20181198 Ver 1_Cover Letter_20180827

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August 28, 2018
U.S. Army Corps of Engineers
Wilmington Regulatory Field Office
69 Darlington Avenue
Wilmington, North Carolina 28403
Attention: Emily Greer
NC Division of Water Resources
401 & Buffer Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Attention: Ms. Karen Higgins
Reference: Pre -Construction Notification: NWP No. 12/WQC No. 4133
PNG Casing 695 Replacement Project
Fayetteville, North Carolina
S&ME Project No. 7435-18-040
Dear Ms. Greer and Ms. Higgins:
On behalf of Piedmont Natural Gas (PNG), S&ME, Inc. (S&ME) hereby submits this Pre -construction
Notification (PCN) for temporary and permanent impacts to waters of the U.S. in accordance with
Nationwide Permit (NWP) No. 12. PNG, the project sponsor, will be considered the applicant. The project
entails replacement of a short segment of one of their existing natural gas pipeline in Cumberland County,
NC.
In support of this application, the following accompanying information has been submitted through the
N.C. Division of Water Resources (NCDWR) On-line PCN website (https://edocs.deq.nc.gov/Forms/Pre-
Construction Notification Form):
Figures: Site Vicinity Exhibit (Figure 1), USGS Topographic/NWI Exhibit (Figure 2), Soil Survey Exhibit
(Figure 3), 2017 Aerial Photograph (Figure 4) and Proposed Wetland Impact Exhibit (Figure 5)
Site Photographs
Request for Preliminary Jurisdictional Determination (Pre -JD)
• Agent Authorization Form
• Construction Exhibits
• Agency Scoping Information
NCDMS Request Letter
S&ME, INC. / 9751 Southern Pine Blvd / Charlotte, NC 28273 / p 704.523.4726 f 704.525.3953 / www.smeinc.com

Pre -Construction Notification S&ME Project No. 7435-18-040
PNG Casing 695 Replacement Project August 28, 2018
A copy of this PCN is being provided to NCDWR because a small segment of the combined permanent
and temporary easement will be greater than 50 feet in wetlands. Otherwise, the project should comply
with General Water Quality Certification No. 4133. The project will involve temporary wetland impacts
and conversion of forested wetlands, but will not result in permanent fill placement or the loss of waters
of the U.S.
General Project Information
PNG is planning to replace a "cased" portion of their existing natural gas transmission pipeline currently
located beneath a CSX railroad line south of Custer Avenue and north of Underwood Road in Fayetteville,
N.C. (35.093191°N, -78.834726°W). The project area currently consists of Piedmont's existing natural gas
utility line easement and wooded areas that abut the easement. An existing earthen access road leads
from Underwood road to an aboveground valve located on the south side of the railroad line. A pond is
located near the easement on the south side of the railroad, east of the access road. The vicinity consists
of open fields, woodland and residential areas. The PWC plant and a pond associated with that site are
located to the northeast.
The location of the site is depicted on the attached Site Vicinity Exhibit (Figure 1), the appropriate portion
of the Vander, NC USGS Topographic Map (Figure 2), a Soil Survey Exhibit (Figure 3), and a 2017 Aerial
Photograph (Figure 4).
PNG plans to conduct the work by installing a new segment of natural gas pipeline adjacent to the cased
segment. The new pipe will be installed beneath the railroad line and a wetland are by horizontal
directional drill (HDD). A new easement will be required on the north side of the railroad line, while the
existing easement will be utilized on the south side. Excavations will be required in order to
accommodate the HDD entry and exit points and connect the new pipe segment to the existing line. The
cased segment will then be grouted, capped and abandoned in place.
Existing Environment
The project area is located within the Coastal Plain Physiographic Province of North Carolina. Topography
in the area is generally flat. Review of the Vander, NC USGS Topographic Map indicates that blue -line
streams are depicted both north and south of the railroad line. However, other than a shallow drainage
ditch identified on the on the south side of the railroad line, no evidence of active stream channels was
observed. A pond associated with the PWC site is also depicted to the northeast. Soils mapped within
this assessment area are limited to Tarboro loamy sand (Typic Udipsamments), Roanoke silt loam (Typic
Endoaquults) and Altavista fine sandy loam (Aquic Hapludults). Roanoke soils are typically classified as
hydric.
