20202009 Ver 1_Cover Letter_20210111

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January 8, 2021
Raleigh Regulatory Field Office
US Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Randolph Forest, NC 27587
Attention: Mr. James Lastinger
N.C. Division of Water Resources
401 & Buffer Permitting Branch
512 North Salisbury Street
Raleigh, North Carolina 27604
Attention: Mr. Paul Wojoski
Reference: Pre -construction Notification
Nationwide Permit No. 12/WQC No. 4133
Line 333 Retrofit
Randolph County, North Carolina
S&ME Project 7335-20-115
Dear Mr. Lastinger and Mr. Wcjoksi:
On behalf of our client, Piedmont Natural Gas (PNG), S&ME, Inc. (S&ME) hereby submits this notification
to inform you of work they plan to conduct in accordance with Nationwide Permit (NWP) 12 and the
corresponding North Carolina Water Quality Certification (WQC) No. 4133. The proposed project will
involve temporary stream/wetland impacts associated with work at several locations along PNG's Line 333
natural gas transmission pipeline in Randolph County, North Carolina.
The application and accompanying support information is being submitted through the NCDWR E-PCN
website (htti2s://edocs.deq.nc.gov/Forms/Pre-Construction Notification FormU. The supporting
information submitted online consists of the following:
Figures: Site Vicinity Exhibit (Figure 1), USGS Topographic Exhibits (Figures 2A-2D), Soil Survey
Exhibits (Figures 3A-3D) and Jurisdictional Impact Exhibits (Figures 4A-4D)
Authorization to Act as Agent
Site Photographs (Sites 4, 5b, 7, 8, and 9)
Typical Construction and Erosion & Sediment Control (E&SC) Details
NCNHP and IPaC Reports
S&ME, Inc. 12016 Ayrsley Town Blvd, Suite 2AI Charlotte, NC 28273 1 p 704.523.4726 1 f 704.525.3953 1 www.smeinc.com

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Nationwide Permit No. 12/WQC No. 4133
Line 333 Retrofit
Randolph County, North Carolina
S&ME Project 7335-20-115
Written concurrence from the USACE is required because: 1) the project will require mechanized land
clearing of forested wetlands at one location for construction of a temporary access road, and 2) the work
will take place within an existing, maintained utility easement, which is identified as suitable habitat for
Schweinitz's sunflower (He(ianthus schweinitzii). The project will otherwise comply with all applicable
conditions of the general permit.
Written concurrence from the North Carolina Division of Water Resources (NCDWR) is not required,
because the project does not meet any of the notification thresholds identified in WQC 4133, and will
comply will all applicable conditions. Similarly, NCDWR approval for Lake Randleman Reservoir riparian
buffer impacts is not required per 15A NCAC 02B .0724 because the sole temporary access road that is
required will impact less than 2,500 square feet (sf) of riparian buffer, and the area will be restored upon
completion of the project. Accordingly, this PCN is being submitted to NCDWR as a courtesy.
General Project Information
PNG is planning to conduct retrofit work along portions of their Line 333 natural gas transmission
pipeline. Line 333 originates near the southeast quadrant of Mount Hopewell Church Road and Interstate
1-85 in Trinity, Randolph County, North Carolina, then extends generally northeast for approximately 12
miles, terminating at an existing PNG station east of Interstate 1-85 in Greensboro, Forsyth County North
Carolina. The pipeline was originally constructed in 1984-1985.
The work will occur at approximately 12 locations along the existing pipeline, and in most cases will be
conducted within the existing 50-foot wide easement. Temporary construction easements (TCE) will be
required at certain sites in order to provide equipment access. The proposed work will entail a variety of
activities, such as excavation and inspection of the pipeline, replacement of fittings, and similar pipeline
upgrades. Of the 12 sites, the work will result in temporary stream/wetland impacts at five of the sites, as
identified below:
Site 4
This site is located west of Weant Road in High Point, Randolph County, North Carolina (35.914944°N,
-79.935159°W). Overall, the site is approximately 0.47 acre. The proposed work area is an
approximately 0.14-acre portion of PNG's existing easement. The site also includes a proposed 25-
foot wide temporary road (0.33 acre) which will provide access to easement from Weant Road. The
access road will utilize an existing driveway associated with a neighboring church, then pass through a
wooded area to the existing easement, which is located in an agricultural field. The proposed work
consists of replacement of a fitting.
