20181638 Ver 3_More Info Requested_20190923

ROY COOPER
Governor
MICHAEL S. REGAN
Secretory
LINDA CULPEPPER
Director
Mountain Valley LLC
Attn: Kathy Salvaor
700 Universe Boulevard
Juno Beach FL 33408
NORTH CAROLINA
Environmental Quality
September 23, 2019
DWR # 20181638 v3
Alamance & Rockingham Counties
Subject: REQUEST FOR ADDITIONAL INFORMATION
Mountain Valley Pipeline — Southgate (MVP Southgate)
Dear Ms. Salvaor:
On August 14, 2019, the Division of Water Resources (Division) received your application dated August
9, 2019, requesting a 401 Individual Water Quality Certification and Jordan Lake Buffer Authorization
(15A NCAC 02B .0267) from the Division for your project. The Division has determined that your
application is incomplete and cannot be processed. The application is on -hold until all of the following
information is received:
Public Hearing — The Director has determined that it is in the public's interest to hold a public
hearing to receive public comment and additional information on the proposed project. This
hearing must be held prior to taking final action on your application. The Division is in the
process of scheduling the public hearing and will forward the details by separate letter. [15A
NCAC 02H .0503(f)]
2. Provide a qualitative cumulative impact analysis for the project. The analysis should follow the
procedure/guidance outlined in the Division's Cumulative Impact Policy for the 401 and Isolated
Wetland Permitting Programs (Ver2.1, dated April 10, 2004), available online:
https://files.nc.gov/ncdeg/Water%20Quality/Surface%2OWater/o2OProtection/401/Policies Gui
des Manuals/Cum ulativelmpactPolicy.Of 115A NCAC 02H .0506(b)(4)]
Provide the exact locations and rate of discharge for the hydrostatic test water to be used within
the Project. [15A NCAC 02H .0506(b)(3)]
4. Appendix I — HDD Contingency Plan Page 7 states "Technical data sheets for the more typical
benign and environmentally friendly products that are approved for use by the Project are
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mall Service Center I Raleigh, North Carolina 27699-1617
rx�+ncu+o�eN �
919.707.9000

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included in Appendix A." Please provide these technical data sheets. [15A NCAC 02H
.0506(b)(3)]
The Division's review of the documents submitted with the application has identified
discrepancies between the following exhibits:
• Wetland and Waterway Delineation Maps
• Pipeline Alignment sheets
• Proposed Pipeline Route and Impacts sheets
• Wetland Impact Table
• Stream Impact Table
The inconsistencies in these exhibits include:
• pipeline corridor location
• access road location
• jurisdictional features and impacts.
Please submit updated exhibits that incorporate the most recent available data. Please ensure
that the various sheets/maps correspond with each other, as well as other available documents
such as the ATWS variance tables filed with FERC, with regards to jurisdictional features,
alignment corridors, access road locations, additional temporary workspace locations and
impact locations and amounts. [15A NCAC 02H .0506(b)]
The following comments are made in reference to the Proposed Pipeline Route and Impacts sheets
(Appendix M):
6. At various locations within the project corridor, it appears that impacts could be avoided with a
minor realignment or reduction of the construction corridor. Please review these areas and
propose further avoidance and minimization, or provide site-specific justification of why these
impacts could not be avoided or further minimized: [15A NCAC 02H .0506(b)(2)]
a. Sheet 3, W -A18-44
b. Sheet 21, W -C18-40
c. Sheet 94, 5-618-11, Buffer Zone Impacts for workspace
d. Sheet 102, Parallel Buffer Zone Impacts at approximately MP 72.7
e. Sheet 108, appears that minor revision to norther boundary of CY-26B would reduce
impacts to the adjacent buffer in this location
7. On Sheet 4, impacts are noted for both Cascade Creek and Dry Creek at MP27.5, however the
Stream Impact Table notes that Cascade Creek is to be crossed using a Conventional Bore
method, but Dry Creek is to be crossed using typical dewatering methods. Please explain why
the Conventional Bore method is not proposed for the Dry Creek crossing, given its adjacency to
Cascade Creek within the Construction Corridor. [15A NCAC 02H .0506(b)(2)]
8. Please review the Proposed Pipeline Route and Impacts sheets to confirm that in all wetland and
waterbody impact locations the construction corridor width has been reduced to 75 feet where

