HomeMy WebLinkAbout20090381 Ver 1_401 Application_20090409PSNC ENERGY
A SCANA COMPANY
April 2, 2009
NC DWQ, 401 Wetlands Unit
1650 Mail Service Center
Raleigh, NC 27699-1650
09-0381
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Subject: NOTICE OF VIOLATION
NOV-2008-PC-0853
T-I IB Replacement 12" Steel Natural Gas Transmission/Distribution Line
To whom it may concern:
As proposed in our February 2, 2009, letter, PSNC seeks after-the-fact approval for
impacts related to the referenced project. To that end, attached is an application for 401
Water Quality Certification and buffer authorization. PSNC believes that permitting
these impacts as they currently exist is the best course of action to protect the safety and
integrity of our critical transmission pipeline and to keep the streams banks from eroding
and adversely impacting water quality.
In our previous letter, we state that we would seek a Major Variance to the Buffer Zone
rules. That is no longer the case. At the time of that writing, the PSNC work was thought
to be categorized by the Neuse River buffer rules as a "Non-electric utility: impacts other
than perpendicular crossing." Subsequent discussions with Lauren Witherspoon of
NCDENR have concluded that such a variance is not required, because the work should
have been categorized as "Protection of existing structures, facilities and streambanks
when this requires additional disturbance of the riparian buffer or the stream channel."
Thus the project is no longer "Allowable with Mitigation" but is classed as "Allowable."
If you have any questions about this application, please call me at (803) 217-6125.
Sincerely,
Darrell R. Shier, P.E.
Supervisor - Environmental Services
SCANA Corporation
PSNC Energy 1 800 Gaston Road • Post Office Box 1398 • Gastonia, North Carolina • 28053-1398 • www.psn(energy.com
Letter to NCDENR
April 2, 2009
Page 2
cc. Lauren Witherspoon, NCDENR
DWQ Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
Rusty Harris, PSNC, w/o attachment
Bill Rayner, PSNC, w/o attachment
Jerry Littlejohn, PSNC, w/o attachment
Scott Swindler, PSNC, w/o attachment
Tucker Bullock, PSNC, w/o attachment
Hagood Hamilton, SCANA, w/o attachment
Tom Effinger, SCANA, w/o attachment
09-0381
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Office Use Only:
Corps action ID no.
DWQ project no.
Form Version 1.3 Dec 10 2008
Pre-Construction Notification PCN Form
A. Applicant Information
1. Processing
1 a. Type(s) of approval sought from the
Corps:
® Section 404 Permit ? Section 10 Permit
1 b. Specify Nationwide Permit (NWP) number: NWP 12 or General Permit (GP) number: 3699
1 c. Has the NWP or GP number been verified by the Corps? ® Yes ? No
1 d. Type(s) of approval sought from the DWQ (check all that apply):
® 401 Water Quality Certification - Regular ? Non-404 Jurisdictional General Permit
? 401 Water Quality Certification - Express ® Riparian Buffer Authorization
1 e. Is this notification solely for the record
because written approval is not required? For the record only for DWQ 401
Certification:
? Yes ® No For the record only for Corps Permit:
? Yes ® No
1f. Is payment into a mitigation bank or in-lieu fee program proposed for mitigation
of impacts? If so, attach the acceptance letter from mitigation bank or in-lieu
fee program. ? Yes ® No
1g. Is the project located in any of NC's twenty coastal counties. If yes, answer 1h
below. ? Yes ® No
1 h. Is the project located within a NC DCM Area of Environmental Concern (AEC)? ? Yes ® No
2. Project Information
2a. Name of project: T-11 B Replacement
2b. County: Durham
2c. Nearest municipality / town: Durham
2d. Subdivision name: N/A
2e. NCDOT only, T.I.P. or state
project no: N/A
3. Owner Information
3a. Name(s) on Recorded Deed: N/A - PSNC has easement from property owners, and is therefore the project owner
3b. Deed Book and Page No.
