where connected to flanged components.
Welders and welding procedures will be qualified in accordance with API standards. Welds in gas piping
systems will be examined using radiography, ultrasound, or other approved non-destructive examination
methods to ensure compliance with code requirements. Aboveground piping surfaces will be cleaned and
painted in accordance with the Project construction specifications. Paint inspection and cleanup will be
conducted in accordance with regulatory requirements and best engineering practices.
Components in high-pressure natural gas service will be tested prior to placing in service. Pressure testing
will follow all applicable federal and state requirements. Before being placed in service, controls and safety
equipment and systems including emergency shutdown, relief valves, gas and fire detection, and engine
over speed and vibration protection will be calibrated and tested.
2.2.6 Access Roads
New and existing roads will be used to provide access to the pipeline right-of-way during construction
and/or operation of the Southgate Project. Access road widths will be the minimum necessary to provide
access for construction equipment while maintaining safe travel conditions. Maintenance or upgrades may
be required on some of the existing roads prior to use by construction equipment. Upgrades may include
grading to prevent rutting, widening or placement of additional stabilization means including but not limited
to gravel or crushed stone on the existing surface to ensure safe travel conditions in uplands. Matting or a
similar material would be used for access roads through wetlands. A filter fabric will be laid down prior to
installing matting in order to facilitate restoration.
Existing culverts that are damaged or otherwise not properly functioning will be repaired or replaced with
an in -kind structure to ensure they are functional during construction activities. Permanent culverts or
temporary flumes installed as part of the Project will include measures to promote the safe passage of fish
and other aquatic organisms. The dimension, pattern, and profile of the stream above and below a culvert
will not be modified by altering the width or depth of the stream profile in connection with the construction
activity. The width, height, and gradient of a proposed culvert will be sufficient to pass the average historical
low flow and spring flow without adversely altering flow velocity. Access will be constructed such that
the length of the road minimizes impacts on waters of the United States and will be maintained as close as
possible to pre -construction contours and elevations.
2.3 RESTORATION
Following construction of the Southgate Project, the areas disturbed by construction will be restored to their
original grades, condition, and use, to the greatest extent practicable. The Project will complete restoration
in accordance with the Southgate Plan and Procedures, the Project -specific E&SCP, stormwater
2-25 March 2020

IT Mountain Valle+, Joint Permit Application Addendum
PIPELINE ut USACE — Wilmington District and NCDEQ
SAW-2018-008887
management plans (SWMP), the Jordan Lake Watershed Buffer Restoration Plan, applicable regulatory
approvals, and landowner agreements. Restoration will be considered successful if the disturbed surface
condition is similar to adjacent undisturbed lands, construction debris is removed (unless requested
otherwise by the landowner in upland areas), revegetation is successful, proper drainage has been restored,
and the appropriate federal and state agencies approve. The Project will reseed areas disturbed by
construction in accordance with and proposed seed mixes that will be developed for the Project and
provided in an additional submittal.
2.3.1 Pipeline
Upon completion of the pipeline installation, the surface of the right-of-way disturbed during construction
activities will be graded to match original contours and to be compatible with surrounding drainage patterns,
except at those locations where permanent changes in drainage will be required to prevent erosion, scour,
and possible exposure of the pipeline. Segregated topsoil will be replaced, and soils that have been
compacted by construction equipment traffic will be de -compacted. Permanent stormwater management
measures will be installed in accordance with the Project's SWMP. Temporary erosion control measures
may be left in place, where appropriate, until sufficient vegetative cover is re-established to prevent
significant erosion or sedimentation.
2.3.1.1 Uplands
In most upland locations, excluding actively cultivated cropland, herbaceous vegetative cover will be re-
established by spreading a grass seed and hydro or straw -mulch mixture over the disturbed surface. The
type of seed will be selected to match the mix required by applicable regulatory agencies, or as otherwise
requested by the landowner. Depending upon the time of year, a temporary seed mix may be broadcast or
drilled until a more permanent cover can be established. Steep slopes (e.g., stream banks) may require
additional stabilization using erosion control fabric, revetments, or sod. Vegetation success in these areas
will be monitored by the Project, and reseeding, fertilizing, hydroseed (where allowed), or other
supplemental revegetation measures may be implemented until the density and cover of non -nuisance
vegetation is similar in density and cover to adjacent undisturbed lands.
2.3.1.2 Wetlands
Original surface hydrology will be re-established in wetlands by backfilling the pipe trench and grading the
surface to pre -construction contours with equipment operating from timber mats or equivalent or using low -
ground -pressure tracked vehicles working in the spoil pile depending upon degree of soil saturation and the
bearing capacity. Segregated topsoil will be replaced in unsaturated wetlands. Once the trench is backfilled
and ground surface restored to its natural grade, the soils will be mechanically loosened to a depth of 12
inches, if necessary, and allowed to naturally revegetate. In emergent wetlands, the herbaceous vegetation
is expected to regenerate quickly (typically within one growing season). The Project will conduct
restoration and monitoring of wetland crossings in accordance with the Southgate Procedures to ensure
successful wetland revegetation. Wetland revegetation will be considered successful when the cover of
herbaceous and/or woody species is at least 80 percent of the type, density, and distribution of the vegetation
in adjacent wetland areas that were not disturbed by construction. Revegetation efforts will continue until
wetland revegetation is successful based on the Southgate Procedures and other applicable regulatory
approvals. If revegetation is unsuccessful, the wetlands will be seeded with appropriate native wetland
species in consultation with USACE and NCDEQ.
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2.3.1.3 Waterbodies
Cleanup and restoration activities commence as soon as practicable following completion of the waterbody
crossing. Waterbody substrate will be segregated from other soils and will be replaced as the uppermost
layer of backfill in the trench once the pipeline is laid. Excavated streambed material will be placed in
uplands to the extent practicable, and where not practicable will be placed on filter cloth or another semi -
impervious surface. Riparian areas that are disturbed will be restored to pre -construction or better
conditions. Original streambed and bank contours will be re-established for surface water and groundwater
flow, and mulch, jute thatching, or bonded fiber blankets will be installed on the stream banks, which are
preferential to plastic erosion control blankets because they reduce wildlife entrapment and are
biodegradable. Streambank grading would only occur where stream banks are incised to ensure the bank
is stable and tapered to tie back into the adjacent bank area. The Project will continue to evaluate if riprap
is necessary to maintain the stream contours to pre -construction grade and safety of the pipeline. Where
the flume technique is used, stream banks will be stabilized before removing the flume pipes and returning
flow to the waterbody channel. Additionally, the Project conducted a scour analysis on perennial streams
with widths greater than or equal to 10-feet, which are crossed by the pipeline to ensure that the placement
depth is sufficient to prevent erosion by expected high flows. Engineers also evaluated other streams to
ensure that they will not require additional controls to stabilize the streambed post -construction. Results of
this analysis are included in the Southgate Pipeline Stream Crossing Burial Recommendations ("Scour
Analysis") filed with FERC in October 2019 (FERC Accession No. 20191023-5022). A revised Scour
Analysis is currently being prepared and will be provided to NCDEQ in April 2020.
Seeding and planting of disturbed stream approaches will be completed in accordance with the Southgate
Procedures and Jordan Lake Watershed Buffer Restoration Plan after final grading, weather and soil
conditions permitting. Other Federal and State permit seeding requirements will be considered where
applicable. Where necessary, slope breakers will be installed adjacent to stream banks to minimize the
potential for erosion. Sediment barriers, such as silt fence and/or straw bales will be maintained across the
right-of-way until permanent vegetation is established. Temporary equipment bridges will be removed
following construction.
2.3.2 Access Roads
Previously existing access roads that were modified and used during construction will be returned to
original or better condition upon completion of the pipeline facilities installation. Temporary access roads
constructed specifically for the Project installation will be removed, the surface graded to original contours,
and the land restored to its original use unless otherwise requested by the landowner and approved by
NCDEMLR. Temporary erosion control measures will be removed upon final stabilization and approval
from applicable regulatory agencies and installation of permanent erosion control measures, if necessary.
2.3.3 Aboveground Facilities
Aboveground facilities will be fenced. The areas inside the fence at the aboveground facilities will be
permanently converted to industrial use. Most areas in and around the buildings, meters, and associated
piping and equipment will be covered with an approved stabilization method (typically crushed rock or
equivalent) to minimize the amount of maintenance required. Roads and parking areas may be crushed
rock, concrete, or asphalt. Other ground surfaces will be seeded with a grass that is compatible with the
climate and can be easily maintained. Temporary workspace areas outside the fence will be restored as
described above for the pipeline right-of-way.
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2.3.4 Contractor Yards
Upon completion of construction, all temporary facilities (e.g., trailers, sheds, latrines, pipe racks, fencing,
and gates) will be removed from the contractor yards. Unless otherwise requested by the landowner and
approved by NCDEMLR, each site will be graded to original contours and the land restored to its original
use, to the greatest extent possible. The site will be revegetated, permanent erosion control measures will
be installed, and temporary erosion control measures will be removed.
2.4 QUALITY ASSURANCE MEASURES
To ensure that construction of the facilities will comply with measures identified in the FERC Certificate
and applicable regulatory permits and clearances, the Project will include implementation details in its
construction drawings and specifications. Copies of permit requirements, known conditions and related
drawings will be added to the Construction Bid Package.
Consistent with the Southgate Plan and Procedures and the Project -specific E&SCP, environmental training
will be given to the Project personnel and to contractor personnel whose activities may impact the
environment during pipeline and aboveground facility construction. The level of training will be
commensurate with the type of duties of the personnel. All construction personnel from the Chief Inspector,
EI, craft inspectors, and contractor job superintendent to clearing crews, welders, equipment operators, and
laborers will be given the appropriate level of environmental training. The training will be given prior to
the start of construction and throughout the construction process, as needed. The training program will
cover job -specific permit conditions (NWP 12, 401 Water Quality Certification, NPDES, etc.),
contaminated sediment and groundwater management, health and safety, company policies, cultural
resource procedures, threatened and endangered species restrictions, the SPCC Plan (Appendix F), HDD
Contingency Plan (Appendix H), and any other pertinent information related to the Project. The Invasive
Species Plan will be provided at a later date. In addition to the EIs, all other construction personnel will
play an important role in maintaining strict compliance with all permit conditions to protect the environment
during construction.
To ensure quality assurance and compliance with mitigation measures, a Chief Inspector will represent the
Project assisted by another Inspector, and one or more craft inspectors. In addition, there will be at least
one EI who will report to the Chief Inspector, who in turn reports to the Construction Manager. The EI's
duties are consistent with those contained in Section II.B (Responsibilities of the Environmental Inspector)
of the Southgate Plan; the EI will be:
• Responsible for monitoring and documenting compliance with all mitigation measures required by
the FERC's Order and any other grants, permits, certificates, or other authorizing documents;
• Responsible for evaluating the construction contractor's implementation of the environmental
mitigation measures required in the contract or any other authorizing document;
• Empowered to order correction of acts that violate the environmental conditions of the FERC's
Order, or any other authorizing document (e.g., USACE Section 404 permit), including stop work
authority;
• A full-time position, separate from all other activity inspectors; and
• Responsible for maintaining status reports and training records.
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Copies of the Construction Drawing Package will be distributed to inspectors and to contractors'
supervisory personnel. If a contractor's performance is unsatisfactory, the terms of the contract will allow
for work stoppage and will require the contractor to begin remedial work.
The Project's engineering and construction departments are responsible for designing and constructing
certificated facilities in compliance with regulatory and contractual requirements and agreements. If
technical or management assistance is required, the responsible Construction Manager and/or Chief
Inspector will request assistance from the appropriate company department. The operations department
will be responsible for long-term Project maintenance and regulatory compliance once the Project is in-
service.
2.5 SCHEDULE
The order in which each facility will be constructed may vary, depending upon numerous factors, including
the receipt of necessary authorizations, the capabilities of each contractor, available work force, and
optimized logistics. The Southgate Project anticipates clearing to start in the first quarter of 2021 contingent
upon receipt of necessary approvals, and pipeline construction will begin in late 2020 to achieve a target
in-service date of Q4 2021. A preliminary construction schedule is provided below in Table 2-5.
Table 2-5
Construction Schedule for Major Components of the MVP Southgate Project
Component
Commence
Activity
Complete
Activity
Clearing
Q4 2020
Q1 2021
Pipeline Construction
Q4 2020
Q4 2021
Compressor Stations
Q1 2021
Q4 2021
Restoration
Q2 2021
Q4 2022
Hydrostatic Testing
Q4 2021
Q4 2021
Anticipated full in-service date of Q4 2021.
2.6 OPERATION AND MAINTENANCE
The Southgate Project will be operated and maintained in compliance with Department of Transportation
Pipeline and Hazardous Materials Safety Administration's regulations at 49 CFR Part 192, FERC
regulations at 18 CFR § 380.15, and maintenance provisions of the Southgate Plan and Procedures and its
Project -specific E&SCP. Operational activity on the pipeline will be limited primarily to vegetation
management within the permanent easement and inspection, repair, and cleaning of the pipeline. Periodic
aerial and ground inspections by the Project will identify:
• soil erosion that may expose the pipe;
• dead vegetation that may indicate a leak in the line;
• conditions of the vegetation cover and erosion control measures;
• unauthorized encroachment on the right-of-way, such as buildings and other substantial structures;
and
• other conditions that could present a safety hazard or require preventive maintenance or repairs.
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Following construction, certain areas along the pipeline alignment (and at aboveground facilities) will have
an associated permanent right-of-way or operational area. For pipeline facilities, the Project will maintain
a typical permanent right-of-way of 50 feet in width. Vegetation on the permanent right-of-way will be
maintained by mowing, cutting, and trimming. Herbicide treatment will only be used to control invasive
species, as necessary, and will not be allowed within 100 feet of a waterbody or wetland unless specifically
allowed by the appropriate federal or state agency.
In uplands, routine vegetation mowing or clearing over the full width of the permanent right-of-way will
occur no more than once every three years. However, to facilitate periodic corrosion/leak surveys, the
Project may clear a corridor not exceeding 10 feet in width centered on the pipeline at a frequency necessary
to maintain the 10-foot corridor in an herbaceous state. See Appendix C for a typical construction detail of
the maintenance corridor.
In wetlands and riparian buffers, routine vegetation mowing or clearing over the full width of the permanent
right-of-way will not occur. However, to facilitate periodic corrosion/leak surveys, the Project may clear a
corridor centered on the pipeline up to 10 feet in width at a frequency necessary to maintain the 10-foot
corridor in an herbaceous state. In addition, trees within 15 feet on either side of the pipeline may be
selectively cut and removed from the permanent right-of-way to ensure that root systems do not affect the
exterior coating of the pipeline.
2.7 FUTURE PLANS AND ABANDONMENT
The Project currently has no plans for either future expansion or abandonment of the facilities. Should the
Project propose any future expansion or abandonment of Project facilities, the Project will seek the
appropriate authorizations from FERC and other federal and state agencies as applicable.
2.8 ROUTE ALTERNATIVES ANALYSIS
Due to the linear nature of this Project, there are no practical alternatives that fulfill the project purpose,
while avoiding all impacts to surface waters and wetlands. Impacts have been avoided and minimized to
the extent practicable through the routing alternatives analysis discussed in this section, the right-of-way
area limitations discussed in Section 2.3.1, and the impact avoidance and minimization measures outlined
in Section 4.4.
During development of the Southgate Project, an extensive review of potential routes was evaluated to
identify viable corridors for placement of the pipeline. Potentially viable corridors were reviewed for a
variety of potential constraints including environmental impacts, effects on landowners, and
constructability and further refined to determine the most feasible route within the least impactful corridor.
One of the Project's primary objectives with respect to pipeline routing was to avoid or minimize, to the
extent possible, crossings of major population centers and significant environmental resources, including
waterbodies and wetlands. The Project also attempted to route its pipeline adjacent to existing rights -of -
way, where feasible, to minimize new land impacts. The Project used field reconnaissance, aerial
photography, topographic maps from the U.S. Geological Survey, and National Wetland Inventory maps
during the route identification and evaluation processes. Updated Appendix G (to be submitted in April of
2020) provides a cost analysis of wetland and waterbody crossing methods.
The Project evaluated four major route alternatives (including the preferred route) as part of the planning
and design process (See Appendix J). The evaluation was based on environmental and land use impacts, as
well as permanent easement acquisitions and overall Project costs. The primary objective of the evaluation
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was to develop the most direct route that could connect customers to the available supply system while
avoiding or minimizing potential adverse environmental impacts and engineering constraints to the greatest
extent practicable. The Project evaluated pipeline routing options based on potential adverse environmental
impacts, existing land usage, constructability, safety, and feasibility considerations.
The selection of the major route alternatives involves several steps.
• Development of routing criteria;
• Identification of potential routing alternatives;
• Collection of data relative to each alternative;
• Evaluation of potential environmental and land use impacts;
• Evaluation of routing alternatives against routing criteria; and
• Determination of the most cost-effective technical solution
The route best meeting the selection criteria was selected as the preferred route. The preferred route was
selected primarily for these reasons:
• Shortest length and, therefore, least area of land disturbance during construction and operation;
• Greatest percent of route collocated with existing rights -of -ways;
• Least mileage of forested land crossing; and
• Least area of forested land construction or operation impacts.
Minor Route Variations
The Project evaluated a 300 to 400-foot wide "study area" around the preferred route. The purpose of the
study was to allow for minor route deviations within the corridor to avoid or minimize impacts to sensitive
resources, including wetlands and waterbodies. The Project has currently identified 280 route variations
during preliminary routing, stakeholder outreach efforts, and landowner and/or and agency requested route
deviations. Of these, the Project has incorporated 191 of these into the proposed current preferred route.
Those that are relevant to avoiding or minimizing impacts to wetlands or waterbodies are summarized in
Table 2-6. Additionally, the Project has made specific adjustments in collaboration with the DEQ since the
initial November 2018 Application to address areas of concern and reduce impacts to wetlands,
waterbodies, and riparian areas. The updated tables and appendices in this addendum (to be submitted in
April of 2020) provides a list of additional non -perpendicular stream crossings that are being revised from
the conventional crossing method to the conventional bore method to further reduce riparian impacts within
the Jordan Lake Watershed.
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3.0 EXISTING SITE CONDITIONS
3.1 WETLAND AND WATERBODY DELINEATION
The Southgate Project performed a wetland and waterway delineation for the Project environmental survey
area that consisted of a typical 300 to 400-foot-wide corridor along the 47 miles of proposed pipeline. The
survey area included limits of additional temporary workspaces, above ground facilities, construction yards,
staging areas, and access roads. A typical 50-foot wide corridor centered over the proposed access road was
surveyed for all access roads. Overall, the survey area for the North Carolina portion of the Project
encompasses approximately 2,135 acres.
