20201403 Ver 1_PNG Line 473_SHPO Correspondence_20201113

BURNS 1 MCDONNELL
May 20, 2020
Renee Gledhill -Earley
State Historic Preservation Office
109 East Jones Street, Room 258
Raleigh, NC 27601
Re: Piedmont Natural Gas Line 473 Clayton City Gate 92 Project Review
Dear Ms. Gledhill -Earley:
Piedmont Natural Gas is proposing to install approximately 1.4 miles of new 8-inch diameter gas
pipeline for the Line 473 Clayton City Gate 92 Project in Johnston County, North Carolina
(Project) (Figures 1 and 2). The pipeline will be installed below the ground surface. In addition,
two new aboveground regulator stations are proposed. The purpose of the Project will be to
continue to provide reliable service to its existing and future customers in the greater Clayton
Area.
Piedmont Natural Gas has asked Burns & McDonnell Consultants, Inc. (Burns & McDonnell) to
assist with environmental review for the Project. Burns & McDonnell anticipates the proposed
project will impact wetlands and as a result, a U.S. Army Corps of Engineers (USACE)
Nationwide Permit 12 is anticipated. Since the jurisdiction of wetlands have yet to be finalized,
Piedmont Natural Gas has not submitted its permit application with the USACE regarding this
Project. This project review letter compiles known cultural resources in the Project vicinity.
CULTURAL RECORDS REVIEW
Burns & McDonnell conducted an archaeological resources records search at the North Carolina
Office of State Archaeology (OSA) on February 6, 2020. Burns & McDonnell used the North
Carolina Historic Preservation Office (NCHPO) HPOWEB GIS service database to conduct
historic -age non -archaeological resources (historic resources) research on February 25, 2020.
The proposed Project consists of an approximately 75-foot wide construction corridor centered
on the proposed pipeline centerline along with temporary construction and laydown areas. For
the records review, Burns & McDonnell looked at a Study Area extending 1 mile beyond the
Project (Figure 1).
No previously recorded historic resources were identified in the Project (Figures 1 and 2). The
northern end of the Study Area extends into the Clayton Historic District which has been
determined eligible for the National Register of Historic Places (NRHP). However, at this
preliminary stage, it does not appear that the Project will impact contributing district resources.
There are three additional historic resources that have been surveyed in the Study Area (Table 1).
One historic resource has been determined eligible for the NRHP, the Battle -Horne -Benson
House (Resource JT0672). This resource is over 1,400 feet from the proposed Project and even
the temporary visual effects of pipeline construction would be blocked by dense woods. The
other two resources outside the Clayton Historic District are JT0790 and JT1857. Resource
9400 Ward Parkway \ Kansas City, MO 64114
0 816-333-9400 \ F 816-333-3690 \ burnsmcd.com

BURNS 1 MCDONNELL
Renee Gledhill -Earley
State Historic Preservation Office
May 20, 2020
Page 2
JT0790 was recorded as a house and put on the Study List, but has since been demolished or
removed. Resource JT1857 is a tobacco barn that was surveyed but not evaluated for listing on
the NRHP.
Table 1: Historic -Age Non -Archaeological Resources Within the Study Area
Resource #
Resource Name
NRHP Eligibility Status
Notes
JT0672
Battle -Horne -Benson House
Eligible
JT0790
House
Study List
Gone
JT1356
Clayton Historic District
NRHP Listed
JT1857
Tobacco Barn
Survey Only —Not Evaluated
Source: HPOWEB 2020.
Fourteen archaeological sites have been recorded within the Study Area (Table 2; Figures 1 and
2). One site, 31JT342, is within the Project. The site is a twentieth century domestic artifact
scatter that is not eligible for the NRHP. Site 31JT95, a Woodland lithic scatter, is adjacent to the
site and is unassessed for its NRHP eligibility. All of the sites within the Study Area are listed in
Table 2 below as an indication of the types of archaeological resources found in the area.
Table 2: Archaeological Sites Within the Study Area
Site #
Prehistoric/Historic
Site Type
Recommendation
31JT91
Early Archaic and
Woodland
Lithic scatter
Unassessed for NRHP
31JT92
Middle Archaic and
Woodland
Artifact scatter
Unassessed for NRHP
31JT95
Woodland
Lithic scatter
Unassessed for NRHP
31JT97
Unknown prehistoric
Artifact scatter
Unassessed for NRHP
31JT233
Early and Middle
Archaic/19th century
Artifact scatter
Not eligible for NRHP
after evaluation
31JT239
Unknown prehistoric
Lithic workshop
Not eligible for NRHP
after evaluation