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proposed. Section 4.4 of the application notes that the construction right-of-way width will be
reduced "unless alternative, site specific measures are requested by the Project and approved
by FERC and other applicable agencies". If you are proposing a construction corridor greater
than 75 feet through any wetland or waterbody please provide a clear identification/list of those
locations a detailed site-specific justification for each location. Please note that although in
some locations a stream or wetland may not be present within the entire width of the
construction corridor, a reduction in the corridor to 75 feet would still provide avoidance and
minimization, and therefore should still be justified on site-specific merit, not solely the length
of the stream or wetland within the corridor. Please also update the impact quantities as
appropriate. Examples of locations noted as having a greater than 75 -foot construction corridor
are: [15A NCAC 02H .0506(b)(2)]
a. Sheet 5, MP 28.0, W -A18-39 PEM and W -A18-26 PEM
b. Sheet 10 MP 30, W -A18-18 PFO.
c. Sheet 29, MP 38.7, W -A18-7 (7-2 through 7-7)
d. Sheet 32, MP 40.5 RR, S -A18-210 and S -A18-210-2
e. Sheet 55, MP 50.5, SS -SOIL -18-02
f. Sheet 59, MP 52.4, AS -A18-219
g. Sheet 61, MP 53.4, W -A18-83
h. Sheet 62, MP 53.7, W -A18-85
L Sheet 63, MP 54.4, W -C18-67
j. Sheet 81, MP 63.0, AS -618-24
k. Sheet 85 MP 65, S -A19-319 and W -A19-320
I. Sheet 86, MP 65.1, S -A19-321 and S -A19-324
m. Sheet 87, MP 65.5, W-1319-168
n. Sheet 92, MP 67.9, SS -SOIL 19-12
o. Sheet 93, MP 68.3, 5-1318-3
p. Sheet 102, Parallel Buffer Zone Impacts at approximately MP 72.7.
9. The application proposes to adhere to a 30 -foot operational workspace (10 feet regularly
mowed, and trees removed within 15 feet on either side of the pipeline) as required by FERC for
intermediate and major waterbodies and all wetlands. Provide a detailed justification why the
operational workspace cannot be reduced to 30 feet in for all other streams within the project.
[15A NCAC 02H .0506(b)(2)]
10. On Sheet 29, stream construction impacts have been identified for Wolf Island Creek however
the application notes that Wolf Island Creek is to be crossed by Conventional Bore. Please
clarify what the nature of the impacts to Wolf Island Creek is and please verify if adjacent
streams and wetlands impact are accurate given the location of the Bore entry and exit which
are not shown on the sheets. [15A NCAC 02H .0506(b)(2)]
11. The Division recognizes the Wetland and Waterbody Crossing Analysis that has been provided,
however we request additional information on the following specific locations: [15A NCAC 02H
.0506(b)(2)]

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a. Sheet 34, MP 41.2 - Given the size of Lick Fork and the adjacency of 2 tributaries and a
wetland, please provide further detailed analysis that incorporates the practicality of a
Conventional Bore which could avoid impacts to all 4 features at this location.
b. Sheet 39, MP 43.3 - Given the size of Jones Creek and the adjacency of a perennial
tributary, please provide further detailed analysis that incorporates the practicality of a
Conventional Bore which could avoid impacts to both features at this location.
c. Sheet 39 and 40, MP 43.7 - Given the size of the Tributary to Jones Creek (S -A18-105)
and that the stream runs parallel with, and directly over the pipeline in this location, and
the adjacency of a perennial tributary, please provide further detailed analysis that
incorporates the practicality of a Conventional Bore which could avoid impacts to both
features at this location.
d. Sheet 56, MP 50.8 - Given the size of the Tributary to Haw River (5-A19-286) and that
the stream runs parallel with, and directly over the pipeline in this location, and that the
Jordan Buffers also run parallel with the pipeline, please provide further detailed
analysis that incorporates the practicality of a Conventional Bore which would address
significant concerns the Division has regarding temporary impacts to and permanent
restoration of a large stream running parallel and immediately over the pipeline.
12. At various locations within the project corridor, streams are present and parallel with the
corridor/pipeline. Please provide site specific drawings indicating how these features are to be
impacted during construction activities and how they are to be restored upon construction
completion. The typical dewatering specifications provided with the application for stream
crossings are not sufficient for parallel impacts. Please also describe how downstream water
quality will be protected during construction activities when a stream is parallel within the
project corridor. Please provide site-specific restoration details for each of these locations. The
Division is specifically concerned with any proposal to restore the channel to pre -construction
location when the channel is parallel with the pipeline and within the operational workspace, as
long term maintenance activities are likely to have permanent impacts to the channels. The
following locations are noted as examples of this scenario: [15A NCAC 02H .0506(b)(2)]
a. Sheet 15, MP 32.0, S -A18-140, S -A18-143 and S -A18-144
b. Sheet 15 MP 32.2, S -A18-147
c. Sheet 21, MP 34.6 S -C18-38-2
d. Sheet 21, MP 34.7, S -C18-53
e. Sheet 28, MP 38.2, AS -APS -400
f. Sheet 28, MP 38.5, S -A18-4 and S -A18-4-2
g. Sheet 29, MP 38.8, S -A19-269 (if not avoided by adjacent Bore for Wolf Island Creek)
h. Sheet 39 and 40, MP 37.7, S -A18-105
i. Sheet 43, MP 45.6, S -A18-213
j. Sheet 56, MP 50.8, S -A19-286
13. On Sheet 48 at MP 47.4 two streams are shown within the corridor however only one stream is
called out with impacts. Please clarify.