The wetland and waterbody delineation was conducted using a combination of the desktop and field
surveys. To date, the field surveys have covered over 93 percent (45.0 miles) of the North Carolina Project
survey area, where survey access was available. The remaining area where survey access was not available
was evaluated using existing data resources such as National Wetland Inventory (" NWP') maps, National
Hydrography Dataset ("NHD") maps, published US Department of Agriculture- Natural Resources
Conservation Service "USDA-NRCS" Soil Surveys for Rockingham and Alamance Counties, North
Carolina, and site specific aerial photography and Lidar data flown for the Project area in 2018. Project
scientists made observations of the estimated resources from adjacent tracts where survey access was
available, to the extent possible. Wetland and waterbody limits estimated using desktop analysis will be
field delineated when survey access is available. Wetlands and waterbody boundaries were identified based
on the interpretation of this data and typically represent an over -estimation of the extent of jurisdictional
resources. Details of the survey methodology and results, including data forms, wetland and waterway
delineation maps, and photographs, are provided in Appendix K (MVP Southgate Project — North Carolina
Wetland and Waterbody Delineation Report — March 2019 Addendum). The areas delineated via desktop
methods will be surveyed in the field when access becomes available.
3.1.1 Wetlands
Wetlands delineated to date in the North Carolina Project survey area are summarized in Updated Table 3-
1 (to be submitted in April of 2020) by resource ID, milepost, and type. None of the delineated wetlands
are isolated. The wetlands in the survey area are associated with stream and river floodplains or their
headwaters and include a combination of palustrine forested ("PFO"), palustrine scrub -shrub ("PSS"), and
palustrine emergent wetlands ("PEM"). Updated Table 3-1 summarizes the wetlands delineated (in the field
and by estimated) in the North Carolina Project survey area by watershed and Cowardin cover type.
3.1.2 Waterbodies
Waterbodies delineated to date in the North Carolina Project survey area are identified in Updated Table 3-
2, to be submitted in April of 2020. None of the delineated resources are isolated waterbodies and none are
classified as Section 10 waterways by the USACE-Wilmington District.
To determine whether impaired waterbodies will be affected by the Southgate Project, the Project reviewed
the North Carolina 303(d) lists that are included in USEPA Categories 4 and 5. Category 4 lists waterbodies
where TMDLs have been completed or cannot be completed due to the nature of the contamination, and
Category 5 lists waterbodies where TMDLs need to be developed by the state (USEPA, 2016b).
Similar to Virginia, the Project found that the majority of the waterbodies crossed by the Southgate Project
in North Carolina have not been assessed for impairment, or the data collected resulted in a "Category 3a —
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Inconclusive Data" designation. In North Carolina, the 303(d) list consists of only Category 5 designations.
According to the 2016 NCDEQ data, there are no designated impaired waterbodies crossed by the Project
in North Carolina.
Appendix A-2 of the Wetland and Waterbody Delineation Report (Appendix K) provides a summary of
each delineated waterbody, including resource ID, milepost, stream name, flow type, watershed, and
area/linear feet within the North Carolina Project survey area. Updated table 3-2 (to be submitted in April
of 2020) summarizes the waterbodies delineated in the Project survey area.
3.1.3 Preliminary Jurisdictional Determination
An application for a preliminary jurisdictional determination ("PJD") was submitted to the USACE-
Wilmington District in August of 2018. The Southgate Project has participated in several field review days
of the delineated resources with USACE and North Carolina Division of Water Resources ("NCDWW')
personnel on September 5th, I Ith and 25th, 2018. Additional field reviews with NCDWR took place on July
26th, 2019 and January 7th, 2020.
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4.0 WETLAND AND WATERBODY IMPACT ASSESSMENT
The majority of the wetland and waterbody impacts associated with construction and operation of the
Southgate Project will be temporary. While there will not be any permanent wetland fill, construction and
operation of the Project will require some permanent conversion of forested wetland to non -forested
wetland within the permanent easement. Temporary impacts in wetlands may include temporary loss of
vegetation; wildlife habitat disruption; soil disturbance associated with grading, trenching, and stump
removal; soil compaction; sedimentation and increased turbidity; and hydrological profile changes. Impacts
to forested wetlands may include conversion to emergent and/or scrub/shrub wetland types resulting from
tree removal within the construction and operational right-of-way.
A summary of the proposed impacts to wetlands and waters is provided in Updated Tables 4-1 and 4-2
respectively, by resource type and impact type (to be submitted in April of 2020). Details of the proposed
impacts for each individual wetland and waterbody crossing are provided in updated Appendix L-1 and L-
2, respectively (to be submitted in April of 2020), and depicted on the Updated Impact Drawings in
Appendix M (to be submitted in April of 2020). The following sections outline the potential impacts and
measures that the Project will implement to avoid and minimize impacts to the resources to the maximum
extent practicable.
4.1 WETLAND IMPACTS
4.1.1 Temporary Construction Impacts
The Project will temporarily impact wetlands during the construction process from typical pipeline
construction procedures, listed in updated table 4.1 and described in Section 2.4. The project is evaluating
parallel stream crossings and will provide site specific crossing information, including restoration details,
as a supplemental submittal in April of 2020.
The temporary wetland impacts will result from vegetation clearing, stump and root removal above the
proposed trench, excavation and stockpiling of wetland soils, and ground disturbance from construction
vehicles. The impacts will temporarily affect non -forested (PEM and PSS) wetland, and forested (PFO)
wetland per updated Table 4-1.
4.1.2 Permanent Conversion of Forested Wetlands to Non -forested Wetlands
As required by the Southgate Procedures, the Southgate Project will maintain no more than a 10-foot-wide
strip centered over the pipeline in an herbaceous state and will only remove woody vegetation within a 30-
foot-wide strip (15' on either side) centered over the pipeline. This will result in a 10-foot wide strip of
herbaceous vegetation centered over the pipeline flanked by a potential shrub (PSS wetland type) strip of
10-foot width on either side. Woody species removal from the 30-foot wide maintenance corridor would
be performed periodically as needed and would be done on a selective basis, only removing woody species
with potential to compromise the integrity of the buried pipeline. Maintaining this 30-wide maintenance
corridor is necessary for the safety and protection of the pipeline in accordance with the applicable federal
standards. This operational requirement would result in the conversion forested wetlands to emergent and/or
scrub/shrub wetland types in North Carolina per updated Table 4-1. Crossing of the pipeline through
forested wetlands has been minimized to the extent practicable through Project siting as described in Section
2.8.
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The Southgate Project will provide compensatory mitigation for the conversion of all forested wetland to
non -forested wetland through purchase of wetland mitigation credits at a 1:1 ratio from an approved
mitigation bank with a service territory covering the watershed where the impacts would occur.
4.1.2.1 Permanent Fill for Access Road
The Project will not require any permanent fill within wetlands or waterbodies for the use of temporary or
permanent access roads.
4.2 WATERBODY IMPACTS
4.2.1 Temporary Construction Impacts
The Project will temporarily impact waterbodies during construction as described in Section 2.4 and updated
Table 4-2. No single and complete project / crossing will exceed 300 linear feet of temporary waterbody
disturbance. These waterbodies will be restored to their pre -construction condition, as closely as possible,
after construction and will be monitored to ensure they remain stabilized and restoration is successful per
the Southgate Procedures.
4.2.2 Permanent Impacts
The Project will not result in any permanent impacts to waterbodies (Updated Table 4-2 — to be submitted
in April of 2020). As identified in Section 2.3.1, a Scour Analysis was completed for the Project in October
2019 and resulting stream burial depth recommendations were filed with FERC. A revised Scour Analysis
is currently being prepared and will be filed with NCDEQ in April 2020.
4.3 RIPARIAN BUFFER IMPACTS
The Jordan Lake Impoundment (Jordan Lake) was created in 1983 by damming the Haw River near its
confluence with the Deep River. Jordan Lake spans several county boundaries and supplies drinking water
to approximately 500,000 people and offers recreational opportunities (e.g. swimming, boating, fishing) to
residents (TCH, 2018, USACE, 2018). In December of 1963, the U.S. Army Corps of Engineers
("USACE") Wilmington District took stewardship of Jordan Lake, proposing an earthen dam with a multi-
level intake tower in the interest of flood control, water supply, water quality control, recreation and other
purposes (USACE, 2018). In a joint effort to improve the low water quality of Jordan Lake, the Wilmington
District and NCDWR have enacted the Jordan Lake Nutrient Strategy, consisting of the Jordan Lake Rules
that are a nutrient management strategy designed to restore the water quality in the lake by reducing the
amount of pollution entering upstream (15A NCAC 02B .0267). Specific issues addressed by the rules
include reducing pollution from wastewater discharges, stormwater runoff from new and existing
development, agricultural and fertilizer application (NCDWR, 2018). In an effort to further define the
Jordan Lake Nutrient Strategy program, a riparian buffer zone watershed upstream of Jordan Lake was
developed which outlines the stormwater and buffer permit program for the watershed. The Jordan Lake
watershed is divided into three Jordan subsheds, the Lower New Hope, Upper New Hope and the Haw
subshed (NCDWR, 2018).
Per the Jordan Supply Nutrient Strategy Buffer Rules (15A NCAC 02B .0267), protective buffers were
applied to all intermittent streams, perennial streams, lakes, reservoirs and ponds, excluding wetlands,
where the feature is approximately shown on any of the following references:
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(1) The most recent version of the soil survey map prepared by the Natural Resources Conservation
Service of the United States Department of Agriculture, and/or
(ii) The most recent version of the 1:24,000 scale (7.5 minute) quadrangle topographic maps
prepared by the United States Geologic Survey (USGS).
Features not shown on either reference are not subject to the buffer rules per the administrative code, and
as such, are not buffered on the Updated Impact maps in Appendix M.
Although Jordan Lake is located approximately 25 miles southeast of the southern extent of the Southgate
Project, the Project crosses the Jordan Lake riparian buffer zone watershed (Jordan Lake watershed),
specifically the Haw subshed, for a total of approximately 24 miles in Rockingham (4 miles) and Alamance
(20 miles) counties.
The Project will abide by state requirements / permit conditions for the Jordan Lake riparian buffer
("riparian buffer') zone watershed. Overall, the Project attempted to design all waterbody crossings
perpendicular or as close to perpendicular as practicable. For those crossings where the pipeline cannot be
installed at a perpendicular angle to the waterbody, the Project modified the construction approach and
technique such that the Project no longer requires a major variance from the Jordan Lake buffer rules (see
Updated Table 4.3 — to be submitted in April of 2020).
The riparian buffer applies to intermittent streams, perennial streams, lakes, ponds, estuaries and modified
natural streams within natural drainageways that are depicted on the most recent published version of the
soil survey map prepared by the Natural Resources Conservation Service or the 1:24,000 scale topographic
map prepared by the USGS (Appendix A). In September of 2018, July 26th, 2019 and January 7, 2020,
Project staff have visited a number of the mapped Natural Resources Conservation Service soil survey
streams with NCDWR staff in order to confirm presence/absence of these streams.
As outlined in 15A NCAC 02B.0267(7)(a), the Zone One buffer consists of a vegetated area that is
undisturbed except for allowed uses initiating at the bank of a waterbody and extending 30 feet horizontally.
The Zone Two buffer extends from the outer limit of the Zone One buffer and measures 20 feet horizontally,
which comprises the outer portion of the 50-foot buffer zone for waterbodies that qualify for the riparian
buffer protection within the portion of the Southgate Project area that is inside the Jordan Lake watershed.
The Southgate Project's temporary impacts within the riparian buffer zone are classified as either
"Allowable" or "Allowable with mitigation" uses for non -electric, utility line projects (NCDEQ, 2010a).
Therefore, the Project is seeking a buffer authorization for construction and operation -related impacts
within the Zone One and Zone Two buffers associated with jurisdictional waterbodies. Surface waters that
are exempt from the buffer requirements include man-made ponds and lakes that are not part of a natural
drainage way; ephemeral streams and ditches or other man-made water conveyances (15A NCAC 02B
.0267(5)). Proposed impacts to waterbodies in the Jordan Lake watershed subject to the riparian buffer
rules are summarized in Updated Table 4-3 — to be submitted in April of 2020 and in Updated Appendix M
(Impact Drawings — to be submitted in April of 2020).
4.3.1.1 Diffuse Flow Requirement
The Jordan Lake Rules state that `diffuse flow of runoff shall be maintained in the riparian buffer by
dispersing concentrated flow prior to its entry into the buffer and reestablishing vegetation'. To ensure
compliance with this requirement, the Project will implement its E&SCP during construction and adhere to
the Southgate Plan and Procedures. Both of these documents provide for stormwater best management
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practices during construction and detail post -construction stabilization and revegetation measures. In
addition, the Project will comply with applicable federal and state stormwater management requirements
and approvals.
4.3.1.2 No Practicable Alternatives
Since the use associated with the Project is designated as `allowable' or `allowable with mitigation',
Southgate is including a request for a `no practicable alternatives' determination. The Project is linear in
nature and, as such, cannot completely avoid impacts within the riparian buffer. Since the Project terminus
is located within the Jordan Lake watershed, there is no practical alternative that could avoid activities
within the buffers. As detailed within this narrative, the Southgate Project certifies that the Project meets
the following criteria for a determination of `no practical alternatives':
• The basic project purpose cannot be practically accomplished in a manner that would better
minimize disturbance, preserve aquatic life and habitat, and protect water quality;
• The use cannot practically be reduced in size or density, reconfigured or redesigned to better
minimize disturbance, preserve aquatic life and habitat, and protect water quality; and
• Best management practices shall be used if necessary to minimize disturbance, preserve aquatic
life and habitat, and protect water quality.
4.3.1.3 Compliance with Performance Standards
The Jordan Lake Rules provide for specific performance standards associated with Utility, non -electric
projects that cross streams at both perpendicular and non -perpendicular angles. The allowable use table
within the Jordan Lake Rules identifies 5 footnotes containing performance standards that are applicable to
the various types of projects. Footnote 2 is not applicable to utility projects. Footnote 3 pertains to the
installation of poles or aerial infrastructure within 10 feet of a waterbody. Since the Project is an
underground utility, this Footnote is not applicable.
Footnote 1 is applicable to utility, non -electric, other than perpendicular crossings with impacts in Zone
One. Based on site -specific conditions, engineering standards and construction / operational safety
considerations, the Project includes several waterbody crossings at angles outside of the range defined as
perpendicular (between 75 to 105 degrees) in the Rules (See Updated Table 4-3). Therefore, the
performance standards associated with Footnote 1 apply to the Project. The following is a listing of those
performance standards with information regarding Project compliance:
No heavy equipment is used in Zone One.
Due to the nature of natural gas pipeline construction, heavy equipment is required to prepare the
workspace, excavate and backfill the trench and hoist and lower the pipeline. The Project has reduced the
construction workspace within Zone One to the extent practicable while maintaining safe working
conditions.
• Vegetation in undisturbed portions of the buffer is not compromised.
In accordance with the Southgate Plan and Procedures, the Project is not allowed to exceed its
proposed workspace and limits of disturbance. The only vegetation removed within the buffer
will be located within the construction workspace. Vegetation within undisturbed portions of the
buffer will not be impacted.
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• Felled trees are removed by chain.
Joint Permit Addendum
USACE — Wilmington District and NCDEQ
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The Project will comply with this performance standard.
• No permanent felling of trees occurs in protected buffers or streams.
Trees will only be permanently removed within the 50-foot permanent right-of-way to allow for
periodic monitoring of the pipeline as well as maintenance during operation. Within wetlands
and riparian buffers, the Project will periodically maintain the vegetation through mechanical
mowing for a 10-foot section over the pipeline where the pipeline was not installed by horizontal
directional drill. As necessary, lasting until the pipeline is abandoned, trees will be selectively
removed within 15 feet of the pipeline to ensure that the root systems do not contact the pipeline
and potentially adversely affect the pipe coating and cathodic protection.
• Stumps are removed only by grinding.
Trees will be cut to ground level within the construction workspace within the Zone One riparian
buffer and only removed over the trenchline and in areas where allowing the stumps to remain in
place would result in a safety concern during construction. To the extent possible, stumps will be
ground below grade versus removed to allow for re -sprouting
• At the completion of the project the disturbed area is stabilized with native vegetation.
Within riparian buffers, herbaceous vegetative cover will be re-established by spreading a native
grass seed and hydro or straw -mulch mixture over the disturbed surface. The type of seed will be
selected to match the mix required by applicable regulatory agencies, or as otherwise requested by
the landowner. Depending upon the time of year, a temporary seed mix may be broadcast or drilled
until a more permanent cover can be established. Steep slopes (e.g., stream banks) may require
additional stabilization using erosion control fabric, revetments, or sod. Vegetation success in these
areas will be monitored by the Project, and reseeding, fertilizing, hydroseed (where allowed), or
other supplemental revegetation measures may be implemented until the density and cover of non -
nuisance vegetation is similar in density and cover to adjacent undisturbed lands.
• Zones One and Two meet the requirements of Sub -Items (7) and (8) of this Rule.
Sub -Items (7) and (8) establish the criteria for the riparian buffer zones (Sub -Item 7) and the Diffuse
Flow Requirements (Sub -Item 8). The Project will comply with the Diffuse Flow Requirements,
which is detailed further in Section 4.3.1.1.
Footnote 4 is applicable to utility, non -electric projects that included non -perpendicular crossings of streams
and other surface waters. The Project includes these types of crossings that do not intersect the surface
water at an angle of 75 to 105 degrees; therefore, the performance standards associated with Footnote 4
apply to the Project. The following is a listing of those performance standards with information regarding
Project compliance:
• In Zone One, all of the following BMPs for underground utility lines are used. If all of these BMPs
are not used, then the underground utility line shall require a no practical alternative evaluation.
The Project meets the identified BMPs below to the extent practicable and has also requested a no
practical alternative determination from NCDEQ.
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• Woody vegetation shall be cleared by hand. No land grubbing or grading is allowed.
The Project proposes to use mechanized equipment for removal of vegetation based on the extent
of workspace within the riparian buffer. Land grubbing and grading is required to prepare a safe
construction workspace and facilitate the installation of the pipeline. Compliance with this
performance standard cannot be completely met as vegetation must be cleared from the trenchline.
Following installation of the pipeline, disturbed areas will be returned to their preconstruction grade
and contours.
• Vegetative root systems shall be left intact to maintain the integrity of the soil. Stumps shall remain,
except in the trench where trees are cut.