BURNS 1 MCDONNELL
Renee Gledhill -Earley
State Historic Preservation Office
May 20, 2020
Page 3
Site #
Prehistoric/Historic
Site Type
Recommendation
31JT240
Unknown
Lithic scatter/domestic artifact
Not eligible for NRHP
prehistoric/ 19th and
scatter
after evaluation
20th centuries
31JT241
Woodland/historic
Artifact scatter/domestic
Not eligible for NRHP
artifact scatter
after evaluation
31JT252
19th and 20th
Cemetery
Not eligible for NRHP
centuries
after evaluation
31JT342
20th century
Domestic artifact scatter
Not eligible for NRHP
after evaluation
31JT555
Unknown
Lithic scatter/domestic artifact
Unassessed; no further
prehistoric/20th
scatter; former home sites
work recommended
century
associated with Clayton
Cotton Mills
31JT556
20th century
Domestic and industrial
Unassessed; no further
artifact scatter; former cotton
work recommended
warehouses associated with
Cl a ton Cotton Mills
31JT557
20th century
Domestic artifact scatter;
Unassessed; no further
former home site associated
work recommended
with Cl a ton Cotton Mills
31JT558
Woodland/20th
Prehistoric isolate/ industrial
Unassessed; no further
century
artifact scatter associated with
work recommended
John A. Vinson Planing Mill
and Lumber Yards
Source: OSA files 2020.
North Carolina is the setting of numerous Revolutionary War, War of 1812, and Civil War sites
(American Battlefield Protection Program [ABPP] 2007, 2010; Howard 2010). The closest
documented war -related event in the area was the Civil War Battle of Bentonville in Johnston
County about 14 miles southeast of the Project. Revolutionary War campaigns and battles were
east and west of the Project, but nothing has been documented in the Project area.
Several buildings near the Project are depicted on historic -era maps and more recent Google
Earth aerial imagery. Sometime between 1993 and 1999, the alignment of North Carolina

BURNS 1 MCDONNELL
Renee Gledhill -Earley
State Historic Preservation Office
May 20, 2020
Page 4
Highway 42 moved from the west to its current location, which parallels the northern part of the
Project. Two buildings depicted on the historic period maps appear to have been demolished as
part of the road construction project. The one closest to the pipeline Project is depicted outside
the Project and under the current alignment of Highway 42. The south end of the Project passes
by other historic -age buildings depicted on 1911 and 1964 maps (North Carolina Department of
Agriculture 1911; USGS 1964). However, because the Project is not planning to demolish any
historic -age buildings and will be underground it is not likely to affect these resources. The
Project parallels and crosses an active railroad built in 1856 but plans to construct under the
railroad (Mississippi Rails 2017).
The map and imagery review showed changes in the Project area that may affect the likelihood
of intact archaeological sites crossed by the Project. The northern part of the Project that parallels
North Carolina Highway 42 and U.S. Route 70 has experienced disturbances from road
construction and alignment changes along both roads and mass tree clearing, possibly timber
harvesting. The part of the Project south of U.S. Route 70 parallels Wildwood Drive and is
predominantly in agricultural fields.
Your review of and comments on this records review for Piedmont Natural Gas's Line 473
Clayton City Gate 92 Project is appreciated. A USACE Nationwide Permit 12 is anticipated for
the Project, and the USACE has previously requested that Piedmont Natural Gas should follow
your recommendations regarding any additional cultural resources surveys.
Sincerely,
Amber Javers
Senior Cultural Resources Specialist
Attachment: Map Figures
cc: Alicia DePalma, Piedmont Natural Gas
Anthony McMullan, Burns & McDonnell
Sara Kent, Burns & McDonnell

BURNS 1 MCDONNELL
Renee Gledhill -Earley
State Historic Preservation Office
May 20, 2020
Page 5
REFERENCES CITED
American Battlefield Protection Program (ABPP)
2007 Report to Congress on the Historic Preservation of Revolutionary War and War
of 1812 Sites in the United States. National Park Service, U.S. Department of the
Interior, Washington, D.C.
2010 Update to the Civil War Site Advisory Commission Report on the Nation's Civil
War Battlefields, State of North Carolina. National Park Service, U.S.
Department of the Interior, Washington, D.C.
Howard, Josh
2010 North Carolina in the U.S. Revolution. Research Branch, NC Office of Archives
and History. Electronic document,
https://www.ncpedia.org/history/usrevolution/overview, accessed July 23, 2019.
Mississippi Rails
2017 North Carolina with Logging Trails. Google Earth file. Electronic document,
http://www.msrailroads.com/Google_earth.htm, accessed July 23, 2019.
North Carolina Department of Agriculture
1911 Soil Map, North Carolina, Johnston County Sheet. United States Bureau of Soils,
North Carolina Department of Agriculture, Washington, D.C.
U.S. Geological Survey (USGS)
1964 Clayton, North Carolina. 1:24,000 topographic quadrangle map. Washington,
D.0