Overstory vegetation within wooded portions of the project area included loblolly pine (Pinus taeda), red
maple (Acer rubrum), sweetgum (Liquidambar styraciflua), water oak (Quercus nigra), black cherry (Prunus
serotina) and tulip tree (Liriodendron tulipifera). The mid -story layer includes wax myrtle (Myrica cerifera),
American holly (Ilex opaca) and saplings of overstory species. Woody vines include poison ivy
(Toxicodendron radicans), yellowjasmine (Gelsemium sempervirens) and catbriar (Smilax rotundifolia).
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Pre -Construction Notification S&ME Project No. 7435-18-040
PNG Casing 695 Replacement Project August 28, 2018
Vegetation within the existing utility corridor included broomstraw (Andropogon virginicus), ragweed
(Ambrosia artemisiifolia), giant cane (Arundinaria gigantean), dog fennel (Eupotorium capillifolium), switch
grass (Panicum sp.), goldenrod (Solidago canadensis), blackberry, catbriar, and a variety of grasses.
During an initial site visit on March 27, 2018, S&ME personnel delineated jurisdictional surface waters
located within the project area. A follow-up site visit was also performed on July 17, 2018. We followed
the procedures set forth in the 1987 USACE Wetlands Delineation Manual and the corresponding
Regional Supplement. Conditions were documented using USACE Routine Wetland Determination Data
Forms, as appropriate.
Jurisdictional wetlands and located on each side of the railroad line. Wetland Area WA, which is located
south of the railroad line, is classified as a mixed hardwood -pine flat, and crosses the assessment area at
two separate locations. An earthen access road bisects the wetland through the maintained easement. A
portion of an open -water pond also extends slightly into the eastern boundary of the assessment area.
Wetland Area WB is located on the north side of the railroad line, and occupies nearly the entire
assessment area on this side. WB is classified as a bottomland hardwood swamp. Although stream
channels are depicted by the USGS topographic survey, there is no evidence of active channels, aside from
a ditch and culverted crossing south of the assessment area.
Information relative to the delineation (Request for Pre -JD) and photographs of conditions at the site are
included in the accompanying information submitted with the online PCN.
Description of Proposed Impacts
Performance of the work will result in both temporary and permanent impacts to wetlands. Permanent
impacts will result from wetland conversion of forested wetlands on the north side of the railroad tracks.
The remaining wetland impacts are temporary.
fable 1: Summary of Wetland Impacts
impact ii, Type i-orestecif Permanent Tempo
WA Temporary workspace Headwater Partial 0.024 0.178
Permanent conversion for new Bottomland
WB Partial 0.204 0.082
easement Hardwood
Total Wetland Impacts: 0.228 0.260
Total wetland impacts resulting from the project will be 0.448 acre. Of these impacts, 0.228 are
permanent and 0.260 acre will be temporary. The temporary impacts will result from excavation to
connect the new pipe segment to the unaffected portions of the pipe, placement of timber mats and
disturbance and from land disturbance necessary to stage equipment. The permanent impacts will result
from establishment of a ground -to -sky corridor over the new pipe. Within the new easement, the area
will be cleared but not grubbed, and stumps will be left in place. No permanent fill placement, stream
impacts or loss of waters of the US will occur as a result of the project.
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Pre -Construction Notification S&ME Project No. 7435-18-040
PNG Casing 695 Replacement Project August 28, 2018
Figure 5 depicts the proposed disturbance limits and impacts to the wetland, and Exhibits depicting
construction of the HDD are included in the accompanying information submitted with the online PCN.
Protected Species
To assist you in determining the project's compliance with applicable sections of the Endangered Species
Act (ESA) of 1973 (16 USC 1531-1543), S&ME conducted a search of the North Carolina Natural Heritage
Program (NCNHP) database to identify element occurrences (EOs) of such species listed as potentially
occurring near the project corridor. The NCNHP list was compared to the U.S. Fish and Wildlife Service
(USFWS) list of protected species for Cumberland County. Additionally, S&ME personnel conducted a
pedestrian field review of the site in conjunction with the delineation to locate potential habitat or the
presence of protected terrestrial species that were identified through the records review. The assessment
did not include sampling or a habitat assessment for aquatic or state -listed species.
The NCNHP provided a September 28, 2017 report that did not identify records of rare species, important
natural communities, natural areas, conservation areas or federally -protected species documented within
one mile of the site. The report did identify the project area as part of a collection of tracts managed as
open space by Cumberland County.
The NCNHP report is included in the accompanying information submitted with the online PCN.