Site 5b
This site is located east of and adjacent to Comanche Drive and approximately 330 feet west of US
Highway 311 (South Main Street) in Archdale, Randolph County, North Carolina (35.895908°N, -
79.945403°W). The site totals approximately 0.98 acre, which includes a portion of PNG's existing
easement, and a proposed 20-foot wide access road which will provide access to easement from
Comanche Drive. The access road will utilize an existing driveway and grassed area associated with a
neighboring commercial facility. The proposed work consists of installation of a transition fitting.

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Nationwide Permit No. 12/WQC No. 4133
Line 333 Retrofit
Randolph County, North Carolina
S&ME Project 7335-20-115
Site 7
This site is located west of Fairview Church Road in Trinity, Randolph County, North Carolina
(35.880653°N-79.966793°W). The site consists of an approximately 0.57-acre portion of the existing
Line 333 easement. Equipment accessing the work area from Fairview Church Road will utilize the
easement, which abuts the road. The proposed work consists of replacement of a fitting.
Site 8
This site is also located west of Fairview Church Road in Trinity, Randolph County, North Carolina
(35.878772°N-79.967500°W). The site is comprised of a 0.35-acre area that includes both a portion of
the Line 333 easement and a temporary access road. Equipment accessing the work area from
Fairview Church Road will utilize an existing gravel drive and open area. The proposed work consists
of replacement of a fitting.
Site 9
This site is also located east of Elmwood Road in Trinity, Randolph County, North Carolina
(35.877643°N-79.985794°W). The site is comprised of a 0.87-acre portion of the Line 333 easement.
Equipment accessing the work area from Elmwood Road will utilize an existing easement, which abuts
the road. The proposed work consists of replacement of a fitting.
The general project location of the sites is depicted on the Site Vicinity Exhibit (Figure 1). The project
vicinity ranges from largely undeveloped agricultural and forested land, and mixtures of residential and
light industrial development. At those sites where temporary construction easement (TCE) is required for
access, PNG has negotiated private easements. The location of the sites is depicted in greater detail on
the appropriate U.S. Geological Survey (USGS) Topographic Map Exhibits (Figures 2A-213) and Survey
Exhibits (Figure 3A-313).
Description of the Proposed Work
The proposed work will involve excavation and exposing the existing pipeline in areas where replacement
of existing fittings or similar upgrades are necessary. The work is needed in order to make the pipeline
compatible with an in -line inspection device (aka — "smart pig").
The work will first involve demarcation of disturbance limits, which in most instances will not exceed a 50'
x 50' area within the existing easement. If jurisdictional boundaries are present, these areas will be
demarcated as well. Appropriate erosion and sedimentation control (E&SC) measures will be installed in
advance of excavation to prevent sedimentation of adjacent jurisdictional features. Equipment crossing
over herbaceous wetlands that may be located within the existing easement will do so on mats to avoid
impacts. A track hoe will then excavate a pit and expose the pipe. Spoil material will be temporarily
stockpiled within the easement adjacent to the pit and contained within silt fence. In wetland areas,
topsoil will be segregated from the subsoil.
At one location (Site 4), temporary equipment access from Weant Road will be required. Construction of
the temporary road will result in clearing a minor amount of forested wetlands. Access from this location
is required in order to avoid additional disturbance by utilizing the existing easement, where disturbance
to agricultural fields, along with multiple crossings of more significant wetlands and a stream would be
required.

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Nationwide Permit No. 12/WQC No. 4133
Line 333 Retrofit
Randolph County, North Carolina
S&ME Project 7335-20-115
Following completion of the work to the pipeline, the spoil material will be replaced in the pit, and the
topsoil will be replaced last. The affected areas will be restored to their pre -construction grades and
contours, and permanent seed and will be mulch applied. All work within wetland areas will be conducted
in accordance with the applicable permit conditions.
Jurisdictional Areas
The entirety of the Line 333 easement was delineated by S&ME in 2013 in connection with maintenance
of the easement. The subject retrofit sites were re -delineated by S&ME on December 29, 2020. S&ME
followed the procedures set forth in the 1987 USACE Wetlands Delineation Manual and the appropriate
Regional Supplemental Guidance. Field conditions were documented using USACE Routine Wetland
Determination Data Forms, as appropriate. The field review also included identification of tributaries
(streams or jurisdictional ditches) within each site.