3c. Responsible Party (for LLC if
applicable):
3d. Street address:
3e. City, state, zip:
3f. Telephone no.:
3g. Fax no.:
3h. Email address:
Page 1 of 11
PCN Form - Version 1.3 December 10, 2008 Version
4. Applicant Information (if different from owner)
4a. Applicant is: ? Agent ® Other, specify: Pipeline owner
4b. Name: D. Russell Harris, President and COO
4c. Business name
(if applicable): PSNC Energy
4d. Street address: PO Box 1398
4e. City, state, zip: Gastonia, NC 28053
4f. Telephone no.: 704 834-6622
4g. Fax no.: 704 810-3171
4h. Email address: RHARRIS5@scana.com
5. Agent/Consultant Information (if applicable)
5a. Name: Darrell Shier
5b. Business name
(if applicable): PSNC Energy
5c. Street address: PO Box 1398
5d. City, state, zip: Gastonia, NC 28053
5e. Telephone no.: 803 217 6125
5f. Fax no.: 803 217 7810
5g. Email address: dshier@scana.com
Page 2 of 11
PCN Form - Version 1.3 December 10, 2008 Version
B. Project Information and Prior Project History
1. Property Identification
1 a. Property identification no. (tax PIN or parcel ID): 0840-02-65-4640, 0840-02-66-3137, 0840-02-88-0797
Latitude: 35.965497 Longitude: -
1 b. Site coordinates (in decimal degrees): 78.842981
(DD.DDDDDD) (-DD.DDDDDD)
1 c. Property size: 8.634, 9.509, 7.359 acres
2. Surface Waters
2a. Name of nearest body of water (stream, river, etc.) to Little Lick Creek
proposed project:
2b. Water Quality Classification of nearest receiving water: Class C
2c. River basin: Neuse
3. Project Description
3a. Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of this
application:
The site consists of an existing natural gas and water pipeline corridor, which is mowed periodically. The surrounding
properties are a mix of undeveloped forest and light-density residential.
3b. List the total estimated acreage of all existing wetlands on the property:
0.19 acres
3c. List the total estimated linear feet of all existing streams (intermittent and perennial) on the property:
Little Lick Creek crosses the pipeline corridor twice (designated hereafter as S3 and S4), with about 255 linear feet of
stream within the project corridor. Another 73 linear feet of an unnamed, intermittent tributary to Little Lick Creek crosses
the corridor (designated hereafter as S1). Finally, a small turn (about 25 linear feet) of Little Lick Creek bends within, but
does not cross the corridor. There is total of approximately 333 linear feet of streams within the project corrdidor.
3d. Explain the purpose of the proposed project:
The T-11 & T-11 B high pressure transmission pipelines extend generally north-south from Stem to the southern edge of
the Research Triangle Park. They are a critical part of a larger network of transmission pipelines that supply natural gas
to a 10 county area including Raleigh, Durham, Chapel Hill, and Research Triangle Park. These pipelines were initially
installed in 1960 & 1963 to meet the customer growth and new development in this rapidly growing area. The current
replacement project was necessary to ensure safe and reliable operation of the T-11 B pipeline in the future and to ensure
compliance with applicable USDOT safety regulations
3e. Describe the overall project in detail, including the type of equipment to be used:
Prior to construction, erosion and sediment control measures were installed as detailed in the erosion control plan for the
project. The existing natural gas pipeline was excavated using trackhoes and other construction equipment. All used
pipe was hauled away for recycling and the trench was backfilled. All spoils were sidecast away from sterams and
wetlands. A trench was then cut in approximately the same location, again using trackhoes and other construction
equipment. After the new pipeline was welded and placed in the trench, the exc avation was backfilled and compacted.
The area was seeded and mulched to stabilize the area. Periodic inspections are now being performed and corrective
actions taken, as needed, to maintain a stablized site.
Page 3 of 11
PCN Form - Version 1.3 December 10, 2008 Version
4. Jurisdictional Determinations
4a. Have jurisdictional wetland or stream determinations by the
Corps or State been requested or obtained for this property /
project (including all prior phases) in the past?