The Project will comply with this performance standard with the exception of areas where stumps
need to be removed to ensure safe working conditions.
• Underground cables shall be installed by vibratory plow or trenching.
The pipeline will be installed via trenching or trenchless methods.
• The trench shall be backfrlled with the excavated soil material immediately following cable
installation.
The Project will backfill the trench with excavated soil material upon completion of installation.
• No fertilizer shall be used other than a one-time application to re-establish vegetation.
The Project will comply with this performance standard.
• Construction activities shall minimize the removal of woody vegetation, the extent of the disturbed
area, and the time in which areas remain in a disturbed state.
The Project will comply with this performance standard.
• Measures shall betaken upon completion ofconstruction and during routine maintenance to ensure
diffuse flow ofstormwater through the buffer.
The Project will be constructed and operated in accordance with the Southgate Plan and Procedures,
the Project -specific E&SCP, and applicable permits regarding construction and post -construction
stormwater management.
• In wetlands, mats shall be utilized to minimize soil disturbance.
The Project will comply with this performance standard and will utilize mats in all wetlands that
are saturated or inundated.
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4.3.1.4 Impact Mitigation
Based on the table of uses within the Jordan Lake Rules, the Project will be regulated under two uses that
are allowable with mitigation: (1) Utility, non -electric, perpendicular crossing of streams and other surface
waters that disturb greater than 40 linear feet but equal to or less than 150 linear feet of riparian buffer with
a maintenance corridor greater than 10 feet in width (applicable in both Zone 1 and Zone 2); and (2) Utility,
non -electric, other than perpendicular crossings with impacts located within Zone 1. Based on consultation
with NCDEQ, the mitigation ratios for Project -related impacts within Zone 1 are 3 to 1, and 1.5 to 1 in
Zone 2 for (1) Utility, non -electric, perpendicular crossing of streams and other surface waters, and the
mitigation ratios for Project -related impacts within Zone 1 are 3 to 1, and allowable without mitigation in
Zone 2 for (2) Utility, non -electric, other than perpendicular crossings. Updated riparian buffer impacts
and associated mitigation estimates are provided in Updated Table 4-3. The Project will continue to consult
with NCDEQ regarding the approved form(s) of buffer mitigation for the Project.
4.4 IMPACT AVOIDANCE AND MINIMIZATION MEASURES
Where impacts to wetlands and waterbodies cannot be avoided, the Southgate Project will seek to minimize
impacts through use of the following measures, as applicable:
• Clearly marking wetland and waterbody boundaries with signs and flagging in the field prior to the
start of construction;
• Limiting the construction right-of-way width to 75-feet through wetlands and waterbodies (unless
alternative, site -specific measures are requested by the Project and approved by the FERC and other
applicable agencies) and extending this reduced width 50 feet on each side of the resource;
• Limiting the operation of construction equipment within wetlands to only equipment essential for
clearing, excavation, pipe installation, backfilling, and restoration;
• Cutting trees to grade, and only removing stumps from directly over the trench, or where safety
concerns dictate otherwise, thus allowing existing vegetation to recover more rapidly in the
remainder of the right-of-way once the equipment mats and spoil piles have been removed;
• Installing and maintaining sediment barriers, such as silt fences or other approved barriers
throughout the construction process per the Southgate Plan and Procedures and Project -specific
E&SCP;
• Preventing the compaction and rutting of wetland soils by operating equipment off of equipment
mats or equivalent in wetlands that are not excessively saturated;
• Restricting grading in wetlands to the area directly over the trench, except where necessary for
safety concerns;
• Locating ATWS at least 50 feet away from wetland and waterbody boundaries (unless alternative,
site -specific measures are requested by the Project and approved by the FERC and other applicable
agencies);
• Selecting the most appropriate FERC-approved crossing procedure, based on site specific
conditions at the time of crossing;
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• Dewatering the trench, if needed, in a manner designed to prevent heavily silt -laden water from
entering a waterbody or undisturbed portions of wetlands within and adjacent to the Project limits;
• Segregating topsoil from the trench in non -saturated wetlands and returning topsoil to its original
location during backfilling to avoid changes in the subsurface hydrology and to promote re-
establishment of the original plant community by replacing the seed bank found in the topsoil;
• Placing excavated soils in wetlands on filter cloth, mats, or similar semi -permeable surface to avoid
mixing of with underlying materials and stabilizing the soils with filter cloth, straw bales or other
appropriate measure to prevent re-entry into adjacent wetlands or waters;
• Limiting storage of excavated soil material in wetlands to no longer than 30 days after the pipe has
been laid in the trench, without prior approval from the USACE;
• Installing trench breakers or trench plugs at the boundaries of wetlands, as needed, to prevent
draining of wetlands;
• Backfilling the ditch with the spoil excavated from the wetland;
• Spreading segregated topsoil over the area from which it was stripped and restoring the ground
surface to approximate pre -construction contour;
• Mechanically loosening the upper 12 inches of soils backfilled in wetlands;
• Seeding wetland areas that are not inundated with annual rye to provide soil stabilization while
allowing the natural seedbank to revegetate the wetland area.
• Seeding wetlands with appropriate native wetlands species if natural revegetation is not successful;
• Removing all equipment mats, debris, or other material from the wetlands and waterbodies after
construction;
• Aligning the crossings as close to perpendicular to the axis of the waterbody channel as engineering
and site -specific conditions allow;
• Limiting the operation of construction equipment within waterbodies to only equipment essential
for clearing, excavation, pipe installation, backfilling, and restoration;
• In the event that riprap is required for bank stabilization purposes, the Project will adhere to the
general conditions;
• Installing temporary bridges for equipment crossings over channels with flowing water and
ensuring they are constructed and maintained to allow unrestricted flow and to prevent soil from
entering the waterbody;
• Limiting crossing of waterbodies to clearing equipment and equipment necessary for installation
of bridges prior to bridge installation;
• Remove temporary equipment bridges as soon as practicable after permanent seeding.
• Aligning culverts to prevent bank erosion or streambed scour. If necessary, install energy
dissipating devices downstream of the culverts;
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• Adherence to required time of year construction restrictions. If adherence to time of year
restrictions is not possible, notification will be provided on a case -by -case basis to the applicable
agency with a request for a modification or waiver of the timing restriction;
• Adherence to the Southgate Plan and Procedures and applicable permit requirements;
• Adherence to NWP 12 terms and conditions (see Updated Appendix N).
• Developing and adhering to a Project specific SPCC plan; and
• Use of independent qualified EI's through the construction process to ensure construction adhered
to Southgate Plan and Procedures and application permit terms and conditions.
• Prohibiting the use of live concrete as a building material such that wet concrete does not come
into contact with water;
• Prohibiting the use herbicides or pesticides within 100 feet of a wetlands or waterbodies, unless
specified or approved by a federal or state agency;
• Prohibiting the storage of chemicals, fuels, hazardous materials, and lubricating oils within 100 feet
of a wetland;
• Prohibiting parking and/or fueling of equipment within 100 feet of a wetland; unless the
Environmental Inspector determines there is no reasonable alternative, and appropriate steps (such
as secondary containment structure) are taken;
• Conducting annual monitoring of wetlands and waterbodies and performing maintenance activities,
as needed, until the wetlands and waterbodies are successfully restored;
• Preventing the invasion or spread of undesirable exotic vegetation according to a project -specific
invasive plant species management plan;
• The Project will conduct pre -construction testing of all private wells located within 150 feet of the
construction workspace. The Project will conduct post -construction tests if requested by a
landowner who had a pre -construction test (See Appendix O — Water Resources Identification and
Testing Plan).
Specific measures to minimize or avoid impacts to waterbodies for the dry or trenchless waterbody crossing
methods proposed include:
Dam and Pump
• Sufficient pumps, including on -site backup pumps, will be used to maintain downstream flows;
• Pumps will be placed in secondary containment and properly aligned to prevent streambed scour
at pump discharge;
• Dams will be constructed with materials that prevent sediment and other pollutants from entering
the waterbody;
• Pump intakes will be screened to minimize entrainment of fish; and
• Dams and pumps will be continuously monitored while in use to ensure proper operation
throughout the waterbody crossing.
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• In the event that the crossing is dry at the time of construction, this equipment will still be available
in the event that conditions change and the waterbody begins to flow.
Flume
• Sand bags, sand bag and plastic sheeting diversion structures, or the equivalent will be used to
develop an effective seal and to divert stream flow through the flume pipe;
• Flume pipes will be installed after blasting (if necessary), but before trenching;
• Flume pipes will remain in place until trenching, pipe laying, backfilling, and initial streambed
restoration efforts are complete;
• Flume pipes will be properly aligned to prevent bank erosion and streambed scour; and
• All flume pipes and dams that are not part of the equipment bridge will be removed as soon as final
cleanup of the streambed and bank is complete.
Cofferdam
• Hydrographic studies of the waterbody
• Sand bags, sand bag and plastic sheeting diversion structures, or the equivalent will be used to
develop an effective seal
Conventional Bore
• Desktop analysis of the water table
HDD
• Implementation of HDD Contingency Plan (if needed).
4.4.1 Stormwater Management and Diffuse Flow Plan
Stormwater permit applications and associated Erosion and Sediment Control plans are currently being
developed by the Project, and the initial applications were submitted in January of 2020. The Project team
submitted a diffuse flow plan in March of 2020 as part of the Erosion and Sediment Control plans that will
be submitted to the appropriate local government and NCDWR responsible for review and approval of
construction Stormwater permitting.
4.4.1.1 Stormwater Management Plan
Stormwater permit applications and associated Erosion and Sediment Control plans are currently being
developed by the Project, and initial applications were submitted in January of 2020. The Project team will
develop a storm water management plan, where required, as part of the Erosion and Sediment Control plans
that will be submitted to the NCDEMLR, as applicable, who is responsible for review and approval of
construction stormwater permitting.
4.4.1.2 Certified Local Government Stormwater Review
Stormwater permit applications and associated Erosion and Sediment Control plans are currently being
developed by the Project, and the initial round of applications was submitted in January of 2020. The Project
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will develop an Erosion and Sediment Control plan that will be submitted to the appropriate local
government or NCDEMLR, as applicable, responsible for review and approval of construction stormwater
permitting.
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5.0 ADDITIONAL SUPPORTING INFORMATION
5.1 ENVIRONMENTAL DOCUMENTATION
The Project filed an application with FERC for a Certificate of Public Convenience and Necessity under
Section 7(c) of the Natural Gas Act on November 6th, 2018 (FERC Docket No. CP19-14-000, Accession
No. 20181106-5159). As a part of the FERC filing process, a Final Environmental Impact Statement
("FEIS") prepared by the FERC for the Southgate Project was issued for public review and comment on
February 14, 2020. The FEIS includes a comprehensive cumulative impacts analysis and an alternatives
analysis. FERC concluded that the currently proposed route (i.e., the one included in this revised
application) is the preferred alternative. Any additional documents will be filed as a supplemental that are
required to support this joint permit application.
5.2 VIOLATIONS
This section is not applicable to the Project as it consists of new construction. See Section F2 of the Joint
Permit Application Form for additional information.
5.3 CUMULATIVE IMPACTS
The Southgate Project has potential to cause cumulative effects to the wetlands or waterbodies from the
incremental consequences of the Project when added to other past, present, and reasonably foreseeable
future actions, regardless of what agency or person undertakes such other actions. The scope of the
cumulative effects analysis in this permit application is limited to direct or indirect effects on wetlands or
waterbodies from projects having potential to affect surface waters within the same HUC 10 or 12 as the
Southgate Project. The draft EIS, which includes a comprehensive cumulative impacts analysis, was issued
by FERC on July 26ffi, 2019.
Projects included in this assessment were limited to those with publicly available information pertaining
the proposed undertaking and potential impacts. Sources of information used to collect data about relevant
projects included federal, state, and local agencies permitting databases or websites. Projects with potential
cumulative impacts on wetlands or waterbodies within the North Carolina portion of the Southgate Project
area are listed in Table 5-1.
The Southgate Project need originated from a forecasted growing demand in the region of the Project in
North Carolina. This is an open access pipeline; therefore, other companies have the option to request gas
service from the pipeline system. An increase in demand beyond the current scope would likely require
modifications to the pipeline and/or its facilities. DENC solicited interest because it requires additional
pipeline capacity to meet forecasted incremental demand on its distribution system. Over the past four
years, DENC has experienced a 15 percent increase in peak daily throughput on its system. This trend will
carry forward into the future, as DENC expects its design day requirements to increase an additional 11
percent over the next five years. This past, present, and future demand growth on DENC's system reflects,
at least in part, the substantial population increase in North Carolina. North Carolina's population is
expected to increase by nearly 2 million people between 2020 and 2035. In Alamance County, where the
project terminates, the population is anticipated to grow approximately 11 percent from July 2020 to July
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IT Mountain Valley Joint Permit Addendum
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2029.10 Secondary impacts as a result of this Project are currently anticipated through new developments
that will be serviced by DENC (e.g., residential communities, industrial facilities). Construction of these
developments could affect surface waters or wetlands that would not occur if the Project were not built as
the result of a newly available natural gas supply. The potential water quality impacts from any induced
new development in the Roanoke River Basin and Cape Fear River Basin will be mitigated by federal and
state specific permitting requirements, and often including municipal stormwater management programs.
If the Project were not constructed, it is likely that at least some of the forecasted growth would still occur
without a new gas supply. Future expansion plans are not discussed because Mountain Valley has no plans
to expand the pipeline beyond the terminus at the Haw River Interconnect in Graham, North Carolina.
Cumulative effects on surface water resources affected by the Project would be limited to waterbodies that
are affected by other projects located within the same major watersheds. No permanent diversions or dams
are planned, so any impacts from construction on surface waters would be temporary. The greatest potential
impacts of pipeline construction on surface waters would result from an increase in sediment loading to
surface waters and an increase in internal sediment loading due to channel/floodplain instability as a result
of a change in erosion deposition patterns. Each of the project proponents will minimize these effects by
implementing wetland and waterbody construction and mitigation measures, including erosion control
measures by complying with applicable federal and state permit requirements.
Construction of the Project facilities will result in temporary impacts to wetlands. However, each proponent
for the projects listed in Table 6-1 that affects wetlands will be required, by the terms and conditions of
their respective Section 404 permits, to provide compensatory mitigation for unavoidable wetland impacts.
The cumulative effect on water resources and wetlands will be temporary and minor.
The primary factors associated with the Southgate Project that will minimize its contribution to cumulative
impacts are as follows:
• The impacts resulting from the Project pipeline facilities will primarily be short-term and constitute
temporary impacts associated with construction.
• Approximately 34 percent of the Project pipeline facilities will be parallel to existing utility
corridors and other rights -of -way; thereby minimizing impacts associated with construction.
• The Project has been designed to avoid and minimize impacts to the extent practicable and will
implement various plans and techniques to ensure potential impacts are further minimized (e.g.,
Project -specific E&SCP and SWMP).
• The Project E&SCP and SWMP will address post -construction stormwater management associated
with the permanent right-of-way.
• In addition to the cumulative Project (i.e., all Project facilities including interconnect/meter
stations) and other project effects on water resources and wetlands, the Project assessed cumulative
impacts from the Project interconnect / meter stations along the proposed pipeline. Three
interconnect/meter stations are proposed for the Project in North Carolina: 1) LN 3600 Interconnect
at MP 28.2RR in Rockingham County; 2) T-15 Dan River Interconnect at MP 30.4 in Rockingham
10 See North Carolina Office of State Budget and Management population projections, available at:
https://files.nc.gov/ncosbm/demog/countytotals_populationoverview.ht nl
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IT Mountain Valley PIPELI
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County; and, 3) T-21 Haw River Interconnect at MP 73.2RR in Alamance County. Of these, only
the LN 3600 Interconnect and the T-15 Dan River Interconnect impact wetlands and waterbodies.
Additionally, the LN 3600 and T-15 Dan River Interconnect are located within the same HUC 10
and 12 watersheds (Cascade Creek — Dan River and Town Creek — Dan River, respectively).
Wetland impacts from these two interconnects are temporary and include 0.54 acre of PEM wetland
and 0.15 acre of PFO wetland. The wetlands are not located within the operational footprint of the
facilities, no permanent fill will be placed in wetlands, and the wetlands will be restored post
construction in accordance with the Project Wetland and Waterbody Construction and Mitigation
Procedures and North Carolina Erosion and Sediment Control Plan.
Additionally, one ephemeral stream (S-1318-38) will be impacted by the temporary construction
workspace for the T-15 Dan River Interconnect. The Project will implement its Wetland and
Waterbody Construction and Mitigation Procedures and its North Carolina Erosion and Sediment
Control Plan, to minimize impacts on the stream. The stream will be restored post -construction
and no permanent impacts on the stream will result from operation of the T-15 Dan River
Interconnect. Based on the minor amount of wetland resources affected, and that no permanent
impacts or conversion of wetland is proposed, construction of the Project interconnect/meter
stations in North Carolina would not result in cumulatively significant impacts on wetland or
waterbody resources.
5-3 March 2020

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M Mountain Valley Joint Permit Addendum
T PIPELINE �t USACE — Wilmington District and NCDEQ
SAW-2018-008887
5.4 SEWAGE DISPOSAL
The Project does not include a wastewater disposal system; therefore, this section is not applicable.
5.5 ENDANGERED SPECIES AND DESIGNATED CRITICAL HABITAT
The Endangered Species Act (ESA) of 1973 (16 United States Code A-1535-1543, P.L. 93-205) provides
for the listing, conservation, and recovery of endangered and threatened species of plants and wildlife.
Under the ESA, plants and animals provide aesthetic, ecological, educational, historic, and scientific value
to the United States. The US Fish and Wildlife Service (USFWS) is mandated to monitor and protect all
federally listed freshwater and terrestrial species, whereas the National Marine Fisheries Service (NMFS)
is responsible for marine species. A federally listed endangered species is any species in danger of
extinction throughout all or a significant portion of its range. A federally listed threatened species is any
species likely to become an endangered species within the foreseeable future throughout all or a significant
portion of its range.
The ESA also provides protection for "critical habitat" that, as defined by the USFWS, are (1) specific areas
within the geographical area occupied by the species, at the time of listing, on which are found those
physical or biological features essential to the conservation of the species and which may require special
management considerations or protections; and (2) specific areas outside the geographical area occupied
by the species at the time it is listed and are determined to be areas essential for the conservation of the
species.