Drainage features identified during the field review were assessed to determine the jurisdictional status of
the tributary. Drainage features were classified as either non -jurisdictional or jurisdictional. S&ME used the
NCDWR Stream Classification Form to document characteristics of identified drainage features on the day
of the assessment. During the site visit, the boundaries of regulated surface waters were demarcated
using sequentially -numbered flagging. The location of the jurisdictional features is depicted on Figures
4A-413. Representative Wetland/Upland Data Forms and typical photographs of some of the subject
features were included with the information submitted online.
Project -wide wetland impacts are summarized in Table 1
Table 1: Summary of Project -wide Wetland Impacts
ESitelD
Wetland ID
Temporary Wetland
Impacts (Ac)
1 11
Wetland Impacts
*Forested Wetland
Conversion (Ac)
1 11
Permanent Fill
Placement (Ac)
1 11
11 1
111
111
�
11�1
111
111
�
1 11
1 11
1 11
11 1
111
111
•
1
1 11
1 11
All of the proposed impacts are temporarily in nature, and no forested wetland will be converted to
herbaceous wetlands. Streams will not be impacted by the excavation activities. If access across a stream
within the easement or temporary access road is required, it will be accomplished by construction of a
timber mat bridge to avoid impacts.
Drawings depicting the location of each site (Figures 4A-4D, and typical construction/E&SC details are
included with the information submitted online with the PCN. Following construction, the temporarily
affected jurisdictional areas will be returned to their pre -construction grade and contour, seeded, and
stabilized.
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Nationwide Permit No. 12/WQC No. 4133
Line 333 Retrofit
! Randolph County, North Carolina
qE S&ME Project 7335-20-115
To determine if the affected stream at Site 4 is subject to riparian buffer rules, S&ME conducted field
reviews of the project corridor as part of the delineation efforts. In the Randleman basin, those features
that score greater than 19.0 points on the NCDWR Stream Assessment Form (Version is 4.11, effective
September 1, 2010) are considered subject to the buffer rules. It should be noted that subject features are
also located at other sites, but access to the work areas at these locations will be conducted within the
existing maintained easement, where no vegetated buffer is present, an existing use is present and
ongoing, and will remain unchanged. Project -wide buffer impacts are summarized in Table 2.
Table 2: Summary of Project -wide Riparian Buffer Impacts
Zone 1 (sf) Zone 2 (sf)
780 492
The project will only affect an existing buffer at one location (Stream 1). Crossings of the remaining on -
site streams with buffers will be conducted in the existing, maintained easement, with no vegetation
removal required.
As indicated previously, the temporary access road crossing of the Stream 1 buffer is deemed allowable
by the buffer rules because less than 2,500 sf of buffer will be impacted, and the area will be restored to
pre -construction topographic and hydrologic conditions and replanted with comparable vegetation within
two months of when construction is complete.
Protected Species
To assist you with 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 sites, and also conducted informal coordination with the US Fish
and Wildlife Service (USFWS) through their online project planning tool. The list fo federally -listed species
for Randolph County is provided below:
Table 2. Summary of FWS/NCNHP Database Search for Randolph County
Cape Fear Shiner
Notropis mekistocho(as
E
Current
Atlantic pigtoe
Fusconaia mosoni
ARS
Current
Brook floater
Alasmidonta varicosa
ARS
Current
Savannah lilliput
Toxo(asma pu((us
ARS
Current
Georgia aster
Symphyotrichum georgionum
C
Current
Schweinitz's sunflower
He(ionthus schweinitzii
E
Current
ARS = At -risk Species ; C = Candidate ; E = Endangered

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Nationwide Permit No. 12/WQC No. 4133
Line 333 Retrofit
Randolph County, North Carolina
S&ME Project 7335-20-115
Additionally, S&ME personnel conducted a pedestrian field review of the sites 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 reports for each site on December 4, 2020. The reports did not identify records of
federally -protected species, state listed species, or managed areas documented within one mile of any of
the sites.
A summary of the listed species is provided below:
Cape Fear Shiner
Status: Federally -Listed Endangered
Biological Determination: No Effect
This is a small yellowish minnow with yellow pointed fins and a black band along the sides of its body. The
upper lip is black and bears a thin black bar along the margin of the upper lip.