Based on review of the NCNHP and U.S. Fish & Wildlife (FWS) databases, federally -protected species with
documented populations in Cumberland County are listed in Table 1. Descriptions of the relevant species
taken from FWS profiles are also listed below.
Table 2: Summary of Federally -Protected Species
Common Name OL
0 %rIcientific Name I
eral Status
County StatMOS9
American Alligator
Alligator mississippiensis
T(S/A)
Historical
Pondberry
Lindera melissifolia
E
Current
Red -cockaded Woodpecker
Picoides borealis
E
Current
Saint Francis' satyr butterfly
Neonympha mitchellii francisci
E
Current
Michaux's sumac
Rhus michauxii
E
Current
American chaffseed
Mycteria americana
T
Current
Rough -leafed Loosestrife
Lysimachia asperulaefolia
E
Current
American Alligator
Biological Determination: No Effect
The American alligator is listed as Threatened by the federal government because of its similarity in
appearance to the American crocodile (Crocodylus acutus), which is currently limited to between 500 and
1,200 individuals in the United States, limited in range to the southern tip of Florida. American crocodiles
are more common elsewhere in Mexico and South America.
Because the American alligator resembles the American crocodile, it is legally protected in the United
States. American alligators vary in length from up to 9 to 15 feet. The body of the alligator is armored
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Pre -Construction Notification S&ME Project No. 7435-18-040
PNG Casing 695 Replacement Project August 28, 2018
and is generally greenish-brown in color. Alligators have a muscular tail and a long snout with nostrils on
top for breathing while otherwise submerged. Juvenile alligators have yellow -striped tails.
Alligators breed in shallow waters, generally at night during the month of May, with egg -laying occurring
in June and July. Eggs are laid near the shore in nests of vegetation and generally hatch in late August.
Young are susceptible to predation by birds, raccoons, bobcats, otters, snakes, large bass, and larger
alligators. Habitat includes ponds, swamps, rivers, freshwater and brackish marshes, and canals.
Habitat for American was not observed within the project area. Accordingly, the project should not affect
American alligator.
Pondberry
Biological Determination: May Affect, Not Likely to Adversely Affect
Pondberry is an aromatic, deciduous shrub with erect stems and shoots, growing as high as 6.5 feet. It
spreads vegetatively by above ground shoots (stolons). Young stems and leaves are hairy. Leaves are
alternate, drooping, and oblong, with hairy edges, a pointed tip and rounded base, 2-4 inches long and
0.6-1.4 inches wide. Small, pale, clustered flowers appear before leaves from February to April. Pondberry
is characterized by the sassafras -like odor of its crushed leaves and tendency to form thickets of clonal,
unbranched stems.
Flowers appear from February through April before leaf and shoot growth begins in late April. Fruiting
occurs from August to September. The fruit matures in late autumn and is fleshy, oval, bright red, and
about 0.25-0.50 inch in diameter. Pondberry occurs in bottomland hardwood forests, poorly -drained
swampy depressions, and edges of limestone sinks and ponds closer to the coast. It can also be found at
the edges of swamps and ponds and depressions in forests of longleaf pine and pond pine. Pondberry is
typically found in somewhat shaded areas, but can also grow in full sun.
Although the project corridor contains potentially -suitable habitat for pondberry, no individuals of this
species were observed. Based on our pedestrian field review, it is not anticipated that this project will
adversely affect populations of pondberry.
Red -cockaded Woodpecker
Biological Determination: May Affect, Not Likely to Adversely Affect
Red -cockaded woodpecker measures approximately seven inches long and have black and white
horizontal stripes on its back. The cheeks and underparts are white and the sides are streaked in black.
The cap and stripe on the throat and neck of the bird are black. Male individuals of the species have a
small red spot on each side of the black cap and display a red crown patch after the first post -fledgling
molt. The woodpecker's diet consists primarily of insects.
Red -cockaded woodpecker's range is closely linked to the distribution of mature stands of southern pines.
Longleaf and loblolly pines that are 60 years old or greater are most commonly selected for nesting and
roosting trees. The woodpecker excavates nest and roost cavities in trees that are stressed, and often are
infected with red -heart rot fungus. Preferred nesting sites generally include relatively open, park -like,
mature pine stands with a suppressed mid -story layer. Suppression of the mid -story by fire or mechanical
means in mature pine stands promotes colonization by the red -cockaded woodpecker. Foraging habitat
is frequently limited to pine or pine -hardwood stands that are 30 years old or greater with a preference
for pine trees with a diameter of 10 inches or larger. Dense hardwood mid -story hampers foraging by
red -cockaded woodpecker and increases the occurrence of cavity competitors. The USFWS indicates that
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Pre -Construction Notification S&ME Project No. 7435-18-040
PNG Casing 695 Replacement Project August 28, 2018
the maximum foraging radius from a colony site for red -cockaded woodpecker is typically one-half mile
or less.