Under provisions of the ESA, all states were granted the authority to enact their own endangered species
protection policies. The North Carolina Endangered Species Act (G.S. 113-331 to 113-337 Act 25) states
that the NCWRC is the regulatory authority over state -listed endangered, threatened, or species of special
of concern. The regulation allows the NCWRC to adopt the federal list of endangered and threatened
species and develop a list of state "protected species." State protected species are separated into three
separate categories; North Carolina Endangered, North Carolina Threatened, and North Carolina Special
Concern. The definitions are as follows:
North Carolina Endangered: "Any native or once -native species of wild animal whose continued existence
as a viable component of the State's fauna is determined by the Wildlife Resources Commission to be in
jeopardy or any wild animal determined to be an "endangered species" pursuant to the Endangered Species
Act."
North Carolina Threatened: "Any native or once -native species of wild animal that is likely to become an
endangered species within the foreseeable future throughout all or a significant portion of its range or one
that is designated as a threatened species pursuant to the Endangered Species Act.
North Carolina Special Concern: "Any species of wild animal native or once native to North Carolina that
is determined by the Wildlife Resources Commission to require monitoring but that may be taken under
regulations adopted under the provisions of Article 25."
5.5.1 Consultation
The Southgate Project reviewed USFWS online Information for Planning and Conservation (IPaC) system
and requested records of any known federally listed, state -listed, rare or special concern species within the
Project area from the United States Fish and Wildlife Service (USFWS), North Carolina Wildlife Resource
5-14 March 2020

IT Mountain Valley Joint Permit Addendum
PIPELINE,` USACE — Wilmington District and NCDEQ
SAW-2018-008887
Commission (NCWRC), and North Carolina Natural Heritage Program (NCNHP). The Project submitted
listed bat, plant, and freshwater mussel survey plans detailing locations and methods to the applicable
agencies for approval. Similar study plans for other taxonomic groups may be developed as necessary,
following further coordination with federal and state agencies. Concerns regarding nesting eagle and
colonial nesting birds are also addressed herein.
5.5.2 Findings
Based on initial consultation with the USFWS, NCWRC, and NCNHP and review of spatial data provided
by NCNHP, a total of 10 federally listed (8 endangered and 2 threatened),14 state listed (4 state endangered,
2 state threatened, and 8 special concern); and 4 state rare species were identified that could potentially
occur within 2 miles of the Project area.
5.5.3 Wildlife Species
Based on coordination with the USFWS Raleigh and Gloucester Field Offices and NCWRC, nine species
of bats are of concern in North Carolina, including three federally endangered bat species: Indiana bat
(Myotis sodalis), gray bat (Myotis grisescens), Virginia big -eared bat (Corynorhinus townsendii
virginianus), and one threatened species, northern long-eared bat (Myotis septentrionalis); one state
threatened species, Rafinesque's big -eared bat (Corynorhinus rafinesquii rafinesquii); and four state special
concern species, including eastern big -eared bat (Corynorhinus rafinesquii macrotis), eastern small -footed
bat (Myotis leibii), Florida yellow bat (Lasiurus intermedius floridanus), and southeastern bat (Myotis
austroriparius). None of these is known to occur in Rockingham or Alamance counties. Based on lack of
bat survey data available within the Project area, the Project proposed targeted mist netting and acoustic
surveys in accordance with 2018 Range -wide Indiana Bat Survey Guidelines (USFWS 2018) as a voluntary
conservation measure. In consultation with USFWS and NCWRC, the Project submitted a revised study
plan detailing survey type, effort, and locations to the USFWS, NCWRC and VDGIF on July 24, 2018 with
a request for concurrence and site -specific authorization. Written study plan concurrence was received
from the USFWS Raleigh Field Office and NCWRC on July 24, 2018 and August 3, 2018, respectively.
Fifty-two mist net sites (minimum of 6 net nights per site) and 11 acoustic survey sites (minimum of 2
detector nights per site) were completed between July 13 and August 14, 2018. Three hundred and twenty
complete and 114 partial net nights resulted in the capture of 551 bats, including 344 eastern red (Lasiurus
borealis), 153 big brown (Eptesicus fuscus), 37 evening (Nycticeius humeralis), 11 Seminole (Lasirus
seminolus), 3 tri-colored (Perimyotis subflavus), 2 hoary (Lasiurus cincereus), and 1 Mexican free -tailed
(Tadarida brasiliensis). Winter habitat (e.g., portals) was assessed concurrently with other environmental
surveys from June 1 through August 7, 2018 and was not found within the Project study corridor. Based
on the lack of species occurrence during summer sampling, all federally listed species are assumed absent
or present in such low density as for impacts to be inconsequential and Federal requirements for the Project
under Section 7(a)(2) of the ESA are met.
The Project is within geographic ranges of the bald eagle (Haliaeetus leucocephalus) and golden eagle
(Aquila chrysaetos), which are protected under the Bald and Golden Eagle Protection Act of 1940 (16 U.S.
Code 668-688d). A review of the North Carolina Natural Heritage Program database for bald and golden
eagles did not identify element occurrences in Rockingham or Alamance counties. Prior to construction,
the Project intends to conduct an aerial survey in the winter of 2019-2020 for nesting eagles and colonial
nesting bird rookeries within 1 mile of the Project. If eagle nests are identified within 0.5 mile of Project
activities, the Project will implement the USFWS Bald Eagle Management Guidelines (USFWS 2007). If
5-15 March 2020

M Mountain Valley Joint Permit Addendum
T PIPELINE,` USACE — Wilmington District and NCDEQ
SAW-2018-008887
colonial nesting birds are observed during survey, the Project will cease all activities within a buffer of 0.5-
mile around each rookery between February 15 and July 30. Implementation of these measures will avoid
impacts on eagles and colonial nesting birds.
Two state rare invertebrates were identified by NCNHP, including helicta satyr (Neonympha helicta) and
coppery emerald (Somatochlora georgiana). Surveys for these species were not requested; however,
implementation of the Southgate Plan & Procedures and the Project's Invasive Species Control Plan will
minimize impacts to these species.
Five federally listed aquatic species were identified during consultation and review of the NCNHP database,
including the endangered Roanoke logperch (Percina rex), Cape Fear shiner (Notropis mekistocholas), and
James spinymussel (Parvaspina collina) and the threatened yellow lance (Elliptio lanceolata). On October
11, 2018 the Atlantic pigtoe (Fusconaia masoni) was proposed for listing as threatened with a 4(d)
designation. In addition, critical habitat for the Atlantic pigtoe was proposed in the Dan River drainage;
however, the Project does not cross proposed critical habitat for Atlantic pigtoe nor any federally listed
aquatic species.
5.5.4 Aquatic Species
Five state listed species were identified, including four state endangered freshwater mussels: yellow
lampmussel (Lampsilis cariosa), green floater (Lasmigona subviridis), Carolina creekshell (Villosa
vaughaniana), Savannah lilliput (Toxolasma pullus); and two state threatened freshwater mussels: eastern
lampmussel (Lampsilis radiata) and creeper (Strophitus undulatus). Four special concern species include
the notched rainbow (Villosa constricta), Greensboro burrowing crayfish (Cambarus catagius), mole
salamander (Ambystoma talpoideum), and four -toed salamander (Hemidactylium scutatum). Three state
rare species include: riverweed darter (Etheostoma podostemone), eastern creekshell (Villosa delumbis),
and Carolina ladle crayfish (Cambarus davidi).
Early coordination with USFWS and NCWRC identified three waterbodies known or likely to harbor
Roanoke logperch and rare mussel species, including the Dan River, Cascade Creek, and Wolf Island Creek.
The Project is proposing to use HDD or conventional bore methods to cross these waterbodies to avoid
instream impacts on federal and state listed fish and mussel species. During consultation, NCWRC also
requested HDD or conventional bore of Deep Creek to avoid impacts on eastern lampmussel. The Project
is proposing the use of HDD or conventional bore at the Deep Creek crossing.
NCWRC requested surveys for mussel streams and identified 17 streams (21 crossings) for survey.
NCWRC and USFWS reviewed the Project's mussel study plan and provided comments on September 20,
2018. Two stream crossings were later avoided due to alignment shifts, resulting in a revised total of 19
stream crossings requiring mussel survey. Surveys were authorized to commence as soon as possible;
however, surveys were cancelled for the fall 2018 due to Hurricane Florence and restricted access to survey
sites. Freshwater mussel surveys are scheduled for 2019, and results of these surveys will be submitted to
USFWS and NCWRC for review and comment.
As of July 2019, mussel surveys have been completed in 10 stream crossings of which 2 stream crossings
(i.e., Dan River and Stony Creek) resulted in the collection of live mussels. Neither state listed nor federally
listed mussel species have been collected. Restricted land access has prevented access to the remaining 9
stream crossings. Upon completion of 2019 field surveys, results will be submitted to USFWS and NCWRC
for review and comment and filed with FERC.
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The Project will implement and strictly adhere to applicable federal and state erosion and sediment
control/storm water management laws and regulations. If live native freshwater species are observed during
surveys, mussels will be relocated prior to construction in coordination with NCWRC. If federal species
are observed during survey, the Project will notify USFWS and evaluate appropriate avoidance and
minimization measures. Measures taken to avoid and minimize impacts on federal listed species also benefit
state species and unlisted species. The Project is committed to working with the agencies to determine
applicable avoidance, minimization or mitigation strategies to minimize impacts to these species.
The NCWRC requested surveys for the Greensboro burrowing crayfish within 200 feet of any mapped
stream, both intermittent and perennial in the Haw River basin; and requested surveys for Carolina ladle
crayfish in all first to third order streams in the Dan and Haw river basins. The Project is evaluating potential
habitats and continues to coordinate with NCWRC. Implementation of the Southgate Plan & Procedures
and strict adherence to applicable federal and state erosion and sediment control/storm water management
laws and regulations will minimize impacts to these species.
Surveys for Carolina ladle crayfish are concurrently planned at mussel survey stream locations identified
as first to third order stream crossings. In total, Carolina ladle crayfish surveys are anticipated at 17 total
stream crossings. As of July 2019, Carolina ladle crayfish surveys have been completed at 8 stream
crossings of which all stream crossings (100%) resulted in the collection of live Carolina ladle crayfish
individuals. Restricted land permission has prevented access to the remaining 9 stream crossings. Upon
completion of 2019 field surveys, results will be submitted to USFWS and NCWRC for review and
comment and filed with FERC.
The NWCRC requested a desktop habitat evaluation of potential habitats of the four -toed and mole
salamanders. The Project is evaluating potential habitats and continues to coordinate with the NCWRC.
Implementation of the Southgate Plan & Procedures and strict adherence to applicable federal and state
erosion and sediment control/storm water management laws and regulations will minimize impacts to these
species, including abiding by applicable time of year construction restrictions.
5.5.5 Plant Species
Consultation identified three federally endangered plants, including small whorled pogonia (Isotria
medeoloides), smooth coneflower (Echinacea laevigata), and Schweinitz's sunflower (Helianthus
schweinitzii). A study plan was submitted to USFWS and NCWRC on July 17, 2018, and concurrence was
received from USFWS on August 21. A desktop assessment identified 261 acres of potential habitat of
federal listed plants along the Project. Surveys for Schweinitz's sunflower were determined to be
unnecessary following consultation with representatives of NCWRC on December 2, 2018.
Small whorled pogonia is best surveyed May -July when in flower; smooth coneflower can be surveyed
between June -October. Surveys were conducted between July and September 2018. No individuals of the
target species were observed; however, several small whorled pogonia potential habitats were flagged for
re -survey in summer 2019. Due to limited access, surveys in 2018 ended before all potential habitats could
be completed. Approximately 47.5 acres of potential small whorled pogonia habitat and 25 acres of
potential smooth coneflower habitat were planned for survey in summer 2019. Surveys to date during 2019
have assessed 63% of the total required tracts, and no individuals of either target species were identified
during survey to date. Surveys for the remaining 37% of tracts will be completed upon receipt of ROW
access. Upon completion of 2019 field surveys, results will be submitted to USFWS and NCWRC for
review and comment and filed with FERC. If listed species are identified, the Project will develop a
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relocation plan in coordination with USFWS Raleigh Field Office and NCWRC. The final plan will be
submitted to USFWS and NCWRC for review and approval. The Project is committed to working with the
agencies to determine applicable avoidance, minimization or mitigation strategies to minimize impacts to
these species.
One additional plant, the state rare cliff stonecrop (Sedum glaucophyllum), was identified during review of
the NCNHP database. Surveys for this species were not requested; however, implementation of the
Southgate Plan & Procedures and the Project's Invasive Species Plan will minimize impacts to this species
should it be encountered during construction.
5.5.6 Conclusions
The Project will provide Section 7 Endangered Species Act clearance from US. Fish and Wildlife Service
as soon as it is obtained.
5.6 ESSENTIAL FISH HABITAT
According to the NMFS online Essential Fish Habitat Mapper tool (NMFS, 2017), the Project does not
cross any waterbodies identified as Essential Fish Habitat. Because the Project is located well inland of
saltwater and tidal waters and does not cross known anadromous or diadromous fish migration routes, none
of the waterbodies crossed by the Project contain, or have the potential to support, species managed by the
NMFS.
5.7 CULTURAL RESOURCES INFORMATION
MVP Southgate is currently conducting archaeological surveys of the direct area of potential effect for
Project facilities, including the pipeline corridor and all ancillary facilities such as access roads, contractor
yards, and ATWS. As of July 17, 2019, archaeological survey has been completed for approximately 91.2
percent of the pipeline route. Survey for aboveground historic resources is also being conducted, and as of
July 17, 2019 has been completed for an estimated 98.0 percent of the pipeline route. Detailed reports on
cultural resource surveys were submitted to the North Carolina State Historic Preservation Office,
applicable federally -recognized tribes as requested and the FERC along with the FERC Certificate
Application. The Project is currently assessing avoidance or assessment options for those properties that
may be eligible for the National Register of Historic Places and will develop treatment plans for any such
properties that may be affected by the Project. If necessary, the FERC will develop a Programmatic
Agreement (PA) to provide a process for completing surveys on no access properties and implementation
of the treatment plans, if any. A draft unanticipated cultural resources discovery plan is included in
Appendix P. The Project will provide Section 106 concurrence once it is obtained.
5.8 FLOOD ZONE DESIGNATION
The Southgate Project has reviewed Federal Emergency Management Agency ("FEMA") Flood Insurance
Rate Mapping for areas crossed by the Project and recorded the location of 100-year flood zones (FEMA,
2018). A summary of 100-year flood zones crossed by the Project is listed below in Table 5-2 and shown
in the FEMA Figure set in Appendix Q of the August 9, 2019 Re -Application. Two permanent access roads
and one interconnect in North Carolina would be located within the FEMA 100-year flood zone. Temporary
access roads located within floodplains may have a temporary effect on flood storage but will be restored
after construction unless requested to be maintained by the landowner or agency. All applicable floodplain
permits will be obtained from the relevant issuing authorities.
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Table 5-2
100-Year Floodplain areas crossed
State/County
Flood Zone a/
Entry Mile Post
Exit Mile Post
Length Crossed (feet)
North Carolina
AE
27.1
27.8
3,761
AE
27.8
27.8
22
AE
27.9
28.1
770
AE
28.3RR
28ARR
201
AE
29.6
29.6
22
AE
29.6
30.5
4,741
AE
30.5
30.6
315
AE
30.7
30.7
150
AE
30.7
30.9
941
AE
32.1
32.2
37
AE
32.2
32.2
196
Rockingham
AE
32.2
32.2
10
AE
32.6
32.7
526
AE
33.0
33.1
470
AE
33.1
33.1
32
AE
38.6
38.8
886
AE
41.1
41.2
320
AE
43.2
43.3
551
AE
46.4
46.5
88
AE
46.9
47.0
341
AE
48.6
48.7
353
AE
50.8RR
50.8RR
264
AE
53.6
53.7
198
AE
54.6
54.6
125
AE
56.4
56.4
125
AE
56.7RR
56.7RR
68
AE
57.0
57.0
304
AE
57.9
57.9
8
Alamance
AE
58.7RR
58.7RR
188
AE
60.7
60.7
31
AE
63.6
63.6
4
AE
63.6
63.6
350
AE
63.8
63.9
100
AE
64.ORR
64.1 RR
271
AE
65.6
65.6
115
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Table 5-2
100-Year Floodplain areas crossed
State/County
Flood Zone a/
Entry Mile Post
Exit Mile Post
Length Crossed (feet)
AE
67.6RR
67.6RR
153
AE
69.1
69.1
222
AE
69.1
69.3
894
AE
69.1
69.1
222
AE
70.2RR
70.3
243
AE
70.7
70.8
254
AE
70.9
70.9
253
AE
70.9
71.0
115
AE
71.3
71.3
328
AE
71.3
71.8
2,536
AE
72.5
72.7
1,279
AE
72.9RR
73.1RR
1,077
Note: Mileposts with an "RR" indicate locations where a re-route was incorporated into the pipeline alignment.
a/ Flood Zone A — Areas subject to inundation by the 1-percent annual chance flood event determined using
approximate methodologies.
Flood Zone AE — Areas subject to inundation by the 1-percent annual chance flood event determined by detailed
methods.
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6.0 REFERENCES
Cowardin, L.M., V. Carter V., F.C. Golet, E.T. LaRoe. 1979. Classification of Wetlands and Deepwater
Habitats of the United States. U.S. Fish and Wildlife Service Report No. FWS/OBS/-
79/31.Washington, D.C.
Environmental Laboratory. 1987. "Corps of Engineers Wetlands Delineation Manual," Technical Report
Y-87-1, U.S. Army Engineer Waterways Experiment Station, Vicksburg, Miss.
Federal Emergency Management Agency (FEMA). 2018. Flood Map Service Center. Available online at:
hllp://msc.fema.gov/portal. Accessed July 2018.
Federal Energy Regulatory Commission (FERC) 2013. Upland Erosion Control, Revegetation, and
Maintenance Plan. Available online at: http://www.ferc.gov/industries/gas/enviro/plan.pdf. Accessed
August 2, 2018.
Federal Energy Regulatory Commission (FERC) 2013. Wetland and Waterbody Construction and
Mitigation Procedures. Available online
at: ha://www.ferc.gov/industries/gas/enviro/procedures.pdf. Accessed August 2, 2018.
Federal Energy Regulatory Commission (FERC). 2013. Upland Erosion Control, Revegetation and
Maintenance Plan. May 2013.
Federal Energy Regulatory Commission (FERC). 2013. Wetland and Waterbody Construction and
Mitigation Procedures. May 2013.
Federal Energy Regulatory Commission (FERC). 2017. Guidance Manual for Environmental Report
Preparation. February.