? Yes ®No ? Unknown
Comments: No jurisdictional determination has been
conducted by the Corps or DWQ; however, the Corps has
agreed that the project meets the requirements of NWP-12
4b. If the Corps made the jurisdictional determination, what type
? Preliminary ? Final
of determination was made?
4c. If yes, who delineated the jurisdictional areas? Agency/Consultant Company:
Name (if known): Other:
4d. If yes, list the dates of the Corps jurisdictional determinations or State determinations and attach documentation.
5. Project History
5a. Have permits or certifications been requested or obtained for ® Yes ? No ? Unknown
this project (including all prior phases) in the past?
5b. If yes, explain in detail according to "help file" instructions.
A NWP 12 permit was previously requested from the Corp; however, the Corps did not act within 45 days, so the permit
was automatically granted. An NCDENR Erosion Control Permit, Project ID DURHA-2008-016, was granted to this
project.
6. Future Project Plans
6a. Is this a phased project? ? Yes ® No
6b. If yes, explain.
Page 4 of 11
PCN Form -Version 1.3 December 10, 2008 Version
C. Proposed Impacts Inventory
1. Impacts Summary
1 a. Which sections were completed below for your project (check all that apply):
® Wetlands ® Streams - tributaries ® Buffers
? Open Waters ? Pond Construction
2. Wetland Impacts
If there are wetland impacts proposed on the site, then complete this question for each wetland area impacted.
2a. 2b. 2c. 2d. 2e. 2f.
Wetland impact Type of jurisdiction
number - Type of impact Type of wetland Forested (Corps - 404, 10 Area of impact
Permanent (P) or (if known) DWQ - non-404, other) (acres)
Temporary T
W1 ? P ® T Excavation and fill Bottomland
Hardwood Forest ® Yes
? No ® Corps
® DWQ 0.02
W2 ? P ®T Excavation and fill Bottomland
Hardwood Forest ® Yes
? No ® Corps
® DWQ 0.15
W3 ? P ®T Excavation and fill Bottomland
Hardwood Forest ® Yes
? No ® Corps
® DWQ 0.02
W4 ? P ? T ? Yes ? Corps
? No ? DWQ
W5 ? P ? T ? Yes ? Corps
? No ? DWQ
W6 ? P ? T ? Yes ? Corps
? No ? DWQ
2g. Total wetland impacts 0.19
2h. Comments:
3. Stream Impacts
If there are perennial or intermittent stream impacts (including temporary impacts) proposed on the site, then complete this
question for all stream sites impacted.
3a. 3b. 3c. 3d. 3e. 3f. 3g.
Stream impact Type of impact Stream name Perennial Type of jurisdiction Average Impact
number - (PER) or (Corps - 404, 10 stream length
Permanent (P) or intermittent DWQ - non-404, width (linear
Temporary (T) (INT)? other) (feet) feet)
S1 ®P ? T Stabilization LIT to Little Lick ® PER ® Corps 5 73
Creek ? INT ® DWQ
S2 ®P ? T Stabilization Little Lick Creek ® PER
? INT ® Corps
® DWQ 10 10
S3 ®P ? T Stabilization and Little Lick Creek ® PER ® Corps 10 182
Relocation ? INT ® DWQ
S4 ®P ? T Stabilization Little Lick Creek ® PER
? INT ® Corps
® DWQ 10 68
S5 ? P ? T ? PER ? Corps
? INT ? DWQ
S6 ? P ? T ? PER ? Corps
? INT ? DWQ
3h. Total stream and tributary impacts 333
3i. Comments: At S1, 73 linear feet of rip-rap was placed on both streambanks of the unnamed tributary to Little Lick Creek.
Initially, we had also placed rip-rap in the base of this stream, but that rip-rap has been removed, leaving only the rip-rap on
the banks. At S2, 10 linear feet of rip-rap was placed on the western streambank of Little Lick Creek. At S3, 69 linear feet of
a braided stream channel was filled, due to the approaching threat of the stream bank erosion to the safety and reliability of
the natural as transmission pipeline. At the same location, 182 linear feet of stream channel was stabilized using rip-rap. At
Page 5 of 11
PCN Form - Version 1.3 December 10, 2008 Version
S4, PSNC removed and then replaced 57 linear feet of rip-rap on both stream banks. After pipeline construction was
completed, an additional 11 linear feet of rip-rap was placed on the streambanks, for a total of 68 linear feet of impacts. .
