20140957 Ver 2_ACP_AddInfo3_10-19-17_KH_20171019

This office has questions regarding your responses to our September 14, 2017 request for
additional information letter. The Division has determined that the following additional
information is necessary to continue to process your application [15A NCAC 02H .0502(c), 15A
NCAC 02B.0233(8) and .0259 (8)1:
1. Crossing plans for each open cut proposed were provided in response to Lb.i. Modify
the scale on the profile of each sheet to reflect the range of elevation on the specific
plan sheet instead of the range of elevation for the entire project.
2. A narrative description was provided for turbidity and TDS sampling protocol in
response to Lb.i. Modify/incorporate the following into your sampling protocol:
a. The second monitoring event will occur 2-6 hours after start of instrearn
construction.
b. During construction: if monitoring shows turbidity exceeclances and/or TDS
violations, work will stop until the source is identified and remediated.
Measures will be re-evaluated moving forward to ensure further exceeclances
and/or violations do not continue.
c. Records of all turbidity and TDS sampling will be retained by Atlantic for a period
of — and provided to the Division of Water Resources upon request.
d. There is no averaging for stream standards; remove language regarding 4 -day
average for post -construction monitoring.
e. In addition to the perennial waterbody crossings identified by Atlantic, this
sampling protocol will be employed at intermittent streams if water is present in
the right of way at the start of construction activities for that crossing.
3. Inundation response to Lb.ii –wording from JB
4. In your response to 1.b.v you state:
"[sltreom crossings where the banks are deeply incised and narrow would be an example
where a temporary bridge would not be used."
In your response to 2 you state:
"flln instances where streambanks are incised prior to construction, Atlantic would grade the
banks to a stable slope and toper the new contours into the adjacent, undisturbed conditions
outside of the right-of-way as part of the restoration of streambanks."
In your response provided on October 13 you state:
"Atlantic does not anticipate crossing incised streams in North Carolina, and therefore Atlantic
is not providing a typical drawing for incised stream restoration."
a. Explain this discrepancy.
b. If Atlantic is not crossing any incised streams in North Carolina, under what
circumstances would a temporary bridge not be used?
c. If Atlantic is not crossing any incised streams in North Carolina, under what
circumstances would stream banks not be restored to preconstruction
conditions?

5. In your response to Lc you state you anticipate using Type 1 but will use Type 2 if Type
1 is unsuccessful.
a. Explain why you "anticipate" but do not know with confidence what type of
restoration you will use at each crossing.
b. What is the timeframe Atlantic will determine if stabilization is unsuccessful?
What is the timeframe within which Type 2 will be installed?
c. You state that rock riprap or geogrid will not be place below the ordinary high
watermark, however the plans provided in Appendix B show riprap below the
ordinary high watermark. Correct this discrepancy in either the narrative or the
plans. Note that placing rip rap below the ordinary high water mark may require
a permit from the U.S. Army Corps of Engineers and a certification from the
Division.
d. In your response to 2. you state "[ilf waterbody flow forces require greater
stabilization, Atlantic would use riprop or a geogrid type material, as outlined in
response to item 1.c. above.", which is different than using Type 2 only if Type 1
fails. Explain this discrepancy.
e. Two types of restoration plans were provided however they were not assigned
to each stream crossing as requested. Assign Type 1 orType 2 to each stream
crossing listed in your impact table.
6. In your response to 2. you state "Atlantic will use clean rock over culverts for access across
the majority of streams crossed by the pipeline that are otherwise too wide to be crossed by a
single timber mat bridge." What is "too wide"?
7. Also in your response to 2. you state "[tlimber mats supported byflumes will be usedfor
access across streams crossed by the pipeline that have too much flowfor use of clean rock over
culverts." What is "too much flow"?
8. In 6.c. the Division requested a cumulative impact analysis for Johnston, Cumberland
and Robeson Counties, however we received a cumulative analysis only for the
construction footprint of the three M&R stations within those counties.
a. As previously requested, provide a qualitative cumulative impact analysis for all
of Johnston, Cumberland and Robeson Counties not just the construction
footprint of the M&R stations. Refer to the Division's Cumulative Impact Policy
for the 401 and Isolated Wetland Permitting Programs (Ver2.1, dated April 10,
2004) for guidance, available online:
https://files.nc.gov/ncdeg/Water`/�20Quality/Surface�/�2OWater�/�2OProtection 4
L
Ol/Policies Guides Manuals/CumulativeimpactPolicy.pd .
b. Note this analysis is for pastor reasonably anticipated future impacts, which
would include expansion of the pipeline beyond the current terminus in Robeson
County.
c. Attachment 1 in the cumulative impact analysis:
There were several duplicate entries. Remove any duplicate projects
from the Table.

There are several Atlantic projects listed (e.g. Atlantic Coast Pipeline
Office Building, Atlantic Coast Pipeline Utility Services, etc.). These
should be part of the current application under review, not listed within
the Table as projects that may have a cumulative impact. Remove these
from the Table and confirm that these projects are included within the
current application under review.
iii. Add a column to indicate which projects have or you anticipate to have
impacts to surface waters.