Gulf Interstate Engineering. 1999. Temporary Right -of -Way Width Requirements for Pipeline
Construction. Prepared for the INGAA Foundation, Inc. Available online at:
hqp://www.in ag a.or /Fg ile.aMx?id=19105.
National Wild and Scenic Rivers System. 2018. Explore Designated Rivers. Available online at:
http://www.n*vers. og v/mapphp. Accessed July 2018.
NCWRC. 2018. Response to project review request on the MVP Southgate Project. Letter dated August
10, 2018, addressed to Ms. Megan Stahl of EQT, from Mr. Vann Stancil, of NCWRC.
North Carolina Department of Environment and Natural Resources, Division of Environmental Health
(NCDENR). 1999. Source Water Assessment Program Plan. Available online at:
has:Hfiles.nc.gov/ncdeg/Water%20Resources/files/swgp/FullText.pdf. Accessed Jules
North Carolina Department of Environmental Quality (NC DEQ). 2018. Reidsville Energy Center Permit
#NC0089699. htt2s://deg.nc.gov/reidsville-energy-center-permit-nc0089699. Accessed October 3,
2018.
North Carolina Division of Environmental Quality (NCDEQ). 2018b. Digital information regarding
watersheds. Available online at: http://data-ncdenr.opendata.arcgis.com/. Accessed July 2018.
6-1 March 2020

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North Carolina Division of Environmental Quality (NCDEQ). 2018d. Surface Water Classifications.
Available online at: hops://deg.nc.gov/about/divisions/water-resources/planning/classification-
standards/classifications#DWRPrimMClassification. Accessed July 2018.
North Carolina Division of Water Resources (NCDWR). 2018. Jordan lake Nutrient Strategy. Available
online at: hops://deg.nc.gov/about/divisions/water-resources/water-planning/nonpoint-source-
plannina/iordan-lake-nutrient. Accessed August 2018.
North Carolina Wildlife Resources Commission (NCWRC). 2018. Trout Fishing Maps. Available online
at: http://ncwildlife.or /Fg ishing/Trout-Fishing-Maps. Accessed July 2018.
NSF International. 2018. NSF / ANSI 60. Available online at: http://www.nsf.org/services/by-
industry/water-wastewater/water-treatment-chemicals/nsf-ansi-standard-60. Accessed October 2018.
Town of Chapel Hill (TCH). 2018. Jordan Lake Watershed. Available online at:
ha://www.townofchapelhill.org/town-hall/departments-service s/public-works/stormwater-
management/local-watersheds-water-guality/jordan-lake-watershed. Accessed August 2018.
U.S. Army Corps of Engineers (USACE). 2012. Regional Supplement to the Corps of Engineers Wetland
Delineation Manual: Eastern Mountains and Piedmont Region Version 2.0, ed. J. F. Berkowitz, J. S.
Wakeley, R. W. Lichvar, C. V. Noble. ERDC/EL TR-12-9. Vicksburg, MS: U.S. Army Engineer
Research and Development Center.
U.S. Energy Information Agency (EIA). 2017a. State Profile and Energy Estimates — Virginia. Available
online at: hips://www.cia.gov/state/analysis.php?sid=VA Accessed June 3, 2018.
U.S. Energy Information Agency (EIA). 2017b. State Profile and Energy Estimates — North Carolina.
Available online at: https://www.cia.gov/state/analysis.php?sid=NC. Accessed June 3, 2018.
U.S. Fish and Wildlife Service (USFWS). 2009. National Wetlands Inventory website. U.S. Department of
the Interior, Fish and Wildlife Service, Washington, D.C. Available online at:
ha://www.fws.gov/wetlands/. Accessed July 2018.
U.S. Fish and Wildlife Service (USFWS). 2018. Critical Habitat Portal. Available online at:
http://ecos.fws.gov/crithab/flex/crithabMapper. Accessed July 2018.
U.S. Fish and Wildlife Service (USFWS). 2018b. Endangered and Threatened Species and Species of
Concern by County for North Carolina. Available online at:
hlps://www.fws.gov/raleigh/species/cnlylist/nc countles.litnil Accessed on July 31, 2018.
U.S. Geological Survey (USGS). 2018b. National Hydrography Dataset (NHD). Available online at:
http://nhd.usgs.gov/data.httnl. Accessed July 2018.
USFWS. 2007. National Bald Eagle Management Guidelines. Available online at
https://www.fws.gov/northeast/ecological
service s/pdf/NationalBaldEagleManagementGuidelines.pdf.
USFWS. 2016. Final rule: Endangered and threatened wildlife and plants: 4(d) Rule for the northern long-
eared bat. Pages 1900-1922 in Federal Register Volume 81, No. 9. U.S. Department of Interior, Fish
and Wildlife Service.
6-2 March 2020

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USFWS. 2018. Range -wide Indiana bat survey guidelines - April 2018. U.S. Department of the Interior,
Fish and Wildlife Service. 61 pp.
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MVP Southgate Project
Standard Joint Permit Application Supplement
U.S. Army Corps of Engineers —
Wilmington District (SAW-2018-00887)
North Carolina Department of
Environmental Quality,
Division of Water Resources
Appendix N (Updated)
Compliance Statement for NWP 12 Terms and Conditions
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Appendix N-1
Southgate Project Compliance with Nationwide Permit 12 Utility Line Activities Terms and Conditions
Condition
Southgate Project Compliance Statement
Utility lines: This NWP authorizes discharges of dredged or fill
Please refer to Section 2.5.1 of the Project
material into waters of the United States ("WOTUS") and structures
narrative. Upon completion of the pipeline
or work in navigable waters for crossings of those waters
installation, the surface of the right-of-way
associated with the construction, maintenance, or repair of utility
disturbed during construction activities will be
lines, including outfall and intake structures. There must be no
graded to match original contours and to be
change in pre -construction contours of waters of the United States.
compatible with surrounding drainage
A "utility line" is defined as any pipe or pipeline for the
patterns, except at those locations where
transportation of any gaseous, liquid, liquescent, or slurry
permanent changes in drainage will be
substance, for any purpose, and any cable, line, or wire for the
required to prevent erosion, scour, and
transmission for any purpose of electrical energy, telephone, and
possible exposure of the pipeline.
telegraph messages, and internet, radio, and television
communication. The term "utility line" does not include activities
that drain a water of the United States, such as drainage tile or
french drains, but it does apply to pipes conveying drainage from
another area.
Material resulting from trench excavation may be temporarily
See Section 2.5.1 of Project Narrative. Upon
sidecast into waters of the United States for no more than three
completion of the pipeline installation, the
months, provided the material is not placed in such a manner that
surface of the right-of-way disturbed during
it is dispersed by currents or other forces. The district engineer
construction activities will be graded to match
may extend the period of temporary side casting for no more than
original contours and to be compatible with
a total of 180 days, where appropriate. In wetlands, the top 6 to 12
surrounding drainage patterns, except at those
inches of the trench should normally be backfilled with topsoil from
locations where permanent changes in
the trench. The trench cannot be constructed or backfilled in such
drainage will be required to prevent erosion,
a manner as to drain waters of the United States (e.g., backfilling
scour, and possible exposure of the pipeline.
with extensive gravel layers, creating a french drain effect). Any
The Project will segregate the topsoil over the
exposed slopes and stream banks must be stabilized immediately
trenchline in wetlands where hydrologic
upon completion of the utility line crossing of each waterbody.
conditions permit this practice, and all
excavated material will be placed in an upland
area if possible. Segregated topsoil will be
placed in the trench following subsoil
backfilling to restore the original contour.
Utility line substations: This NWP authorizes the construction,
Not Applicable — The Project does not involve
maintenance, or expansion of substation facilities associated with
the construction, maintenance, or expansion
a power line or utility line in non -tidal waters of the United States,
of substation facilities associated with a power
provided the activity, in combination with all other activities
line or utility line in non -tidal waters of the
included in one single and complete project, does not result in the
United States.
loss of greater than 1/2-acre of waters of the United States. This
NWP does not authorize discharges into non -tidal wetlands
adjacent to tidal waters of the United States to construct, maintain,
or expand substation facilities.
Foundations for overhead utility line towers, poles, and
Not applicable — the Project does not include
anchors: This NWP authorizes the construction or maintenance of
overhead utility line towers, poles or anchors
foundations for overhead utility line towers, poles, and anchors in
in waters of the United States.
all waters of the United States, provided the foundations are the
minimum size necessary and separate footings for each tower leg
(rather than a larger single pad) are used where feasible.
Access roads: This NWP authorizes the construction of access
See Section 2.3.3 of the Project narrative and
roads for the construction and maintenance of utility lines,
Appendices J-1 and J-2. Access road widths
including overhead power lines and utility line substations, in non-
will be the minimum necessary to provide
tidal waters of the United States, provided the activity, in
access for construction equipment while
combination with all other activities included in one single and
maintaining safe travel conditions. Access will
complete project, does not cause the loss of greater than 1/2-acre
be constructed such that the length of the road
of non -tidal waters of the United States. This NWP does not
minimizes impacts on waters of the United
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Appendix N-1
Southgate Project Compliance with Nationwide Permit 12 Utility Line Activities Terms and Conditions
Condition
Southgate Project Compliance Statement
authorize discharges into non -tidal wetlands adjacent to tidal
States and will be maintained as close as
waters for access roads. Access roads must be the minimum width
possible to pre -construction contours and
necessary (see Note 2, below). Access roads must be constructed
elevations.
so that the length of the road minimizes any adverse effects on
waters of the United States and must be as near as possible to
The project is not near any tidal water. There
pre -construction contours and elevations (e.g., at grade corduroy
will be no discharges to non -tidal waters.
roads or geotexti le/g ravel roads). Access roads constructed above
pre -construction contours and elevations in waters of the United
States must be properly bridged or culverted to maintain surface
flows.
This NWP may authorize utility lines in or affecting navigable
Not applicable — the Project does not cross
waters of the United States even if there is no associated
any navigable waters of the United States.
discharge of dredged or fill material (See 33 CFR part 322).
Overhead utility lines constructed over section 10 waters and utility
lines that are routed in or under section 10 waters without a
discharge of dredged or fill material require a section 10 permit.
This NWP authorizes, to the extent that Department of the Army
See Section 2.4.4 and Appendix H. The
authorization is required, temporary structures, fills, and work
Project has developed a HDD Contingency
necessary for the remediation of inadvertent returns of drilling
Plan to address disposal of drilling fluid as well
fluids to waters of the United States through sub -soil fissures or
as protocols to be implemented in the unlikely
fractures that might occur during horizontal directional drilling
event of an inadvertent release of drilling fluid
activities conducted for the purpose of installing or replacing utility
to waters of the United States.
lines. These remediation activities must be done as soon as
practicable, to restore the affected waterbody. District engineers
Remediation activities will be conducted as
may add special conditions to this NWP to require a remediation
soon as practicable to restore the affected
plan for addressing inadvertent returns of drilling fluids to waters of
waterbody.
the United States during horizontal directional drilling activities
conducted for the purpose of installing or replacing utility lines.
This NWP also authorizes temporary structures, fills, and work,
See Section 2.4.2.2, Section 2.4.2.3 and
including the use of temporary mats, necessary to conduct the
Section 2.5 of the Project narrative. The
utility line activity. Appropriate measures must be taken to maintain
Project is updating a scour analysis on
normal downstream flows and minimize flooding to the maximum
perennial waterbodies crossed by the pipeline
extent practicable, when temporary structures, work, and
to ensure that the placement depth is sufficient
discharges, including cofferdams, are necessary for construction
to prevent erosion by expected high flows.
activities, access fills, or dewatering of construction sites.
Temporary fills must consist of materials, and be placed in a
manner, that will not be eroded by expected high flows. After
construction, temporary fills must be removed in their entirety and
the affected areas returned to pre -construction elevations. The
areas affected by temporary fills must be revegetated, as
appropriate.
Notification: The permittee must submit a pre -construction
This application serves as the pre -construction
notification to the district engineer prior to commencing the activity
notification for those activities within waters of
if any of the following criteria are met: (1) the activity involves
United States that meet the criteria identified
mechanized land clearing in a forested wetland for the utility line
within the notification procedures for work in
right-of-way; (2) a Section 10 permit is required; (3) the utility line
North Carolina.
in waters of the United States, excluding overhead lines, exceeds
500 feet; (4) the utility line is placed within a jurisdictional area (i.e.,
water of the United States), and it runs parallel to or along a
stream bed that is within that jurisdictional area; (5) discharges that
result in the loss of greater than 1/10-acre of waters of the United
States; (6) permanent access roads are constructed above grade
in waters of the United States for a distance of more than 500 feet;
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Appendix N-1
Southgate Project Compliance with Nationwide Permit 12 Utility Line Activities Terms and Conditions
Condition
Southgate Project Compliance Statement
or (7) permanent access roads are constructed in waters of the
United States with impervious materials. (See general condition
32.) (Authorities: Sections 10 and 404)
Note 1: Where the utility line is constructed or installed in
Not applicable — the Project does not cross
navigable waters of the United States (i.e., section 10 waters)
any navigable waters of the United States.
within the coastal United States, the Great Lakes, and United
States territories, a copy of the NWP verification will be sent by the
Corps to the National Oceanic and Atmospheric Administration
(NOAA), National Ocean Service (NOS), for charting the utility line
to protect navigation.
Note 2: For utility line activities crossing a single waterbody more
The Project will comply with 33 CFR 330.6(d).
than one time at separate and distant locations, or multiple
waterbodies at separate and distant locations, each crossing is
considered a single and complete project for purposes of NWP
authorization. Utility line activities must comply with 33 CFR
330.6(d).
Note 3: Utility lines consisting of aerial electric power transmission
Not applicable — the Project does not include
lines crossing navigable waters of the United States (which are
overhead utility lines.
defined at 33 CFR part 329) must comply with the applicable
minimum clearances specified in 33 CFR 322.5(i).
Note 4: Access roads used for both construction and maintenance
See Section 2.5.2 of the Project narrative.
may be authorized, provided they meet the terms and conditions of
Previously existing access roads that were
this NWP. Access roads used solely for construction of the utility
modified and used during construction will be
line must be removed upon completion of the work, in accordance
returned to original or better condition upon
with the requirements for temporary fills.
completion of the pipeline facilities installation.
Temporary access roads constructed
specifically for the Project installation will be
removed, the surface graded to original
contours, and the land restored to its original
grade.
Note 5: Pipes or pipelines used to transport gaseous, liquid,
Not applicable — the Project does not cross
liquescent, or slurry substances over navigable waters of the
any navigable waters of the United States.
United States are considered to be bridges, not utility lines, and
may require a permit from the U.S. Coast Guard pursuant to
section 9 of the Rivers and Harbors Act of 1899. However, any
discharges of dredged or fill material into waters of the United
States associated with such pipelines will require a section 404
permit (see NWP 15).
Note 6: This NWP authorizes utility line maintenance and repair
Not applicable — the Project does not involve
activities that do not qualify for the Clean Water Act section 404(f)
maintenance and repair activities.
exemption for maintenance of currently serviceable fills or fill
structures.
Note 7: For overhead utility lines authorized by this NWP, a copy
Not applicable — the Project does not include
of the PCN and NWP verification will be provided to the
overhead utility lines.
Department of Defense Siting Clearinghouse, which will evaluate
potential effects on military activities.
Note 8: For NWP 12 activities that require pre -construction
The Southgate Project is only requesting
notification, the PCN must include any other NWP(s), regional
authorization under NWP 12 and does not
general permit(s), or individual permit(s) used or intended to be
require other NWP(s), regional general
used to authorize any part of the proposed project or any related
permit(s) or individual permit(s).
activity, including other separate and distant crossings that require
N-1-3 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-1
Southgate Project Compliance with Nationwide Permit 12 Utility Line Activities Terms and Conditions
Condition
Southgate Project Compliance Statement
Department of the Army authorization but do not require pre -
construction notification (see paragraph (b) of general condition
32). The district engineer will evaluate the PCN in accordance with
Section D, "District Engineer's Decision." The district engineer may
require mitigation to ensure that the authorized activity results in no
more than minimal individual and cumulative adverse
environmental effects (see general condition 23).
N-1-4 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-2
Southgate Project Compliance with General Nationwide Permit Conditions
Condition
Southgate Project Compliance Statement
1. Navigation
Not applicable — the Project does not cross any
navigable waters of the United States.
2. Aquatic Life Movements No activity may
See Section 2.4.4 of the Project narrative and
substantially disrupt the necessary life cycle
Appendices C, D and E. Stream crossings for the
movements of those species of aquatic life
Project will be temporary, and flow will be maintained
indigenous to the waterbody, including those
during construction via a flume, damp and pump, or
species that normally migrate through the area,
cofferdam crossing method. Culverts along access
unless the activity's primary purpose is to
roads will be constructed in a manner that will not
impound water. All permanent and temporary
hinder aquatic life movement.
crossings of waterbodies shall be suitably
culverted, bridged, or otherwise designed and
constructed to maintain low flows to sustain the
movement of those aquatic species. If a
bottomless culvert cannot be used, then the
crossing should be designed and constructed to
minimize adverse effects to aquatic life
movements.
3. Spawning Areas Activities in spawning areas
See Section 4.4 of the Project narrative. Activities
during spawning seasons must be avoided to the
within waterbodies crossed by the Project will adhere
maximum extent practicable. Activities that result
to time of year restrictions that may be required by any
in the physical destruction (e.g., through
federal or state agency. The Project does not cross
excavation, fill, or downstream smothering by
any important spawning areas or other areas that are
substantial turbidity) of an important spawning
presently subject to time of year restrictions.
area are not authorized.
4. Migratory Bird Breeding Areas Activities in waters
The Project intends to avoid migratory bird breeding
of the United States that serve as breeding areas
areas within waters of the United States to the
for migratory birds must be avoided to the
maximum extent practicable.
maximum extent practicable.
5. Shellfish Beds
Not applicable — there are no saltwater shellfish beds
crossed by the Project. See Section 5.5.4 of the
Project narrative for information on freshwater
mussels.
6. Suitable Material No activity may use unsuitable
See Section 2.4.2 of the Project narrative. Previously
material (e.g., trash, debris, car bodies, asphalt,
excavated materials will be pushed back into the
etc.). Material used for construction or
trench using equipment or backhoes. Where the
discharged must be free from toxic pollutants in
previously excavated material contains large rocks or
toxic amounts (see section 307 of the Clean
other materials that could damage the pipe or coating,
Water Act).
clean fill will be used as backfill to protect the pipe.