4. Open Water Impacts
If there are proposed impacts to lakes, ponds, estuaries, tributaries, sounds, the Atlantic Ocean, or any other open water of
the U.S. then individually list all open water impacts below.
4a.
Open water
impact number -
Permanent (P)
or Temporary
T 4b.
Name of waterbody
(if applicable) 4c.
Type of impact 4d.
Waterbody type 4e.
Area of impact (acres)
01 ?P?T
02 ?P?T
03 ?P?T
04 ?P?T
4L Total open water impacts
4g. Comments:
5. Pond or Lake Construction
If and or lake construction proposed, then complete the chart below.
5a.
Pond ID 5b.
Proposed use or purpose of 5c.
Wetland Impacts (acres) 5d.
Stream Impacts (feet) 5e.
Upland
(acres)
number pond
Flooded
Filled
Excavated
Flooded
Filled
Excavated
Flooded
P1
P2
517. Total
5g. Comments:
5h. Is a dam high hazard permit required?
? Yes ? No if yes, permit ID no:
5i. Expected pond surface area (acres):
5j. Size of pond watershed (acres):
5k. Method of construction:
Page 6 of 11
PCN Form - Version 1.3 December 10, 2008 Version
6. Buffer Impacts (for DWQ)
If project will impact a protected riparian buffer, then complete the chart below. If yes, then individually list all buffer impacts
below. If an impacts require mitigation, then you MUST fill out Section D of this form.
6a.
® Neuse ?Tar-Pamlico ? Other:
Project is in which protected basin? ? Catawba ? Randleman
6b. 6c. 6d. 6e. 6f. 6g.
Buffer impact
number - Reason Buffer Zone 1 impact Zone 2 impact
Permanent (P) for impact Stream name mitigation (square feet) (square feet)
or Temporary required?
T
Protection ? Yes
B1 ®P ? T of existing Little Lick Creek ® No 4140 2760
structure
B2 ?P?T ?Yes
? No
B3 ? P ? T ? Yes
? No
6h. Total buffer impacts 4140 2760
6i. Comments: Buffer zone impacts are calculated assuming an impact along 69 linear feet of stream, and then assuming that
50 feet of buffer was impactedon either side. Thus, Zone 1 was calculated as 69 feet x 30 feet x 2; Zone 2 was calculated as
69 feet x 20 feet x 2.
D. Impact Justification and Mitigation
1. Avoidance and Minimization
1 a. Specifically describe measures taken to avoid or minimize the proposed impacts in designing project.
PSNC attempted to find an alternate route for this pipeline, but was unsuccessful. Thus, the pipeline had to follow the route of
the existing pipeline, which required multiple crossings of the same stream, and included one non-perpendicular crossing.
Directional boring of the pipe under the streams was also considered but was not possible, because the existing pipe had to
be removed. Thus, open cutting of the creek was unavoidable. Also, one braided channel of Little Lick Creek threatened to
erode down to the gas pipeline, thus creating a safety hazard to the surrounding community. This erosion could only be
halted by filling of the braided channel.
1 b. Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques.
Appropriate erosion control measures were put in place prior to construction. Work was scheduled during an extremely low
stream flow, thus minimizing the impacts.
2. Compensatory Mitigation for Impacts to Waters of the U.S. or Waters of the State
2a. Does the project require Compensatory Mitigation for ? Yes ® No
impacts to Waters of the U.S. or Waters of the State?