The Cape Fear Shiner is endemic to the upper Cape Fear River Basin in the central Piedmont of North
Carolina. They are generally associated with gravel, cobble, and boulder substrates and have been
observed in slow pools, riffles, and slow runs. During the spawning season (May through July), the adults
move to slower moving pools to lay eggs on the rocky substrate. Juveniles are most often found in slack
water, among large rock outcrops in the midstream, and in flooded side channels and pools.
The project will result in impacts to only one stream — S01. This stream does not exhibit habitat suitable
for Cape Fear shiner. Therefore, the project should have no effect on this species.it is not anticipated that
this project will affect populations of this species.
Atlantic Pigtoe
Status: Federally At Risk Species
Biological Determination: No Effect
The Atlantic pigtoe is a freshwater mussel which rarely exceeds two inches in length. The shell is rhombus
shaped similar to that of a horse or pig's hoof. The outer shell is yellow to dark brown in color and
parchment like with a distinct posterior edge. The inner shell is iridescent blue to salmon, white, or
orange. Young individuals may have greenish rays across the shell surface. The Atlantic pigtoe has
interlocking hinge teeth in the inside of the shell to keep the valves in proper alignment. This species
prefers coarse sand and gravel and is rarely found in silt or detritus substrates. Historically this species was
most often found in small creeks to larger rivers with excellent water quality where the stream flow is
sufficient to maintain clean, silt -free substrates. Threats to this species include non -point and point
sources of pollution, sedimentation, and the construction of dams.
The on -site streams do not exhibit habitat suitable for Atlantic piogtoe and will be avoided by the use of
an equipment bridge. Therefore, the project should have no effect on this species.

Nationwide Permit No. 12/WQC No. 4133
Line 333 Retrofit
I I Randolph County, North Carolina
1 S&ME Project 7335-20-115
Brook Floater
Status: Federally At Risk Species
Biological Determination: No Effect
The brook floater is a freshwater mussel that can reach a length up to 2.8 inches. This mussel has an
oblong, long, rhomboid shell. The outer surface is generally smooth except for the posterior slopes.
Juveniles have yellowish to greenish or covered in dark green rays, transitioning to a brownish color with
rays partially obscured or very dark in adults. The inner shell is white or blueish white with salmon, pink, or
purple in the beak cavity. This species prefers high relief streams with boulders in sand. They are
commonly found in run -riffle complexes with a swift current and clean gravel, sand, and cobble
substrates. Threats to this species include habitat degradation in the firm of silt, nutrient and sewage
loads, and pollution. Over collection and competition from invasive species such as zebra mussels have
also been identified as threats.
The on -site streams do not exhibit habitat suitable for brook floater and will be avoided by the use of an
equipment bridge. Therefore, the project should have no effect on this species.
Savannah Lilliput
Status: Federally At Risk Species
Biological Determination: No Effect
The Savannah Lilliput is a small mussel with an oval or elliptical shell with a double posterior ridge. Large
specimens range from 1.2 to 1.4 inches long. Females of the species have a broader and more truncated
posterior end while males have a narrower and rounder posterior end. The outer shell is blackish,
brownish, greenish, or olive with very fine green rays. The inner surface of the shell is bluish -white with
pink or purple tints at the posterior end. This species prefers shallow water, usually at the edges of
streams, rivers, or lakes and can also be found in backwaters. The mussel is rarely found in deep water and
is often found suspended in mud or silty sand. Threats to the species include off -road motor vehicle
traffic, droughts, and drawdowns due to their preference for shallow water. Distribution appears to be
limited by dams.
Impacts to on -site streams will be avoided. Therefore, the project should have no effect on this species.
Georgia Aster
Status: Federal Candidate Species
Biological Determination: May Affect Not Likely to Aversely Affect
The Georgia aster is a perennial reaching a height of one to three feet. The plant has large flowerheads
approximately two inches wide with dark purple rays encircle white to lavender disk flowers. These flowers
bloom from early October to mid -November. This species prefers woodlands or piedmont prairies
dominated by native plants with acidic soils from sand to heavy clay. A primary controlling factor for the
species appears to be the availability of light, competing well for resources until shaded out by woody
plants. Habitat loss due to development and a lack of the disturbance events necessary to provide the
necessary sunlight appear to be the main threats to the Georgia aster.
The affected areas exhibit only marginally habitat suitable for Georgia aster. Therefore, the project should
not adversely affect this species.