Due to concerns about the acidity of fly ash and its
potential impacts on cathodic protection, fly ash will
not be used as backfill material. However, limestone
dust or sand, which is typically non -acidic and will
often aid in the cathodic protection of the pipeline, may
be used as backfill material. The remaining fill of the
trench will be the aggregate of the excavation material
removed at the time of the excavation. If additional fill
is required, it will be either flowable fill or clean fill.
7. Water Supply Intakes No activity may occur in the
Not applicable - There closest public supply intake is
proximity of a public water supply intake, except
located approximately 1.3 miles from the Project. The
where the activity is for the repair or
NCDWR designates "critical" water supply intake
improvement of public water supply intake
areas within 0.5-miles from the normal pool elevation
structures or adjacent bank stabilization.
of the reservoir in which the intake is located, or a half
N-2-1 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-2
Southgate Project Compliance with General Nationwide Permit Conditions
Condition
Southgate Project Compliance Statement
mile upstream from and draining to the intake located
directly in the stream or river, or to the ridge line of the
watershed (whichever comes first).
8. Adverse Effects from Impoundments If the activity
See Sections 2.4.4 of the Project narrative. Some
creates an impoundment of water, adverse
crossing methods proposed for the Project will
effects to the aquatic system due to accelerating
temporarily create an impoundment during
the passage of water, and/or restricting its flow
construction. The dam and pump method involves the
must be minimized to the maximum extent
installation of temporary dams upstream and
practicable.
downstream of the proposed waterbody crossing.
Following dam installation, appropriately sized pumps
will be used to dewater and transport the stream flow
around the construction work area and trench.
Energy dissipating devices will be installed at the
pump discharge point to minimize erosion and
streambed scour. The flume crossing method will
consist of temporarily directing the flow of water
through one or more flume pipes placed over the area
to be excavated. The number of flumes and / or
diameter will be designed to withstand the expected
high flows within the waterbodies. This method will
allow excavation of the pipe trench across the
waterbody completely underneath the flume pipes
without disruption of water flow in the stream.
Following completion of pipeline installation, backfill of
the trench, and restoration of stream banks, the
temporary impoundments will be removed, and flow
through the construction work area will be restored.
9. Management of Water Flows To the maximum
See Section 2.4.4 of the Project narrative. The dam
extent practicable, the pre- construction course,
and pump method involves the installation of
condition, capacity, and location of open waters
temporary dams upstream and downstream of the
must be maintained for each activity, including
proposed waterbody crossing. Following dam
stream channelization, storm water management
installation, appropriately sized pumps will be used to
activities, and temporary and permanent road
dewater and transport the stream flow around the
crossings, except as provided below. The activity
construction work area and trench so that the passage
must be constructed to withstand expected high
of normal and high flows are not restricted. The flume
flows. The activity must not restrict or impede the
crossing method will consist of temporarily directing
passage of normal or high flows, unless the
the flow of water through one or more flume pipes
primary purpose of the activity is to impound
placed over the area to be excavated. The number of
water or manage high flows. The activity may
flumes and / or diameter will be designed to withstand
alter the pre -construction course, condition,
the expected high flows within the waterbodies.
capacity, and location of open waters if it
These methods will allow excavation of the pipe trench
benefits the aquatic environment (e.g., stream
across the waterbody completely underneath the
restoration or relocation activities).
flume pipes without disruption of water flow in the
stream during construction. The Project will not alter
the pre -construction course during or after the pipeline
is installed. Prior to construction, a scour analysis will
be performed to perennial streams to ensure the
passage of high flows. The scour analysis is being
updated and will be submitted in April of 2020.
Existing culverts that are damaged or otherwise not
properly functioning will be repaired or replaced with an
in -kind structure to ensure they are functional during
construction activities. Permanent culverts or
N-2-2 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-2
Southgate Project Compliance with General Nationwide Permit Conditions
Condition
Southgate Project Compliance Statement
temporary flumes installed as part of the Project will
include measures to promote the safe passage of fish
and other aquatic organisms. The dimension, pattern,
and profile of the stream above and below a culvert will
not be modified by altering the width or depth of the
stream profile in connection with the construction
activity. The width, height, and gradient of a proposed
culvert will be sufficient to pass the average historical
low flow and spring flow without adversely altering flow
velocity. Access will be constructed such that the
length of the road minimizes impacts on waters of the
United States and will be maintained as close as
possible to pre -construction contours and elevations.
10. Fills Within 100-Year Floodplains The activity
The Project will comply with applicable floodplain
must comply with applicable FEMA-approved
management requirements within North Carolina.
state or local floodplain management
Applicable floodplain permit applications are currently
requirements.
underway and will be obtained from the issuing
authorities. There are no proposed permanent impacts
to floodplains (i.e., above -ground structures or
increased elevations) in North Carolina.
11. Equipment Heavy equipment working in
See Section 2.4.3 of the Project narrative. The Project
wetlands or mudflats must be placed on mats, or
will use equipment or timber mats to facilitate
other measures must be taken to minimize soil
equipment movement through and work within the
disturbance.
wetland.
12. Soil Erosion and Sediment Controls Appropriate
See Section 4.4 of the Project narrative. The Project
soil erosion and sediment controls must be used
will conduct crossings of intermittent and perennial
and maintained in effective operating condition
waterbodies during periods of low -flow to the extent
during construction, and all exposed soil and
practicable.
other fills, as well as any work below the ordinary
high-water mark or high tide line, must be
permanently stabilized at the earliest practicable
date. Permittees are encouraged to perform
work within waters of the United States during
periods of low -flow or no -flow, or during low tides
13. Removal of Temporary Fills Temporary fills must
See Section 2.4.2 of the Project narrative. Upon
be removed in their entirety and the affected
completion of the pipeline installation, the surface of
areas returned to pre -construction elevations.
the right-of-way disturbed during construction activities
The affected areas must be revegetated, as
will be graded to match original contours and to be
appropriate.
compatible with surrounding drainage patterns, except
at those locations where permanent changes in
drainage will be required to prevent erosion, scour,
and possible exposure of the pipeline.
14. Proper Maintenance Any authorized structure or
The Project will maintain the pipeline in a safe
fill shall be properly maintained, including
operational manner in accordance with the Project's
maintenance to ensure public safety and
safety standards and specifications and in accordance
compliance with applicable NWP general
with the U.S. Department of Transportation Title 49
conditions, as well as any activity -specific
CFR (Part 192) requirements.
conditions added by the district engineer to an
NWP authorization.
N-2-3 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-2
Southgate Project Compliance with General Nationwide Permit Conditions
Condition
Southgate Project Compliance Statement
15. Single and Complete Project The activity must
Each water of the United States crossing is single and
be a single and complete project. The same
complete and will be completed under NWP 12.
NWP cannot be used more than once for the
same single and complete project.
16. Wild and Scenic Rivers
Not applicable - The Project does not cross any
federally designated Wild and Scenic Rivers.
17. Tribal Rights No NWP activity may cause more
See Section 5.7 of the Project narrative. Detailed
than minimal adverse effects on tribal rights
reports on cultural resource surveys were submitted to
(including treaty rights), protected tribal
the North Carolina State Historic Preservation Office,
resources, or tribal lands.
applicable federally -recognized tribes as requested
and the FERC along with the FERC Certificate
Application.
18. Endangered Species
See Section 5.5 of the Project narrative. The Project
(a) No activity is authorized under any NWP which
is currently consulting with the U.S. Fish and Wildlife
is likely to directly or indirectly jeopardize the
Service and anticipates receipt of a 'not likely to
continued existence of a threatened or
adversely affect' determination. Documentation of
endangered species or a species proposed for
final consultation with the U.S. Fish and Wildlife
such designation, as identified under the Federal
Service will be provided upon completion.
Endangered Species Act (ESA), or which will
directly or indirectly destroy or adversely modify
the critical habitat of such species. No activity is
authorized under any NWP which "may affect" a
listed species or critical habitat, unless ESA
section 7 consultation addressing the effects of the
proposed activity has been completed. Direct
effects are the immediate effects on listed species
and critical habitat caused by the NWP activity.
Indirect effects are those effects on listed species
and critical habitat that are caused by the NWP
activity and are later in time, but still are
reasonably certain to occur.
(b) Federal agencies should follow their own
The Southgate Project is not proposed by a federal
procedures for complying with the requirements of
agency.
the ESA.
(c) Non-federal permittees must submit a pre-
This re -application serves as the pre -construction
construction notification to the district engineer if
notification for those activities within waters of United
any listed species or designated critical habitat
States that meet the criteria identified within the
might be affected or is in the vicinity of the activity,
notification procedures for work in North Carolina.
or if the activity is located in designated critical
habitat, and shall not begin work on the activity
until notified by the district engineer that the
requirements of the ESA have been satisfied and
that the activity is authorized.
(d) As a result of formal or informal consultation
Noted
with the FWS or NMFS the district engineer may
add species -specific permit conditions to the
NWPs. Authorization of an activity by an NWP
does not authorize the "take" of a threatened or
endangered species as defined under the ESA.
(e) If the non-federal permittee has a valid ESA
Not applicable — the Project does not anticipate
section 10(a)(1)(B) incidental take permit with an
requiring an incidental take permit.
N-2-4 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-2
Southgate Project Compliance with General Nationwide Permit Conditions
Condition
Southgate Project Compliance Statement
approved Habitat Conservation Plan.
19.
Migratory Birds and Bald and Golden Eagles
See Section 5.5.3 of the Project narrative. The Project
is committed to avoiding impacts to bald eagles;
The permittee is responsible for ensuring their
action complies with the Migratory Bird Treaty
therefore the Project will conduct surveys during the
Act and the Bald and Golden Eagle Protection
winter of 2019 to identify active nests within 0.5 mile of
Act. The permittee is responsible for contacting
Project workspace areas. If active nests are
appropriate local office of the U.S. Fish and
discovered within 0.5 mile of Project activities,
Wildlife Service to determine applicable
measures adapted from the USFWS National Bald
measures to reduce impacts to migratory birds or
Eagle Management Guidelines for high disturbance
eagles, including whether "incidental take"
activities will be implemented.
permits are necessary and available under the
Migratory Bird Treaty Act or Bald and Golden
While there is no 'incidental take' permit under the
Eagle Protection Act for a particular activity.
Migratory Bird Treaty Act, the Project intends to avoid
migratory bird breeding areas within waters of the
United States to the maximum extent practicable.
20.
Historic Properties
See Section 5.7 of the Project narrative. The Project
(a)
In cases where the district engineer determines
will not commence construction activities until the
that the activity may have the potential to cause
requirements of Section 106 of the National Historic
effects to properties listed, or eligible for listing,
Preservation Act have been satisfied.
in the National Register of Historic Places, the
activity is not authorized, until the requirements
of Section 106 of the National Historic
Preservation Act (NHPA) have been satisfied.
(b)
Federal permittees should follow their own
Not applicable
procedures for complying with the requirements
of section 106 of the National Historic
Preservation Act.
(c)
Non-federal permittees must submit a pre-
This application serves as the pre -construction
construction notification to the district engineer
notification for those activities within waters of United
if the NWP activity might have the potential to
States that meet the criteria identified within the
cause effects to any historic properties listed
notification procedures for work in North Carolina.
on, determined to be eligible for listing on, or
potentially eligible for listing on the National
Register of Historic Places, including previously
unidentified properties.
(d)
For non-federal permittees, the district engineer
Noted
will notify the prospective permittee within 45
days of receipt of a complete pre -construction
notification whether NHPA section 106
consultation is required.
(e)
Prospective permittees should be aware that
Noted
section 110k of the NHPA (54 U.S.C. 306113)
prevents the Corps from granting a permit or
other assistance to an applicant who, with intent
to avoid the requirements of section 106 of the
NHPA, has intentionally significantly adversely
affected a historic property to which the permit
would relate, or having legal power to prevent it,
allowed such significant adverse effect to occur,
unless the Corps, after consultation with the
Advisory Council on Historic Preservation
(ACHP), determines that circumstances justify
N-2-5 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-2
Southgate Project Compliance with General Nationwide Permit Conditions
Condition
Southgate Project Compliance Statement
granting such assistance despite the adverse
effect created or permitted by the applicant.
21. Discovery of Previously Unknown Remains and
See Appendix M for the Project's Unanticipated
Cultural Resources Discoveries Plan.
Artifacts If you discover any previously unknown
historic, cultural or archeological remains and
artifacts while accomplishing the activity
authorized by this permit, you must immediately
notify the district engineer of what you have
found, and to the maximum extent practicable,
avoid construction activities that may affect the
remains and artifacts until the required
coordination has been completed. The district
engineer will initiate the Federal, Tribal, and
state coordination required to determine if the
items or remains warrant a recovery effort or if
the site is eligible for listing in the National
Register of Historic Places.
22. Designated Critical Resource Waters
Not applicable - There are no designated critical
resource waters within the Southgate Project limits.
23. Mitigation The district engineer will consider the
Compensatory mitigation will be provided as detailed
following factors when determining appropriate
in Section 4.1.2 of the Project narrative.
and practicable mitigation necessary to ensure
that the individual and cumulative adverse
environmental effects are no more than minimal:
(a) The activity must be designed and constructed
to avoid and minimize adverse effects, both
temporary and permanent, to waters of the
United States to the maximum extent
practicable at the project site (i.e., on site).
(b) Mitigation in all its forms (avoiding, minimizing,
Compensatory mitigation will be provided as detailed
rectifying, reducing, or compensating for
in Section 4.1.2 of the Project narrative.
resource losses) will be required to the extent
necessary to ensure that the individual and
cumulative adverse environmental effects are
no more than minimal.
(c) Compensatory mitigation at a minimum one -for-
The Project will not incur wetland losses in excess of
one ratio will be required for all wetland losses
1/10-acre at any single and complete crossing of
that exceed 1/10-acre and require pre-
waters of the United States in North Carolina.
construction notification, unless the district
engineer determines in writing that either some
other form of mitigation would be more
environmentally appropriate or the adverse
environmental effects of the proposed activity
are no more than minimal, and provides an
activity -specific waiver of this requirement. For
wetland losses of 1/10-acre or less that require
pre -construction notification, the district
engineer may determine on a case -by -case
basis that compensatory mitigation is required
to ensure that the activity results in only minimal
adverse environmental effects.
N-2-6 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-2
Southgate Project Compliance with General Nationwide Permit Conditions
Condition
Southgate Project Compliance Statement
(d) For losses of streams or other open waters that
Not applicable — The Project will not result in the loss
require pre -construction notification, the district
of streams or open waters.
engineer may require compensatory mitigation
to ensure that the activity results in no more
than minimal adverse environmental effects.
Compensatory mitigation for losses of streams
should be provided, if practicable, through
stream rehabilitation, enhancement, or
preservation, since streams are difficult -to -
replace resources (see 33 CFR 332.3(e)(3)).
(e) Compensatory mitigation plans for NWP
See Section 4.1.2 of the Project narrative. All
activities in or near streams or other open
workspaces within riparian areas will be restored and
waters will normally include a requirement for
revegetated upon completion of construction. The
the restoration or enhancement, maintenance,
project has submitted a draft riparian buffer restoration
and legal protection of riparian areas next to
plan to NCDWR which has been reviewed and
open waters. In some cases, the restoration or
comments incorporated. An updated draft was
maintenance/protection of riparian areas may
submitted to NCDWR in February of 2020.
be the only compensatory mitigation required.
Restored riparian areas should consist of native
species. The width of the required riparian area
will address documented water quality or
aquatic habitat loss concerns. Normally, the
riparian area will be 25 to 50 feet wide on each
side of the stream, but the district engineer may
require slightly wider riparian areas to address
documented water quality or habitat loss
concerns. Where both wetlands and open
waters exist on the project site, the district
engineer will determine the appropriate
compensatory mitigation based on what is best
for the aquatic environment on a watershed
basis. In cases where riparian areas are
determined to be the most appropriate form of
minimization or compensatory mitigation, the
district engineer may waive or reduce the
requirement to provide wetland compensatory
mitigation for wetland losses.
(f) Compensatory mitigation projects provided to
The Project will comply with the applicable provisions
offset losses of aquatic resources must comply
of 33 CFR part 332.
with the applicable provisions of 33 CFR part
332.
(1) The prospective permittee is responsible for
See Section 4.1.2 of the Project narrative. No single
proposing an appropriate compensatory mitigation
and complete project proposed in this application has
option if compensatory mitigation is necessary to
an associated impact that exceeds the thresholds in
ensure that the activity results in no more than
NWP General Condition 23(c) or NWP Regional
minimal adverse environmental effects. For the
Condition 10 for requiring compensatory mitigation.
NWPs, the preferred mechanism for providing
Nevertheless, the Southgate Project will provide
compensatory mitigation is mitigation bank credits
compensatory mitigation for the conversion of all
or in -lieu fee program credits (see 33 CFR
forested wetland to non -forested wetland through
332.3(b)(2) and (3)). However, if an appropriate
purchase of wetland mitigation credits at a 1:1 ratio
number and type of mitigation bank or in -lieu
from an approved mitigation bank with a service
credits are not available at the time the PCN is
territory covering the watershed where the impacts
submitted to the district engineer, the district
would occur. No compensatory mitigation is proposed
engineer may approve the use of permittee-
N-2-7 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-2
Southgate Project Compliance with General Nationwide Permit Conditions
Condition
Southgate Project Compliance Statement
responsible mitigation.
for permanent stream or wetland losses because no
permanent losses are proposed for the Project.
(2) The amount of compensatory mitigation
Noted
required by the district engineer must be sufficient
to ensure that the authorized activity results in no
more than minimal individual and cumulative
adverse environmental effects (see 33 CFR
330.1(e)(3)). (See also 33 CFR 332.3(f)).
(3) Since the likelihood of success is greater and
Noted
the impacts to potentially valuable uplands are
reduced, aquatic resource restoration should be
the first compensatory mitigation option
considered for permittee-responsible mitigation.
(4) If permittee-responsible mitigation is the
See Section 4.1.2 of the Project narrative. No single
proposed option, the prospective permittee is
and complete project proposed in this application has
responsible for submitting a mitigation plan. A
an associated impact that exceeds the thresholds in
conceptual or detailed mitigation plan may be used
NWP General Condition 23(c) or NWP Regional
by the district engineer to make the decision on
Condition 10 for requiring compensatory mitigation.
the NWP verification request, but a final mitigation
Nevertheless, the Southgate Project will provide
plan that addresses the applicable requirements of
compensatory mitigation for the conversion of all
33 CFR 332.4(c)(2) through (14) must be
forested wetland to non -forested wetland through
approved by the district engineer before the
purchase of wetland mitigation credits at a 1:1 ratio
permittee begins work in waters of the United
from an approved mitigation bank with a service
States, unless the district engineer determines that
territory covering the watershed where the impacts
prior approval of the final mitigation plan is not
would occur. No compensatory mitigation is proposed
practicable or not necessary to ensure timely
for permanent stream or wetland losses because no
completion of the required compensatory
permanent losses are proposed for the Project.
mitigation (see 33 CFR 332.3(k)(3)).