2b. If yes, mitigation is required by (check all that apply): ? DWQ ? Corps
? Mitigation bank
2c. If yes, which mitigation option will be used for this project? ? Payment to in-lieu fee program
? Permittee Responsible Mitigation
3. Complete if Using a Mitigation Bank
3a. Name of Mitigation Bank:
3b. Credits Purchased (attach receipt and letter) Type Quantity
Page 7 of 11
PCN Form - Version 1.3 December 10, 2008 Version
3c. Comments:
4. Complete if Making a Payment to In-lieu Fee Program
4a. Approval letter from in-lieu fee program is attached. ? Yes
4b. Stream mitigation requested: linear feet
4c. If using stream mitigation, stream temperature: ? warm ? cool ?cold
4d. Buffer mitigation requested (DWQ only): square feet
4e. Riparian wetland mitigation requested: acres
4f. Non-riparian wetland mitigation requested: acres
4g. Coastal (tidal) wetland mitigation requested: acres
4h. Comments:
5. Complete if Using a Permittee Responsible Mitigation Plan
5a. If using a permittee responsible mitigation plan, provide a description of the proposed mitigation plan.
6. Buffer Mitigation (State Regulated Riparian Buffer Rules) - required by DWQ
6a. Will the project result in an impact within a protected riparian buffer that requires
buffer mitigation? ? Yes ? No
6b. If yes, then identify the square feet of impact to each zone of the riparian buffer that requires mitigation. Calculate the
amount of mitigation required.
Zone 6c.
Reason for impact 6d.
Total impact
(square feet)
Multiplier 6e.
Required mitigation
(square feet)
Zone 1 3 (2 for Catawba)
Zone 2 1.5
6f. Total buffer mitigation required:
6g. If buffer mitigation is required, discuss what type of mitigation is proposed (e.g., payment to private mitigation bank,
permittee responsible riparian buffer restoration, payment into an approved in-lieu fee fund).
6h. Comments:
Page 8 of 11
PCN Form - Version 1.3 December 10, 2008 Version
E. Stormwater Management and Diffuse Flow Plan (required by DWQ)
1. Diffuse Flow Plan
1 a. Does the project include or is it adjacent to protected riparian buffers identified ® Yes ? No
within one of the NC Riparian Buffer Protection Rules?
1 b. If yes, then is a diffuse flow plan included? If no, explain why.
Comments: This is an "as-built" application. Diffuse flow measures were included ? Yes ® No
during the original construction.
2. Stormwater Management Plan
2a. What is the overall percent imperviousness of this project? 0%
2b. Does this project require a Stormwater Management Plan? ? Yes ® No
2c. If this project DOES NOT require a Stormwater Management Plan, explain why: This is an "as-built" application. The
project did not increase stormwater flows over the baseline flow.
2d. If this project DOES require a Stormwater Management Plan, then provide a brief, narrative description of the plan:
? Certified Local Government
2e. Who will be responsible for the review of the Stormwater Management Plan? ® DWQ Stormwater Program
? DWQ 401 Unit
3. Certified Local Government Stormwater Review
3a. In which local government's jurisdiction is this project? City of Durham
? Phase II
3b. Which of the following locally-implemented stormwater management programs ? NSW
? USMP
apply (check all that apply): ? Water Supply Watershed
? Other:
3c. Has the approved Stormwater Management Plan with proof of approval been ? Yes ® No
attached?
4. DWQ Stormwater Program Review
? Coastal counties
? HQW
4a. Which of the following state-implemented stormwater management programs apply ? ORW
(check all that apply): ? Session Law 2006-246
? Other:
4b. Has the approved Stormwater Management Plan with proof of approval been
attached? ? Yes ® No
5. DWQ 401 Unit Stormwater Review
5a. Does the Stormwater Management Plan meet the appropriate requirements? ® Yes ? No
5b. Have all of the 401 Unit submittal requirements been met? ® Yes ? No
Page 9 of 11
PCN Form - Version 1.3 December 10, 2008 Version
F. Supplementary Information
1. Environmental Documentation (DWQ Requirement)
1a. Does the project involve an expenditure of public (federal/state/local) funds or the ? Yes ® No
use of public (federal/state) land?
1 b. If you answered "yes" to the above, does the project require preparation of an
environmental document pursuant to the requirements of the National or State ? Yes ? No
(North Carolina) Environmental Policy Act (NEPA/SEPA)?