The project area was visually assessed for the presence of potential red -cockaded woodpecker foraging
and nesting habitat during the March 27, 2018 field review. The project area is located within and
adjacent to forested land that consists largely of hardwood and younger pine species. No large stands of
pine that were mature enough to contain suitable nesting habitat for the red -cockaded woodpecker were
observed. Given the lack of suitable habitat within the project area, it is not likely that the red -cockaded
woodpecker will be adversely affected as a result of this project.
Saint Francis' Satyr
Biological Determination: No Effect
Saint Francis' satyr is a small, dark brown butterfly. The wingspan for the species ranges from 34 to 44
millimeters. Saint Francis' satyr has conspicuous "eye spots" on the lower surfaces of the wings. These eye
spots have a dark maroon -brown center, and within the eye spots are lighter opalescent patches that
reflect a silver cast. The border of these dark eye spots is straw -yellow in color, with an outermost border
of dark brown. The eye spots are usually round to slightly oval and are well-developed on the fore wing as
well as on the hind wing. The spots are accented by two bright orange bands along the posterior wing
edges and two somewhat darker orange -brown bands across the central portion of each wing.
The habitat occupied by this satyr consists primarily of wide, wet meadows dominated by a high diversity
of sedges and other wetland graminoids. In the North Carolina sandhills, such meadows are often relicts
of beaver activity. Saint Francis' satyr has also been observed in pitcher plant (Sarracenia flava) swales,
with cane (Arundinaria tecta), and with rare plants rough -leaved loosestrife (Lysimachia asperulaefolia)
and pocosin lily (Lilium iridollai). Potential habitat for the satyr was not observed within the project area,
and no individuals of this species were observed. Based on our pedestrian field review, it is not
anticipated that this project will affect individuals or populations of Saint Francis' satyr.
Rough -leaved Loosestrife
Biological Determination: No Effect
Rough -leaved loosestrife is a perennial, colonial herb growing from a rhizome to heights of one to two
feet. Rough -leaved loosestrife flowers from May through June, with yellow flowers. The primary habitat
for rough -leaved loosestrife is the transition zone between longleaf pine stands and pond pine pocosins.
These areas are dominated by grass and shrubs. This species depends on frequent fire or other
disturbance (such as mowing) to decrease competition with more aggressive species. Preferred habitat
includes wet areas with peat or organic soils that are poorly drained. The species is crowded out by the
absence of fire or other disturbance.
Potential habitat for rough -leaved loosestrife was not observed within the project area, and no individuals
of this species were observed. Based on our pedestrian field review, it is not anticipated that this project
will affect individuals or populations of rough -leaved loosestrife.
Michaux's Sumac
Biological Determination: May Affect, Not Likely to Adversely Affect
Michaux's sumac is a non-poisonous, low -growing, deciduous, densely hairy shrub. The erect stems grow
from an underground rhizome to a height of one to three feet. The compound leaves are alternate and
divided into long rows of 9 to 13 stalkless leaflets. The leaflets are 1.6 to 3.5 inches long, oblong, winged
at the base, dull on the top, hairy on the bottoms, with toothed edges. The terminal leaflet has a two inch
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Pre -Construction Notification S&ME Project No. 7435-18-040
PNG Casing 695 Replacement Project August 28, 2018
long winged petiole. Flowers grow at the top of the plant in a dense, erect cluster, colored greenish -
yellow to white, and are four -to five -parted. Fruit are hairy reddish drupes, each containing one seed.
Leaves emerge in April to May, flowering occurs April to June, and fruiting occurs August to October with
fruits persisting for several months. These plants are generally dioecious. Michaux's sumac has been
known to produce male flowers one year and female flowers the next. Other individuals are monoecious
with both male and female flowers at one time. Usually less than half of the stems in a subpopulation do
not flower in a given season. Even though fruit may be plentiful, seed viability is low. This may be a result
of self -incompatibility or hybridization with other Rhus. This species usually produces asexually from
thick, shallow horizontal rhizomes.