(5) If mitigation bank or in -lieu fee program credits
See Section 4.1.2 of the Project narrative. No single
are the proposed option, the mitigation plan only
and complete project proposed in this application has
needs to address the baseline conditions at the
an associated impact that exceeds the thresholds in
impact site and the number of credits to be
NWP General Condition 23(c) or NWP Regional
provided.
Condition 10 for requiring compensatory mitigation.
Nevertheless, the Southgate Project will provide
compensatory mitigation for the conversion of all
forested wetland to non -forested wetland through
purchase of wetland mitigation credits at a 1:1 ratio
from an approved mitigation bank with a service
territory covering the watershed where the impacts
would occur. No compensatory mitigation is proposed
for permanent stream or wetland losses because no
permanent losses are proposed for the Project.
(6) Compensatory mitigation requirements (e.g.,
Noted
resource type and amount to be provided as
compensatory mitigation, site protection,
ecological performance standards, monitoring
requirements) may be addressed through
conditions added to the NWP authorization,
instead of components of a compensatory
mitigation plan (see 33 CFR 332.4(c)(1)(ii)).
(a) Compensatory mitigation requirements (e.g.,
Noted
resource type and amount to be provided as
N-2-8 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-2
Southgate Project Compliance with General Nationwide Permit Conditions
Condition
Southgate Project Compliance Statement
compensatory mitigation, site protection,
ecological performance standards, monitoring
requirements) may be addressed through
conditions added to the NWP authorization,
instead of components of a compensatory
mitigation plan (see 33 CFR
332.4(c)(1 )(ii)). Compensatory mitigation will not
be used to increase the acreage losses allowed
by the acreage limits of the NWPs.
(b) Permittees may propose the use of mitigation
Noted
banks, in -lieu fee programs, or permittee-
responsible mitigation when developing a
compensatory mitigation.
(c) Where certain functions and services of waters
See Section 4.1.2 of the Project narrative. No single
of the United States are permanently adversely
and complete project proposed in this application has
affected by a regulated activity, such as
an associated impact that exceeds the thresholds in
discharges of dredged or fill material into waters
NWP General Condition 23(c) or NWP Regional
of the United States that will convert a forested
Condition 10 for requiring compensatory mitigation.
or scrub -shrub wetland to a herbaceous
Nevertheless, the Southgate Project will provide
wetland in a permanently maintained utility line
compensatory mitigation for the conversion of all
right-of-way, mitigation may be required to
forested wetland to non -forested wetland through
reduce the adverse environmental effects of the
purchase of wetland mitigation credits at a 1:1 ratio
activity to the no more than minimal level.
from an approved mitigation bank with a service
territory covering the watershed where the impacts
would occur. No compensatory mitigation is proposed
for permanent stream or wetland losses because no
permanent losses are proposed for the Project.
24. Safety of Impoundment Structures To ensure
Not applicable - The Southgate Project will not create
that all impoundment structures are safely
impoundment structures.
designed, the district engineer may require non -
Federal applicants to demonstrate that the
structures comply with established state dam
safety criteria or have been designed by qualified
persons.
25. Water Quality Where States and authorized
The Southgate Project will comply with the general
Tribes, or EPA where applicable, have not
water quality certification conditions.
previously certified compliance of an NWP with
CWA section 401, individual 401 Water Quality
This application constitutes the Project's notice and
Certification must be obtained or waived (see 33
request for any 401 Water Quality Certification that
CFR 330.4(c)). The district engineer or State or
may be required for any Project activity described
Tribe may require additional water quality
herein.
management measures to ensure that the
authorized activity does not result in more than
minimal degradation of water quality.
26. Coastal Zone Management
Not applicable - The Southgate Project is not located
within the Coastal Zone.
27. Regional and Case -By -Case Conditions The
See Appendix 0-3.
activity must comply with any regional conditions
that may have been added by the Division
Engineer (see 33 CFR 330.4(e)) and with any
case specific conditions added by the Corps or
by the state, Indian Tribe, or U.S. EPA in its
N-2-9 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-2
Southgate Project Compliance with General Nationwide Permit Conditions
Condition
Southgate Project Compliance Statement
section 401 Water Quality Certification, or by the
state in its Coastal Zone Management Act
consistency determination.
28. Use of Multiple Nationwide Permits The use of
The Southgate Project is only requesting authorization
more than one NWP for a single and complete
under NWP 12 and does not require at this time, and
project is prohibited, except when the acreage
is not expected to require, other NWP(s), regional
loss of waters of the United States authorized by
general permit(s) or individual permit(s).
the NWPs does not exceed the acreage limit of
the NWP with the highest specified acreage limit.
For example, if a road crossing over tidal waters
is constructed under NWP 14, with associated
bank stabilization authorized by NWP 13, the
maximum acreage loss of waters of the United
States for the total project cannot exceed 1/3-
acre.
29. Transfer of Nationwide Permit Verifications If the
Noted
permittee sells the property associated with a
nationwide permit verification, the permittee may
transfer the nationwide permit verification to the
new owner by submitting a letter to the
appropriate Corps district office to validate the
transfer. A copy of the nationwide permit
verification must be attached to the letter, and
the letter must contain the following statement
and signature:
30. Compliance Certification Each permittee who
Noted
receives an NWP verification letter from the
Corps must provide a signed certification
documenting completion of the authorized
activity and implementation of any required
compensatory mitigation. The success of any
required permittee-responsible mitigation,
including the achievement of ecological
performance standards, will be addressed
separately by the district engineer.
31. Activities Affecting Structures or Works Built bV
Not applicable - The Southgate Project is not located
in any of the USACE federally authorized civil works
the United States If an NWP activity also
requires permission from the Corps pursuant to
project areas and will not require permission pursuant
33 U.S.C. 408 because it will alter or temporarily
to 33 U.S.C. 408.
or permanently occupy or use a U.S. Army
Corps of Engineers (USACE) federally
authorized Civil Works project (a "USACE
project'), the prospective permittee must submit
a pre -construction notification. See paragraph
(b)(10) of general condition 32. An activity that
requires section 408 permission is not authorized
by NWP until the appropriate Corps office issues
the section 408 permission to alter, occupy, or
use the USACE project, and the district engineer
issues a written NWP verification.
32. Pre -Construction Notification
This application serves as the pre -construction
a) Timing: where required by the terms of the NWP,
notification for those activities within waters of United
N-2-10 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-2
Southgate Project Compliance with General Nationwide Permit Conditions
Condition
Southgate Project Compliance Statement
the prospective permittee must notify the district
States that meet the criteria identified within the
engineer by submitting a pre- construction
notification procedures for work in North Carolina.
notification (PCN) as early as possible. The
request must specify the information needed to
make the PCN complete. As a general rule, district
engineers will request additional information
necessary to make the PCN complete only once.
b) Contents of Pre -Construction Notification: The
This application serves as the pre -construction
PCN must be in writing and include the following
notification for those activities within waters of United
information:
States that meet the criteria identified within the
notification procedures for work in North Carolina.
(1) Name, address and telephone numbers of the
See completed application form.
prospective permittee;
(2) Location of the proposed activity;
See completed application form.
(3) Identify the specific NWP or NWP(s) the
The Southgate Project is seeking authorization under
prospective permittee wants to use to authorize
NWP 12 for utility line activities.
the proposed activity;
(4) A description of the proposed activity; the
The Joint Permit Application package for the
activity's purpose; direct and indirect adverse
Southgate Project submitted in August of 2019
environmental effects the activity would cause,
provides the applicable information required for Pre -
including the anticipated amount of loss of
Construction Notification. This addendum and
wetlands, other special aquatic sites, and other
subsequent submittal in April of 2020 provides updated
waters expected to result from the NWP activity, in
crossing methods, construction practices and wetland
acres, linear feet, or other appropriate unit of
and waterbody impact tables.
measure; a description of any proposed mitigation
measures intended to reduce the adverse
environmental effects caused by the proposed
activity; and any other NWP(s), regional general
permit(s), or individual permit(s) used or intended
to be used to authorize any part of the proposed
project or any related activity, including other
separate and distant crossings for linear projects
that require Department of the Army authorization
but do not require pre -construction notification.
The description of the proposed activity and any
proposed mitigation measures should be
sufficiently detailed to allow the district engineer to
determine that the adverse environmental effects
of the activity will be no more than minimal and to
determine the need for compensatory mitigation or
other mitigation measures. For single and
complete linear projects, the PCN must include the
quantity of anticipated losses of wetlands, other
special aquatic sites, and other waters for each
single and complete crossing of those wetlands,
other special aquatic sites, and other waters.
Sketches should be provided when necessary to
show that the activity complies with the terms of
the NWP. (Sketches usually clarify the activity and
when provided results in a quicker decision.
Sketches should contain sufficient detail to provide
an illustrative description of the proposed activity
(e.g., a conceptual plan), but do not need to be
N-2-11 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-2
Southgate Project Compliance with General Nationwide Permit Conditions
Condition
Southgate Project Compliance Statement
detailed engineering plans);
(5) The PCN must include a delineation of
See updated Appendix B (alignment sheets — to be
wetlands, other special aquatic sites, and other
submitted in April of 2020) and the updated impact
waters, such as lakes and ponds, and perennial,
maps in updated Appendix M (to be submitted in April
intermittent, and ephemeral streams, on the
of 2020 for the delineated wetlands and other aquatic
project site. Wetland delineations must be
resources as of January 2020.
prepared in accordance with the current method
required by the Corps. The permittee may ask the
Corps to delineate the special aquatic sites and
other waters on the project site, but there may be
a delay if the Corps does the delineation,
especially if the project site is large or contains
many wetlands, other special aquatic sites, and
other waters. Furthermore, the 45-day period will
not start until the delineation has been submitted
to or completed by the Corps, as appropriate;
(6) If the proposed activity will result in the loss of
Not applicable — the Project will not result in the loss of
greater than 1/10-acre of wetlands and a PCN is
greater than 1/10-acre of waters of the United States
required, the prospective permittee must submit a
at any single and complete crossing. See Appendix
statement describing how the mitigation
K-1.
requirement will be satisfied or explaining why the
adverse environmental effects are no more than
minimal and why compensatory mitigation should
not be required. As an alternative, the prospective
permittee may submit a conceptual or detailed
mitigation plan.
(7) For non -Federal permittees, if any listed species
See Section 5.5 of the Project narrative. The Project
or designated critical habitat might be affected or
will provide documentation demonstrating compliance
is in the vicinity of the activity, or if the activity is
with the Endangered Species Act upon completion of
located in designated critical habitat, the PCN
consultation with the U.S. Fish and Wildlife Service.
must include the name(s) of those endangered or
threatened species that might be affected by the
proposed activity or utilize the designated critical
habitat that might be affected by the proposed
activity. For NWP activities that require pre -
construction notification, Federal permittees must
provide documentation demonstrating compliance
with the Endangered Species Act.
(8) For an activity that will occur in a component of
Not applicable - There are no National Wild and
the National Wild and Scenic River System, or in a
Scenic River systems or study rivers within the
river officially designated by Congress as a "study
Southgate Project limits.
river" for possible inclusion in the system.
For an activity that requires permission from the
Not applicable - The Southgate Project is not located
Corps pursuant to 33 U.S.C. 408 because it will alter
in any of the USACE federally authorized civil works
or temporarily or permanently occupy or use a U.S.
project areas and will not require permission pursuant
Army Corps of Engineers federally authorized civil
to 33 U.S.C. 408.
works project.
c) Form of Pre -Construction Notification: The
This application serves as the pre -construction
standard individual permit application form (Form
notification for those activities within waters of United
ENG 4345) may be used, but the completed
States that meet the criteria identified within the
application form must clearly indicate that it is an
notification procedures for work in North Carolina.
NWP PCN and must include all of the applicable
N-2-12 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-2
Southgate Project Compliance with General Nationwide Permit Conditions
Condition
Southgate Project Compliance Statement
information required in paragraphs (b)(1) through
(10) of this general condition. A letter containing
the required information may also be used.
Applicants may provide electronic files of PCNs
and supporting materials if the district engineer
has established tools and procedures for
electronic submittals.
d) Agency Coordination:
Noted
(1) The district engineer will consider any
comments from Federal and state agencies
concerning the proposed activity's compliance
with the terms and conditions of the NWPs and
the need for mitigation to reduce the activity's
adverse environmental effects so that they are
no more than minimal.
(2) Agency coordination is required for: (i) all
Noted
NWP activities that require pre -construction
notification and result in the loss of greater
than 1/2-acre of waters of the United States;
(3) When agency coordination is required, the
Noted
district engineer will immediately provide (e.g.,
via e-mail, facsimile transmission, overnight
mail, or other expeditious manner) a copy of
the complete PCN to the appropriate Federal
or state offices (FWS, state natural resource or
water quality agency, EPA, and, if appropriate,
the NMFS).
(4) In cases of where the prospective permittee
Not applicable — No Essential Fish Habitat is crossed
is not a Federal agency, the district engineer
by the Project.
will provide a response to NMFS within 30
calendar days of receipt of any Essential Fish
Habitat conservation recommendations, as
required by section 305(b)(4)(B) of the
Magnuson -Stevens Fishery Conservation and
Management Act.
(5) Applicants are encouraged to provide the
Noted
Corps with either electronic files or multiple
copies of pre -construction notifications to
expedite agency coordination.
N-2-13 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-3
MVP Southgate Compliance with Nationwide Permit General Regional Conditions for the Wilmington
District
Condition
Southgate Project Compliance Statement
1.0 Excluded Waters
1.1 Anadromous Fish Spawning Areas - Waters of the
Not applicable — The Project does not cross any
United States identified by either the North
identified anadromous fish spawning areas in North
Carolina Division of Marine Fisheries (NCDMF) or
Carolina.
the North Carolina Wildlife Resources Commission
(NCWRC) as anadromous fish spawning areas are
excluded during the period between February 15
and June 30, without prior written approval from
the Corps and either NCDMF or NCWRC.
1.2 Trout Waters Moratorium - Waters of the United
Not applicable — The Project is not located within any
States in the designated trout watersheds of North
designated trout watersheds.
Carolina are excluded during the period between
October 15 and April 15 without prior written
approval from the NCWRC, or from the Eastern
Band of Cherokee Indians (EBCI) Fisheries and
Wildlife Management (FWM) office if the project is
located on EBCI trust land.
1.2 Sturgeon Spawning Areas - Waters of the United
Not Applicable —The Project does not cross any Waters
States designated as sturgeon spawning areas are
of the United States designated as sturgeon spawning
excluded during the period between February 1
areas.
and June 30, without prior written approval from
the NMFS.
2.0 Waters Requiring Additional Notification
2.1 Western NC Counties that drain into Designated
Not applicable — The Project is not located within any of
Critical Habitat - For proposed activities within
the Western NC Counties that drain into Designated
waters of the United States that require a Pre-
Critical Habitat.
Construction Notification (PCN) and are located in
the sixteen Western NC counties, permittees must
provide a copy of the PCN to the U.S. Fish and
Wildlife Service (USFWS).
2.2 Special Designation Waters - Prior to the use of
The Project crosses several Special Designation
any NWP, except NWP 3, that involves a
Waters (See Appendix K-2). This application serves as
discharge of dredged or fill material in any of the
the pre -construction notification for those activities
following identified waters and/or adjacent
within waters of United States that meet the Special
wetlands in North Carolina, permittees shall
Designation Waters criteria identified within the
submit a PCN to the District Engineer prior to
notification procedures for work in North Carolina.
commencing the activity.
2.3 Coastal Area Management Act Areas of
Not applicable — The Project is not located within the
Environmental Concern - Non-federal permittees
North Carolina coastal zone.
for any NWP in a designated "Area of
Environmental Concern" (AEC) in the twenty (20)
counties of Eastern North Carolina covered by the
North Carolina Coastal Area Management Act
(CAMA) must also obtain the required CAMA
permit. Development activities for non-federal
projects may not commence until a copy of the
approved CAMA permit is furnished to the
appropriate Wilmington District Regulatory Field
Office.
N-3-1 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-3
MVP Southgate Compliance with Nationwide Permit General Regional Conditions for the Wilmington
District
Condition
Southgate Project Compliance Statement
2.4 Barrier Islands - Prior to the use of any NWP on a
Not applicable — The Project is not located on a barrier
barrier island of North Carolina, permittees must
island.
submit a PCN to the District Engineer prior to
commencing the activity.
2.5 Mountain or piedmont bogs - Prior to the use of
Not applicable — The Project is not located on a
any NWP in a Bog, as classified by the North
mountain or piedmont bog.
Carolina Wetland Assessment Methodology
(NCWAM), permittees shall submit a PCN to the
District Engineer prior to commencing the activity.
2.6 Animal Waste Facilities - Prior to use of any NWP
Not applicable — The Project does not involve the
for construction of animal waste facilities in waters
construction of an animal waste facility.
of the United States, including wetlands,
permittees shall submit a PCN to the District
Engineer prior to commencing the activity.
2.7 Trout Waters - Prior to any discharge of dredge or
Not applicable — The Project does cross any streams,
fill material into streams, waterbodies or wetlands
waterbodies or wetlands within a designated trout
within the 294 designated trout watersheds of
watershed.
North Carolina, the permittee shall submit a PCN
(see General Condition 32) to the District
Engineer prior to commencing the activity. The
permittee shall also provide a copy of the
notification to the appropriate NCWRC office, or to
the EBCI FWM Office (if the project is located on
EBCI trust land), to facilitate the determination of
any potential impacts to designated Trout Waters.
2.8 Western NC Waters and Corridors - The permittee
Not applicable - The Project is not located within any of
shall submit a PCN to the District Engineer prior
the listed waters of western North Carolina or within 0.5
to commencing the activity in waters of the United
miles on either side of the respective water.
States if the activity will occur within any of the
following identified waters in western North
Carolina, within 0.5 mile on either side of these
waters, or within 0.75 mile of the Little Tennessee
River, as measured from the top of the bank of the
respective water (i.e., river, stream, or creek).