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Nationwide Permit No. 12/WQC No. 4133
Line 333 Retrofit
Schweinitz's Sunflower
Randolph County, North Carolina
S&ME Project 7335-20-115
Status: Federally Listed Endangered
Biological Conclusion: May Affect Not Likely to Adversely Affect
Schweinitz's sunflower is a perennial herb in the aster family that generally grows up to 1.5 meters (five
feet) in height. This plant has tuberous roots, with each stem attached to a single tuberous root. The
stems are scabrous (rough) and generally reddish in color. The leaves are soft pubescent below and
scabrous on the upper surface. The ray flowers are yellow, while the disk flowers are purplish.
Schweinitz's sunflower generally blooms during the month of September. The habitat of Schweinitz's
sunflower is open woods, roadsides, and powerline easements, often on basic soils with bare spots or a
gravel component. The preferred sites are characterized by abundant sunlight and little competition in the
herbaceous layer. Schweinitz's sunflower is listed as a current record for Randolph County.
Because a majority of the project sites consist of maintained utility easement, potential habitat for
Schweinitz's sunflower is present. No apparent individuals of the sunflower (Helianthus) genus were
observed. Further, the survey was conducted in December, outside of the appropriate flowering window,
and the easement was recently mowed, most likely in the fall.
However, given the limited nature of the proposed work and the fact that no occurrences of this species
have been documented in the vicinity of the project sites, we have determined that this project is not
likely to adversely affect populations of Schweinitz's sunflower.
Copies of the NCNHP and IPaC reports were included with the information submitted online with the E-
PCN.
Historic and Archaeological Resources
To assist in your determination of the project's compliance with Section 106 of the National Historic
Preservation Act (NHPA) of 1966, S&ME reviewed the NC State Historic Preservation Office (SHPO) GIS
web mapping service, which indicates that no structures eligible for inclusion on the National Register of
Historic Places are located near any of the sites. Accordingly, the project should have no effect on historic
resources.
Avoidance and Minimization
The proposed project will avoid impacts to wetlands and streams where practicable, and a majority of the
work will take place within the existing utility easement.
Project BMPs used in connection with the conventional stream crossing include the following:
The work will be executed in as minimal amount of time necessary.
Sufficient equipment to execute the work in an expeditious, environmentally responsible manner will
be available on site prior to initiation of construction.
Local weather conditions will be monitored such that, to the extent possible, stormwater events will
be avoided during and immediately following the excavations.

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Nationwide Permit No. 12/WQC No. 4133
Line 333 Retrofit
Randolph County, North Carolina
S&ME Project 7335-20-115
The work will be monitored during installation by personnel experienced in such procedures, familiar
with site conditions, and knowledgeable of North Carolina environmental regulations. The monitor
shall have the authority to stop work should conditions change and additional or different measures
be needed.
The top 6-12 inches of wetland topsoil will be stockpiled separately from the subgrade material and
kept saturated during the installation.
All disturbed areas within wetlands will be seeded with a customized seed mix that will extend 10-feet
landward of the jurisdictional boundary.
Construction equipment operating near wetland areas will be limited to that necessary for excavation,
retrofit work and restoration activities.
Appropriate E&SC practices outlined in the most recent version of the "North Carolina Sediment and
Erosion Control Planning and Design Manual" and approved by the local governing authority shall be in
compliance with specifications governing the proper design, installation, operation, and maintenance of
such BMPs to comply with the appropriate turbidity water quality standard.
The project will comply with applicable conditions of NWP No. 12 and WQC No. 4133. Following the work,
the affected areas will be restored to their original grade and contour. As proposed, the project will not
result in permanent changes to the ground surface elevation(s). Temporarily affected areas are proposed
to be restored in accordance with the attached E&SC Details (submitted online with the E-PCN) following
completion of the work.
Mitigation
The project will not result in loss of wetlands or waters of the US. In addition, the project will not
permanently convert forested wetlands to herbaceous wetlands, and all affected areas will be restored to
original grade and contour. Therefore, purchase of wetland mitigation credit is not required. Stream
impacts will be avoided entirely. The project will cross one area buffer subject to Randleman Lake riparian
buffer rules. However, the activity is deemed allowable and does not require mitigation.
Closing
Thank you for your review of this courtesy PCN. If you have questions or need additional information,
please feel free to contact us at 704.523.4726.
Sincerely,
S&ME
y
Joey Lawler, PWS
Natural Resources Project Manager
[e-mail]
Senior Review by Jason Reeves, PE