ATTACHMENT I - MAP FIGURES

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COPYRIGHT© 2020 BURNS & McDONNELL CONSULTANTS, INC.
Service Layer Credits: Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NRCan, Esri Japan, METI, Esri China (Hong Kong), Esri Korea, Esri (Thailand), NGCC, (c) OpenStreetMap contributors, and the GIS User Community
Copyright:© 2013 National Geographic Society, i-cubed
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•••• Study Area Surveyed Only, Gone Figure 1
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- Archaeological Site Study List 0 0.5 1 ` Cultural Resources in Study Area
NORTH ` BURNS Line 473
Archaeological Survey Study List, NRHP Eligible M112S \=DONNEl.L Clayton City Gate #2 Project
National Register District • Surveyed Only, in NRHP
Johnston County NC
Surveyed Only
Source: North Carolina Office of State Archaeology, North Carolina Historic Preservation Office Issued: 2/28/2020

Path: \\bmcd\Dfs\Clients\TND\DukeEnrgyCar\118874_ClaytonCtyGate\Studies\Geospatial\Data Files\ArcDocs\ClaytonGate_Cultural_aerial.mxd
COPYRIGHT © 2020 BURNS & McDONNELL CONSULTANTS, INC.
Service Layer Credits: Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NRCan, Esri Japan, METI, Esri China (Hong Kong), Esri
Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community
bhbattle 212712020
Korea, Esri (Thailand), NGCC, (c) OpenStreetMap contributors, and the GIS User Community
Source: North Carolina Office of State Archaeology, North Carolina Historic Preservation Office, Issued: 2/27/2020

STAB a
+ Quµ
North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary Susi H. Hamilton
July 15, 2020
Amber Javers
Burns & McDonnell Consultants, Inc.
9400 Ward Parkway
Kansas City, MO 64114
ai avers&burnsmcd.com
Office of Archives and History
Deputy Secretary Kevin Cherry
Re: Piedmont Natural Gas Line 473 Clayton City Gate #2, Clayton, Johnston County, ER 20-1207
Dear Ms. Javers:
Thank you for your May 20, 2020, submission concerning the above -referenced project. We have reviewed
the materials provided and offer the following comments.
We have determined that the project as proposed will not have an effect on any historic buildings or
structures.
The portions of the project area that parallel NC 42 and US 70 have been previously surveyed for the
purpose of identifying cultural resources. Two previously recorded archaeological sites (31JT95 and 31JT342)
are in the project area. Site 31JT342 is not eligible for listing in the National Register of Historic Places, and
additional archaeological work at this site is not warranted. Site 31JT95 has not been assessed to determine
whether it is eligible for listing in the National Register. Based on the artifacts recovered from site 31JT95, it
contains an American Indian Woodland Period component.
We recommend that prior to any ground disturbing activities within the project area, a comprehensive
archaeological survey be conducted by an experienced archaeologist of the project area south of US 70. The
purpose of this survey will be to identify and evaluate the significance of archaeological sites that may be
damaged or destroyed by the proposed project.
Please note that our office now requests consultation with the Office of State Archaeology Review
Archaeologist to discuss appropriate field methodologies prior to the archaeological field investigation. A list
of archaeological consultants who have conducted or expressed an interest in contract work in North
Carolina is available at https://archaeology.ncdcr.gov/archaeological-consultant-list. The archaeologists
listed, or any other experienced archaeologist, may be contacted to conduct the recommended survey.
One paper and one digital copy of all resulting archaeological reports, as well as one digital copy of the North
Carolina site form for each site recorded, should be forwarded to the Office of State Archaeology through
this office for review and comment as soon as they are available and in advance of any construction or
ground disturbance activities. Office of State Archaeology report guidelines are available at
ht�s://files.nc.Vov/dncr-arch/OSA Guidelines Dec201712//files.nc.Vov/dncr-arch/OSA Guidelines Dec2017�df.
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-1617 Telephone/Fax: [phone]-6599

The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR
Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579 or
environmental.review&ncdcr.gov. In all future communication concerning this project, please cite the above
referenced tracking number.
Sincerely,
� LL�.
L./Ramona Bartos, Deputy
State Historic Preservation Officer
cc: Chris Hopper, US Army Corps of Engineers christopher.d.hol2l2er e usace.army.mil