3.0 List of Corps Regional Conditions for All Nationwide Permits
3.1 Limitation of Loss of Stream Bed - NWPs may not
See Section 2.4.4 and 2.5.1 of the Project narrative.
be used for activities that may result in the loss or
The Project will not result in the loss or degradation of
degradation of more than 300 total linear feet of
more than 300 linear feet of stream bed. All streams
stream bed, unless the District Engineer has
temporarily impacted during construction will be
waived the 300 linear foot limit for ephemeral and
restored to pre -construction conditions.
intermittent streams on a case -by -case basis and
has determined that the proposed activity will
result in minimal individual and cumulative
adverse impacts to the aquatic environment.
Waivers for the loss of ephemeral and intermittent
streams must be in writing and documented by
appropriate/accepted stream quality
assessments. This waiver only applies to the 300
linear feet threshold for NWPs.
N-3-2 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-3
MVP Southgate Compliance with Nationwide Permit General Regional Conditions for the Wilmington
District
Condition
Southgate Project Compliance Statement
3.2 Mitigation for Loss of Stream Bed - For any NWP
Not applicable — The Project will not result in the loss of
that results in a loss of more than 150 linear feet
stream bed(s).
of stream, the permittee shall provide a mitigation
proposal to compensate for more than minimal
individual and cumulative adverse impacts to the
aquatic environment. For stream losses of 150
linear feet or less that require a PCN, the District
Engineer may determine, on a case -by -case
basis, that compensatory mitigation is required to
ensure that the activity results in minimal adverse
effect on the aquatic environment.
3.3 Pre —construction Notification for Loss of Streambed
Not applicable — The Project will not result in the loss of
Exceeding 150 feet - Prior to use of any NWP for
stream bed(s).
any activity which impacts more than 150 total
linear feet of perennial stream, intermittent or
ephemeral stream, the permittee shall submit a
PCN to the District Engineer prior to commencing
the activity.
3.4 Restriction on Use of Live Concrete - For all NWPs
See Section 4.4 of the Project narrative. The Project
which allow the use of concrete as a building
will not allow live or fresh concrete to come into contact
material, live or fresh concrete, including bags of
with waters of the United States.
uncured concrete, may not come into contact with
the water in or entering into waters of the United
States. Water inside coffer dams or casings that
has been in contact with wet concrete shall only
be returned to waters of the United States after
the concrete is set and cured and when it no
longer poses a threat to aquatic organisms.
3.5 Requirements for Using Riprap for Bank
The Project does not anticipate the use of riprap for
Stabilization
stream bank stabilization purposes. In the event that
3.5.1. Where bank stabilization is conducted as part of
riprap is required for bank stabilization purposes, the
an activity, natural design, bioengineering and/or
Project will adhere to the general conditions.
geoengineering methods that incorporate natural
durable materials, native seed mixes, and native
plants and shrubs are to be utilized to the
maximum extent practicable.
3.5.2. Filter cloth must be placed underneath the riprap
as an additional requirement of its use in North
Carolina waters. The placement of filter fabric is
not required if the riprap will be pushed or "keyed"
into the bank of the waterbody.
3.5.3. The placement of riprap shall be limited to the
areas depicted on submitted work plan drawings.
3.5.4. The riprap material shall be clean and free from
loose dirt or any pollutant except in trace
quantities that would not have an adverse
environmental effect.
3.5.5. It shall be of a size sufficient to prevent its
movement from the authorized alignment by
natural forces under normal conditions.
3.5.6. The riprap material shall consist of clean rock or
masonry material such as, but not limited to,
granite, marl, or broken concrete.
N-3-3 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-3
MVP Southgate Compliance with Nationwide Permit General Regional Conditions for the Wilmington
District
Condition
Southgate Project Compliance Statement
3.6 Requirements for Culvert Placement
See Section 2.4.4 of the Project narrative. The pre-
3.6.1 For all NWPs that involve the
construction stream conditions will not be altered as the
construction/installation of culverts, measures
result of a newly installed culvert. Culverts will be
will be included in the construction/installation
installed in a manner so that passage will still be
that will promote the safe passage of fish and
possible for fish and aquatic organisms during the
other aquatic organisms. The dimension, pattern,
average historical low flow and spring flow.
and profile of the stream above and below a pipe
or culvert should not be modified by altering the
width or depth of the stream profile in connection
with the construction activity. The width, height,
and gradient of a proposed culvert should be
sufficient to pass the average historical low flow
and spring flow without adversely altering flow
velocity.
3.7 Notification to NCDEQ Shellfish Sanitation Section
Not applicable — The Project is not located in any areas
- Permittees shall notify the NCDEQ Shellfish
where shell fishing occurs.
Sanitation Section prior to dredging in or removing
sediment from an area closed to shell fishing
where the effluent may be released to an area
open for shell fishing or swimming in order to
avoid contamination from the disposal area and
cause a temporary shellfish closure to be made.
3.8 Submerged Aquatic Vegetation - Impacts to
Not applicable — The Project does not cross any areas
Submerged Aquatic Vegetation (SAV) are not
of Submerged Aquatic Vegetation.
authorized by any NWP, except NWP 48, unless
EFH Consultation has been completed pursuant
to the Magnuson -Stevens Fisheries Conservation
and Management Act (Magnuson -Stevens Act).
Permittees shall submit a PCN to the District
Engineer prior to commencing the activity if the
project would affect SAV.
3.9 Sedimentation and Erosion Control Structures
As stated in the August 2019 Re -Application, the
and Measures -All PCNs will identify and describe
Project will adopt the Southgate Plan and Procedures
sedimentation and erosion control structures and
to minimize impacts on the environment. The Project
measures proposed for placement in waters of the
submitted a 10-mile section of Project -specific Erosion
United States. The structures and measures
and Sediment Control Plans ("E&SC") to NCDEQ for
should be depicted on maps, surveys or drawings
review in January 2020.
showing location and impacts to jurisdictional
wetlands and streams.
3.10 Restoration of Temporary Impacts to Stream Beds
See Section 2.5.1 of the Project narrative. Completed
- Upon completion of work that involves temporary
stream crossings using the flume or dam and pump
stream impacts, streambeds are to be restored to
methods will be stabilized before returning flow to the
pre -project elevations and widths using natural
channel. Areas disturbed will be restored to pre-
streambed material such that the impacted stream
construction or better conditions. Streambed
reach mimics the adjacent upstream and
substrate will be segregated from other soils and will
downstream reach.
be backfilled into the stream once the pipeline is laid.
Original streambed and bank contours will be re-
established for surface water and groundwater flow,
and mulch, jute thatching, or bonded fiber blankets will
be installed on the stream banks, which are
preferential to plastic erosion control blankets because
N-3-4 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-3
MVP Southgate Compliance with Nationwide Permit General Regional Conditions for the Wilmington
District
Condition I Southgate Project Compliance Statement
3.11 Restoration of Temporary Impacts to Stream
Banks - Upon completion of work involving
temporary stream bank impacts, stream banks
are to be restored to pre -project grade and
contours or beneficial grade and contours if the
original bank slope is steep and unstable. Natural
durable materials, native seed mixes, and native
plants and shrubs are to be utilized in the
restoration.
they reduce wildlife entrapment and are
biodegradable. Where the flume technique is used,
stream banks will be stabilized before removing the
flume pipes and returning flow to the waterbody
channel.
See Section 2.5.1 of the Project narrative. Completed
stream crossings using the flume or dam and pump
methods will be stabilized before returning flow to the
channel. Areas disturbed will be restored to pre -
construction or better conditions. Streambed
substrate will be segregated from other soils and will
be backfilled into the stream once the pipeline is laid.
Original streambed and bank contours will be re-
established for surface water and groundwater flow,
and mulch, jute thatching, or bonded fiber blankets will
be installed on the stream banks, which are
preferential to plastic erosion control blankets because
they reduce wildlife entrapment and are
biodegradable. Where the flume technique is used,
stream banks will be stabilized before removing the
flume pipes and returning flow to the waterbody
channel. Seeding of disturbed stream approaches
with native seed mixes will be completed in
accordance with the Southgate Procedures after final
grading, weather and soil conditions permitting.
1 3.12 Federal Navigation Channel Setbacks and Corps Easements
3.12.1 Authorized structures and fills located in or
adjacent to Federally authorized waterways will
be constructed in accordance with the latest
setback criteria established by the Wilmington
District Engineer.
3.12.2 The permittee shall obtain a Consent to Cross
Government Easement from the Wilmington
District's Land Use Coordinator prior to any
crossing of the Corps easement and/or prior to
commencing construction of any structures,
authorized dredging or other work within the
right-of-way of, or in proximity to, a federally
designated disposal area.
3.13 Northern Long-eared Bat — Endangered Species
Act Compliance - The Wilmington District, U.S.
Army Corps of Engineers has consulted with the
United States Fish and Wildlife Service (USFWS)
regarding the threatened Northern long-eared bat
(NLEB) (Myotis septentrionalis) and Standard
Local Operating Procedures for Endangered
Species (SLOPES) have been approved by the
Corps and the USFWS. This condition concerns
Not applicable — The Project is not located in a federal
navigation channel and is not located adjacent to a
Federally -authorized waterway.
Not applicable — The Project does not cross any Corps
easements.
See Section 5.5.3 of the Project narrative. The Project
conducted mist net surveys for rare bat species
including northern long-eared bat in 2018. Based on
the lack of species occurrence during summer
sampling, all federally listed species are assumed
absent or present in such low density as for impacts to
be inconsequential and Federal requirements for the
Project under Section 7(a)(2) of the ESA are met.
N-3-5 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-3
MVP Southgate Compliance with Nationwide Permit General Regional Conditions for the Wilmington
District
Condition
Southgate Project Compliance Statement
effects to the NLEB only and does not address
effects to other federally listed species and/or
federally designated critical habitat.
3.14 Work on Eastern Band of Cherokee Indians Land
Not applicable — The Project is not located within
- All PCNs submitted for activities in waters of the
Eastern Band of Cherokee Indians land.
United States on Eastern Band of Cherokee
Indians (EBCI) trust land (i.e., Qualla Boundary
and non-contiguous tracts of trust land), must
comply with the requirements of the latest MOU
between the Wilmington District and the Eastern
Band of Cherokee Indians.
N-3-6 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-4
Southgate Project Compliance with Wilmington District Additional Regional Conditions
for Nationwide Permit 12 Utility Line Activities
Condition
Southgate Project Compliance Statement
Pipeline/utility line construction through jurisdictional waters and
Impacts have been avoided and minimized to
wetlands will be accomplished utilizing directional drilling/boring
the extent practicable through the routing
methods to the maximum extent practicable.
alternatives analysis discussed in the August
2019 Re -Application. Subsequent to the Re -
Application, the Project has incorporated use
of conventional bore to further avoid impacts.
See Updated Appendices L-1 and L-2 for
additional information — to be submitted in
April of 2020.
Temporary discharge of excavated or fill material into wetlands
See Section 2.4.3 and Section 4.4 of the
and waters of the United States will be for the absolute minimum
Project narrative. The Southgate Project will
period of time necessary to accomplish the work. Temporary
conduct construction across waterbodies in
discharges will be fully contained with appropriate erosion control
accordance with the Southgate Procedures.
or containment methods or otherwise such fills will consist of non-
The normal trenching operations will skip the
erodible materials.
waterbody crossing, stopping on each side
near the top of bank. The Project will install
the waterbody section of the pipeline by one of
the methods described below. In general,
pipe will be bent and fabricated as the work
progresses along the right-of-way so that the
excavation of the waterbody crossing is
completed prior to pipe installation by the tie-in
crew.
The work area authorized by this permit, including temporary
See Section 2.3.1 of the Project narrative.
and/or permanent fills, will be minimized to the greatest extent
The pipeline will generally require a 100-foot-
practicable. Justification for work corridors exceeding forty (40) feet
wide construction right-of-way (limit of
in width is required and will be based on pipeline diameter and
disturbance) during construction within
length, size of equipment required to construct the utility line, and
uplands and 75 feet of workspace within
other construction information deemed necessary to support the
wetlands. The temporary workspace is
request. The permittee is required to provide this information to the
necessary for worker safety, the safe travel of
Corps with the initial notification package.
construction vehicles and equipment,
stockpiling soil, and installation of erosion and
sediment controls. The proposed right-of-way
width are consistent with the Interstate Natural
Gas Association of America's ("INGAX)
recommendations for a pipeline diameter of 18
to 24 inches. INGGA recommends the use of
a 95-foot baseline width and increasing or
decreasing this baseline width for special
conditions (Gulf Interstate Engineering, 1999).
Excavated materials shall be returned to the excavated areas and
See Section 2.4.2 of the Project narrative.
any remaining materials shall be disposed of in uplands, unless the
Excess soil will be distributed evenly on the
Corps authorizes disposal in waters of the United States. In areas
right-of-way in accordance with landowner and
where a sub -aqueous utility line is to cross a federally -maintained
agency requirements, only in upland areas
channel, (i.e., the Atlantic Intracoastal Waterway [AIWWj), the line
and only to meet the pre -construction surface
will be buried at least six (6) feet below the allowable over depth of
elevations.
the authorized channel, including all side slopes. For areas outside
federally -maintained channels, sub -aqueous lines must be
See Section 2.4.1 of the Project narrative.
installed at a minimum depth of two (2) feet below the substrate
The pipeline will be buried a minimum of three
when such lines might interfere with navigation.
feet below the ground surface except for
locations where the pipe will be installed within
rock. In those instances, the minimum depth
of cover will be two feet.
N-4-1 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-4
Southgate Project Compliance with Wilmington District Additional Regional Conditions
for Nationwide Permit 12 Utility Line Activities
Condition
Southgate Project Compliance Statement
The minimum clearance for aerial communication lines, or any
Not applicable — The Project does not involve
lines not transmitting electrical power, will be ten (10) feet above
construction of aerial communication lines.
the clearance required for nearby stationary bridges as established
by the U.S. Coast Guard. In the event the U.S. Coast Guard has
not established a bridge clearance, minimum vertical clearances
for power and aerial lines will not be less than required by Section
23, Rule 232, of the latest revision of the National Electrical Safety
Code (American National Standards Institute C2). Clearances will
not be less than shown in Table 232-1, Item 7, American National
Standards Institute C2.
The minimum clearance for an aerial line, transmitting electrical
Not applicable — The Project does not involve
power, is based on the low point of the line under conditions that
construction of electrical transmission lines.
produce the greatest sag, taking into consideration temperature,
load, wind, length or span and the type of supports. The minimum
clearance for an aerial electrical power transmission line crossing
navigable waters of the United States, where there is an
established bridge clearance established by the U.S. Coast Guard,
shall be governed by the system voltage.
On navigable waters of the United States, including all federal
Not applicable — The Project does not cross
navigation projects, where there is no bridge for reference for
any navigable waters of the United States.
minimum clearance, the proposed project will need to be reviewed
by the Corps in order to determine the minimum clearance
between the line and MHW necessary to protect navigational
interests.
A plan to restore and re -vegetate wetland areas cleared for
See Section 2.5 of the Project narrative. Upon
construction must be submitted with the required PCN. Cleared
completion of the pipeline installation, the
wetland areas shall be re -vegetated to the maximum extent
surface of the right-of-way disturbed during
practicable with native species of canopy, shrub, and herbaceous
construction activities will be graded to match
species. Fescue grass shall not be used.
original contours and to be compatible with
surrounding drainage patterns. Segregated
topsoil will be replaced in unsaturated
wetlands. Unsaturated wetlands will be
allowed to revegetate naturally, as the seed
bank will be maintained within the topsoil
layer. Wetland revegetation will be considered
successful when the cover of herbaceous
and/or woody species is at least 80 percent of
the type, density, and distribution of the
vegetation in adjacent wetland areas that were
not disturbed by construction. Revegetation
efforts will continue until wetland revegetation
is successful based on the Southgate
Procedures and other applicable regulatory
approvals.
Any permanently maintained corridor along the utility right of way
See Section 4.1.2 of the Project narrative. The
within forested wetlands shall be considered a permanent impact.
Southgate Project will provide compensatory
A compensatory mitigation plan will be required for all such
mitigation for the conversion of all forested
impacts associated with the requested activity if the activity
wetland to non -forested wetland through
requires PCN and the cumulative total of permanent forested
purchase of wetland mitigation credits at a 1:1
wetland impacts exceeds 1/10-acre, unless the District Engineer
ratio from an approved mitigation bank with a
determines in writing that either some other form of mitigation
service territory covering the watershed where
would be more environmentally -appropriate or the adverse effects
the impacts would occur.
of the proposed activity are minimal.
N-4-2 March 2020

Ir Mountain Valley
PIPELINE L,
Joint Permit Application Addendum
USACE — Wilmington District and NCDEQ
SAW-2018-008887
Appendix N-4
Southgate Project Compliance with Wilmington District Additional Regional Conditions
for Nationwide Permit 12 Utility Line Activities
Condition
Southgate Project Compliance Statement
Use of rip -rap or any other engineered structures to stabilize a
The Project does not currently propose to use
stream bed should be avoided to the maximum extent practicable.
rip -rap or other engineered structures to
If riprap stabilization is needed, it should be placed only on the
stabilize stream beds. If determined to be
stream banks, or, if it is necessary to be placed in the stream bed,
needed, the Project will request permission
the finished top elevation of the riprap should not exceed that of
from the USACE and NCDEQ and would meet
the original stream bed. When directional boring or horizontal
these conditions.
directional drilling (HDD) under waters of the United States,
including wetlands, permittees shall closely monitor the project for
See Section 2.4.4 and Appendix H. The
hydraulic fracturing or "fracking." Any discharge from hydraulic
Project has submitted a HDD Contingency
fracturing or "fracking" into waters of the United States, including
Plan to address disposal of drilling fluid as well
wetlands, shall be reported to the appropriate Corps Regulatory
as protocols to be implemented in the unlikely
Field Office within 48 hours. Restoration and/or compensatory
event of an inadvertent release of drilling fluid
mitigation may be required as a result of any unintended
to waters of the United States.
discharges.
For purposes of this NWP, the term utility line does not include
Noted
pipes or culverts associated with driveways, roadways, lots, etc.
The permittee shall submit a PCN to the District Engineer prior to
This application serves as the pre -construction
commencing the activity if the activity will involve the discharge of
notification for those activities within waters of
dredged or fill material into more than 1/1 0-acre of wetlands or 150
United States that meet the criteria identified
linear feet of stream channel for the construction of temporary
within the notification procedures for work in
access fills and/or temporary road crossings. The PCN must
North Carolina. See Section 2.5 of the Project
include a restoration plan that thoroughly describes how all
narrative for information regarding restoration.
temporary fills will be removed, describes how pre -project
conditions will be restored, and includes a timetable for all
restoration activities.
N-4-3 March 2020