1 c. If you answered "yes" to the above, has the document review been finalized by the
State Clearing House? (If so, attach a copy of the NEPA or SEPA final approval
letter.) ? Yes ? No
Comments:
2. Violations (DWQ Requirement)
2a. Is the site in violation of DWQ Wetland Rules (15A NCAC 2H .0500), Isolated
Wetland Rules (15A NCAC 2H .1300), DWQ Surface Water or Wetland Standards, ® Yes ? No
or Riparian Buffer Rules (15A NCAC 2B .0200)?
2b. Is this an after-the-fact permit application? ® Yes ? No
2c. If you answered "yes" to one or both of the above questions, provide an explanation of the violation(s): PSNC did obtain
NCDENR and US Army Corps of Engineers (Corps) permits and approvals for the project; however, PSNC did not obtain all
necessary regulatory notifications and approvals required by NCDENR's 401 Water Quality Certification, the Neuse River
Riparian Buffer Rules, and the Construction Stormwater General Permit. The violations are more fully described in a
NCDENR letter dated December 17, 2008. PSNC's responded in a letter dated February 2, 2009.
3. Cumulative Impacts (DWQ Requirement)
3a. Will this project (based on past and reasonably anticipated future impacts) result in ? Yes ® No
additional development, which could impact nearby downstream water quality?
3b. If you answered "yes" to the above, submit a qualitative or quantitative cumulative impact analysis in accordance with the
most recent DWQ policy. If you answered "no," provide a short narrative description.
The T-11 B project only replaced an existing natural gas pipeline. The area surrounding this pipe is already serviced with
natural gas, therefore, no additional development is expected because of this pipeline replacement.
4. Sewage Disposal (DWQ Requirement)
4a. Clearly detail the ultimate treatment methods and disposition (non-discharge or discharge) of wastewater generated from
the proposed project, or available capacity of the subject facility.
N/A
Page 10 of 11
PCN Form -Version 1.3 December 10, 2008 Version
5. Endangered Species and Designated Critical Habitat (Corps Requirement)
5a. Will this project occur in or near an area with federally protected species or ? Yes ® No
habitat?
5b. Have you checked with the USFWS concerning Endangered Species Act ? Yes ® No
impacts?
E] Raleigh
5c. If yes, indicate the USFWS Field Office you have contacted. ? Asheville
5d. What data sources did you use to determine whether your site would impact Endangered Species or Designated Critical
Habitat?
A list of state and federal rate species for Durham County was obtained from the North Carolina Natural Heritage
Program. There were three federally protected species found in Durham County. A field survey was conducted by Fish
and Wildlife Services (Whittier, NC). They found no suitable habitat for any of these species and saw no specimens
during a field survey.
6. Essential Fish Habitat (Corps Requirement)
6a. Will this project occur in or near an area designated as essential fish habitat? ? Yes ® No
6b. What data sources did you use to determine whether your site would impact Essential Fish Habitat?
Corps guidance documents for Essential Fish Habitat
7. Historic or Prehistoric Cultural Resources (Corps Requirement)
7a. Will this project occur in or near an area that the state, federal or tribal
governments have designated as having historic or cultural preservation ? Yes ® No
status (e.g., National Historic Trust designation or properties significant in
North Carolina history and archaeology)?
7b. What data sources did you use to determine whether your site would impact historic or archeological resources?
The project involved the replacement of an existing natural gas pipeline. The only area that was disturbed was within the
footprint of the previous pipeline installation. Therefore, no cultural resources were expected in the area.
8. Flood Zone Designation (Corps Requirement)
8a. Will this project occur in a FEMA-designated 100-year floodplain? ® Yes ? No
8b. If yes, explain how project meets FEMA requirements: Only temporary impacts will take place. No fill will be placed within
the FEMA floodplain
8c. What source(s) did you use to make the floodplain determination? FEMA Map
00,
X13 o?
Applicant/Agent's Printed Name App ica t/Ag nt's Signature Date
(Agent's signature is valid o y if an authorization letter from the applicant
is provided.)
Page 11 of 11
PCN Form -Version 1.3 December 10, 2008 Version
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