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Home My WebLink About20191640 Ver 3_Draft Permit Mod_final version_20191014 Dramby Environmental Consulting, Inc. Dramby Environmental Consulting • 2707 West Cary Street, Richmond, VA 23220 • (757) 894 -1673 September 19, 2019 Ms. Emily Thompson Washington Regulatory Field Office U.S. Army Corps of Engineers 2407 West 5th Street Washington, NC 27889 AND Mr. Anthony Scarbraugh Division of Water Resources – Water Quality Regional Operations Department of Environmental Quality 943 Washington Square Mall Washington, NC 27889 Subject: Piedmont Natural Gas – Line 439 Project Minor Permit Modification Submittal Greenville, North Carolina Emily and Anthony: On behalf of Piedmont Natural Gas, Dramby Environmental Consulting, Inc. (DEC) is pleased to provide you with the following minor permit modification submittal for the Line 439 Project located in Pitt County, North Carolina. This permit modification is being submitted in association with previously issued permits received by Piedmont Natural Gas noted below and included in Attachment A: • U.S. Army Corps of Engineers (USACE) Permit Number: SAW-2019-00181 a) Received on August 12, 2019 • North Carolina Department of Environmental Quality Number: DWR #18-1640 a) Received on April 26, 2019 The purpose of the proposed permit modification is a result of minor design changes that are necessary in order to rectify landowner constraints and safe construction accessibility that have surfaced since permit submittal. Similarly, other minor changes in design are also being requested by the General Contractor (Price Gregory) in order to provide additional construction techniques and sequencing scenarios to be implemented that has helped with further reducing, in many instances, impacts to wetland and stream resources and riparian buffers, while also increasing overall safety needed throughout the duration of construction. These required minor design changes, including the addition of a HDD installation, have been detailed on the updated graphics located in Attachment B (i.e., Updated Pre-Construction Notification Exhibits & Updated Riparian Buffer Exhibits). These changes are also generally summarized below: Ms. Emily Thompson – USACE Mr. Anthony Scarbraugh - NCDWR September 19, 2019 Page 2 of 4 • USACE Permit Number: SAW-2019-00181 (see attached graphics and associated tables for details; along with the updated USACE Water’s Upload Table) a) Wetland Temporary Impact = Previously permitted 18.49 acres (Updated = 18.25 acres; calculation does not include reduction of PUB Impact from 0.16 acres to 0.061 Acres) ▪ Overall reduction in 0.24 acres b) Wetland Permanent Conversion = Previously Permitted 13.739 acres (Updated = 13.73 acres) ▪ Overall reduction in 0.009 acres c) Wetland Permanent Loss – Previous 0.065 acres (Updated = 0.109 acres; calculation does not included increase of PUB Impact of 0.098 acre resulting from proposed fill of manmade farm pond; additional impacts can be associated with permanent access roads) ▪ Increase in 0.04 acres d) Tributaries Temporary – Previous 5,479 LF (Updated = 4,310 LF) ▪ Overall reduction of 1,169 LF e) Tributaries Permanent Impact = Previous 235 LF (Updated = 75 LF) ▪ Overall reduction of 160 LF • North Carolina Department of Environmental Quality Number: DWR #18-1640 (see attached graphics and tables for details; all other Riparian Buffer Impacts remained the same based on revised designs). a) Neuse River Riparian Buffer No. 1 (Sheet 3 of 87) ▪ Zone 1 Temporary • PSS – Increased 1,813.86 ft2 • Upland – Increased 452.24 ft2 ▪ Zone 2 Temporary • Upland – Increased 1,539.22 ft2 b) Neuse River Riparian Buffer No. 6 (Sheet 26 of 87) ▪ Zone 1 Temporary • Upland – Decreased 125.23 ft2 ▪ Zone 2 Temporary • Upland – Decreased 820.99 ft2 c) Tar River Riparian Buffer No. 24 (Sheet 71 of 87) ▪ Zone 1 Temporary • Upland – Decreased 3,018.23 ft2 ▪ Zone 2 Permanent • Upland – Decreased 294.47 ft2 ▪ Zone 2 Temporary • Upland – Decreased 2,927.91 ft2 d) Tar River Riparian Buffer No. 25 (Sheet 74 of 87) ▪ Zone 1 Permanent • Upland – Increased 214.19 ft2 • Modified Stream – Decreased 30.65 ft2 ▪ Zone 2 Permanent • Upland – Increased 25.91 ft2 Ms. Emily Thompson – USACE Mr. Anthony Scarbraugh - NCDWR September 19, 2019 Page 3 of 4 • Modified Stream – Decreased 11.98 ft2 e) Tar River Riparian Buffer No. 26 (sheet 75 of 87) ▪ Zone 1 Permanent • PSS – Increased 214.19 ft2 • Upland – Decreased 146.44 ft2 ▪ Zone 1 Temporary • PSS – Decreased 136.86 ft2 • Upland – Decreased 101.11 ft2 ▪ Zone 2 Permanent • Upland – Decreased 15.04 ft2 ▪ Zone 2 Temporary • Upland – Decreased 216.78 ft2 f) Tar River Riparian Buffer No. 27 (Sheet 76 of 87) ▪ Zone 1 Permanent • Upland – Decreased 74.76 ft2 ▪ Zone 1 Temporary • PFO – Decreased 1,027.36 ft2 • Upland – Decreased 87.22 ft2 ▪ Zone 2 Temporary • PFO – Decreased 5.07 ft2 • Upland – Decreased 498.61 ft2 g) Tar River Riparian Buffer No. 32 ▪ Zone 1 Permanent • PFO – Decreased 262.28 ft2 • Upland – Increased 240.15 ft2 ▪ Zone 1 Temporary • PFO – Decreased 1,172.16 ft2 • Upland – Decreased 202.10 ft2 ▪ Zone 2 Permanent • PFO – Increased 118.14 ft2 • Upland – Decreased 842.78 ft2 ▪ Zone 2 Temporary • PFO – Decreased 136.73 ft2 • Upland – Decreased 2,023.21 ft2 Updated – Neuse and Tar River Riparian Buffer Impacts Neuse River ▪ Zone 1 Temporary • PSS – Increased 1,813.86 ft2 • Upland – Increased 327.01 ft2 ▪ Zone 2 Temporary • Upland – Increased 718.23 ft2 Ms. Emily Thompson – USACE Mr. Anthony Scarbraugh - NCDWR September 19, 2019 Page 4 of 4 Tar River • Zone 1 Permanent • PFO – Decreased 262.28 ft2 • PSS – Increased 214.19 ft2 • MS – Decreased 30.65 ft2 • Upland – Increased 233.22 ft2 • Zone 1 Temporary • PFO – Decreased 2.199.52 ft2 • PSS – Decreased 136.86 ft2 • Upland – Decreased 3,408.66 ft2 • Zone 2 Permanent • PFO – Increased 118.14 ft2 • MS – Decreased 11.98 ft2 • Zone 2 Temporary • PFO – Decreased 141.80 ft2 • Upland – Decreased 5,666.51 ft2 No additional compensatory mitigation is being proposed at this time based on this permit modification submittal due to the proposed overall avoidance and minimization of impacts. Please contact me at (757) 894–1673 or at SDramby@Drambyenv.com should you have any questions or require additional information. Thank you for your time and consideration of this permit modification submittal and your continued support on the Line 439 project. On behalf of Piedmont Natural Gas, we look forward to a favorable response to our submittal. Sincerely, Dramby Environmental Consulting, Inc. J. Shearin Dramby Principal/Senior Regulatory Specialist