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14. On Sheet 68, MP 56.5 and Sheet 69, MP 56.7, please provide a construction sequences and site-
specific details for how the pipeline will be constructed within these ponds in a manner which
will protect downstream water quality. Please also include a dewatering detail/sequence (if
applicable) and pond restoration detail for these locations. [15A NCAC 02H .0506(b)(2)]
The following comments are made specific to Jordan Buffer Rules and the portion of the project that lies
within the Jordan Lake Watershed. [15A NCAC 02B.0267]
15. Provide a copy of the most recent USGS 1:24,000 map and published soil survey map with the
proposed corridor as an overlay on each set of maps. The scale must be such that all streams as
shown on these maps are easily identifiable. Please label all streams shown on these maps with
the nomenclature used throughout the application documents.
16. Provide specific details of how diffuse flow shall be maintained for all above ground facilities
within the Jordan Lake Watershed in order to document compliance with the diffuse flow
provisions of the Jordan Buffer Rules.
17. Provide a detailed buffer restoration plan for all temporary workspace areas within Zone 1 that
are not within the operational corridor shown on the plans. The plan must include a replanting
plan, a vegetation monitoring plan, and proposed success criteria.
18. On Sheets 65 and Sheet 90, an access road is shown as impacting the buffer of a pond, however
it appears that a road already exists at this location. The existing road should be considered as
an "existing use" and buffer impacts should not be counted within the footprint of the existing
road. Buffer impacts should be shown only for widening/improvements to the road outside of
the existing footprint.
19. At the following locations please provide a detailed drawing at a more detailed scale which
clearly shows how buffer impacts were identified between separate buffer impacts/categories
(perpendicular vs. non -perpendicular)
a. Sheet 74, MP 59.2-59.3
b. Sheet 78, MP 61.8
20. It appears that there are buffer impacts along an intermittent stream that is unlabeled on Sheet
87 at MP 65.6 that serves as the outlet of the pond and joins S -A18-250 that have not been
shown on the Proposed Pipeline Route and Impact sheet.
21. It does not appear that the buffer impacts associated with a pond on Sheet 90 at MP 67.3 are
called out on the Sheet but appear on the Buffer Impact Table.
22. It does not appear that the buffer impacts on Sheet 95 at MP 69.1-2, which are called out on the
Sheet and include 33VAR and 34VAR, are tabulated on the Buffer Impact Table.
23. It does not appear that the buffer impacts on Sheet 102 at MP 72.7, which are called out on the
Sheet, are tabulated on the Buffer Impact Table.

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Pursuant to Title 15A NCAC 02H .0502(e) and 15A NCAC 02B .0267, the applicant shall furnish all of the
above requested information for the proper consideration of the application. Please respond in writing
within 30 calendar days of receipt of this letter by sending one (1) copy of all of the above requested
information to the 401 & Buffer Permitting Branch, 1617 Mail Service Center, Raleigh, NC 27699-1617
OR by submitting all of the above requested information through this
link: https://edocs.deg.nc.gov/Forms/Supplemental-Information-Form (note the DWR# requested on
the link is referenced above).
If all of the requested information is not received within 30 calendar days of receipt of this letter, the
Division will be unable to approve the application and it will be denied as incomplete. The denial of this
project will necessitate reapplication to the Division for approval, including a complete application
package and the appropriate fee.
Please be aware that you have no authorization under the Water Quality Certification Rules for this
activity and any work done within waters of the state may be a violation of North Carolina General
Statutes and Administrative Code.
Please contact Sue Homewood at 336-776-9693 or [e-mail] if you have any
questions or concerns.
Sincerely,
Jeffrey Poupart, Section Chief
Water Quality Permitting Section
Division of Water Resources
cc: Heather Patti, TRC Environmental Corporation (via email)
David Bailey, USACE Raleigh Regulatory Field Office (via email)
Olivia Munzer, NCWRC (via email)
Todd Bowers, EPA (via email)
Christopher A. Militscher, Chief, NEPA Section, Strategic Programs Office, USEPA, 61 Forsyth St
SW, Atlanta GA 30303
Maria Clark, NEPA Section — Region 4, USEPA, 61 Forsyth St SW, Atlanta GA 30303
DWR WSRO 401 files
DWR 401 & Buffer Permitting Unit