Michaux sumac prefers sandy, loamy swales and depressions, acidic and circumneutral uplands, and rocky
open woods. It grows best where disturbance has maintained an open area. Michaux's sumac has been
found along roadsides, in powerline clearings, and areas where forest canopies have been opened up by
blowdowns and/or hurricane damage. Episodic fires accentuate habitat for this species and reduce
hardwood encroachment, recycle nutrients, and aid regeneration of longleaf pine/wiregrass communities.
Potential habitat for Michaux's sumac exists in the utility easement. However, field review did not identify
populations of Michaux's sumac. Accordingly, it is not anticipated that this project will adversely affect
populations of this species.
American Chaffseed
Biological Determination: May Affect, Not Likely to Adversely Affect
American chaffseed is an erect, densely hairy, unbranched perennial, one -to -two feet tall. Leaves are
alternate, 0.8-1.6 inches tall and 0.2-0.4 inch wide, and attach directly to the stalk without a leaf stem.
Each leaf has three noticeable veins. Its flowers are grouped in a long terminal cluster. Numerous seeds
are enclosed in a loose -fitting, sac-like structure that provides the basis for the common name, chaffseed.
Showy, insect -pollinated flowers occur in May -June, with fruits maturing in August. The fruit is a brown,
dry dehiscent capsule, narrowly oval-shaped, about 0.4 inches long. The seeds are numerous, flat, and
winged. Fire appears to be a requirement for long-term viability, strongly affecting the reproductive
success by controlling conditions necessary for successful seed germination. American chaffseed prefers
sandy, acidic, seasonally moist soils in sunny or partly sunny areas subject to frequent fires in the growing
season.
Only marginally -suitable habitat for American chaffseed exists within the project area, and the pedestrian
field review did not identify individuals of this species. Based on these results and the limited and largely
temporary nature of the proposed work, it is not anticipated that this project will adversely affect
populations of American chaffseed.
We anticipate that the USACE will complete the necessary coordination with the FWS prior to issuance of
the permit.
Historic Resources
To assist in your determination of compliance with Section 106 of the National Historic Preservation Act
(NHPA) of 1966, S&ME conducted a review of the NC State Historic Preservation Office (SHPO) GIS
database. Review of the database did not identify any sites that are listed or eligible for listing on the
National Register of Historic Places within a one -mile radius of the project site. We also provided SHPO
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Pre -Construction Notification S&ME Project No. 7435-18-040
PNG Casing 695 Replacement Project August 28, 2018
with project information on March 5, 2018 and requested that they review and comment on the proposed
project. SHPO responded with a March 28, 2018 letter stating that they had conducted a review of the
project and aware of no historic resources which would be affected by the project. A copy of the SHPO
letter is included in the accompanying information submitted with the online PCN.
We anticipate that the USACE will complete the necessary coordination with the SHPO prior to issuance of
the permit.
Avoidance And Minimization
The project area has been limited to the minimum amount considered necessary to safely accommodate
the new pipe and support equipment that will be required during construction. Impacts have been
minimized by PNG's use of appropriate erosion and sediment control measures during construction,
including timber/equipment mats, utilizing high -visibility fencing to demarcate wetland areas that are to
remain undisturbed, and by conducting a pre -construction meeting to review applicable permit
conditions prior to construction.
Temporarily affected areas will be restored in accordance with the restoration plan included in the
accompanying information submitted with the online PCN. Following construction, disturbed wetlands
within the easement will be restored to their original grade and contour and seeded with a native wetland
seed mix. The work will not result a loss of waters of the U.S. There should be no loss of waters, as only
temporary ground disturbance from equipment access and logging operations will be required
Mitigation
To account for the proposed permanent conversion wetland impacts, PNG proposes to purchase the
appropriate amount of wetland credit from the NC Division of Mitigation Services (NCDMS) at a 1:1 ratio
in the corresponding HUC (Cape Fear 03030004). Based on review of the NCDMS list of approved
mitigation banks, the only private bank authorized to operate in this HUC (Barra Farms II) has no available
credit.
A request letter to NCDMS is included in the accompanying information submitted with the online PCN.
A 1:1 ratio is proposed because the permanent impacts will result only from conversion, and there will be
no loss of waters of the U.S.
Closing
Thank you for your review of this PCN. If you have questions or need additional information, please feel
free to contact us at 704.523.4726.
Sincerely,
5&ME
Joey Lawler, P.W.S.
Project Manager
Senior Review by Jason S. Reeves, P.E.
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