20120586 Ver 1_More Info Received_20120730

July 27 2012
North Carolina Division of Water Quality
Winston Salem Regional Office
585 Waughtown Street
Winston Salem North Carolina 27107 2241
Attention Ms Sue Homewood
North Carolina Division of Water Quality
Wetlands /401 Certification Unit
1650 Mail Service Center
Raleigh North Carolina
Attention Mr Ian McMillan
a- D5 810
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Reference Application for Nationwide Permit No 12 and Water Quality
Certification No 3884
Piedmont Natural Gas Proposed Carlson Dairy Road Maintenance Project
Greensboro North Carolina
S &ME Project No 1357 12 002 Phase 01
DWQ No 12 0586
Dear Ms Homewood and Mr McMillan
S &ME Inc (S &ME) on behalf of Piedmont Natural Gas (PNG) is providing a letter of
response to address additional information requested from the North Carolina Division of
Water Quality ( NCDWQ) in order to continue review and authorization of the proposed
Carlson Dairy Road Maintenance Project application (dated June 12 2012) for
Nationwide Permit No 12 and Water Quality Certification No 3884 The NCDWQ
request was provided in a letter dated July 16 2012 addressed to Mr Neil Moser of PNG
The request included the following
1 Provide further documentation that supports PNG s request to permanently fill
0 10 acres of wetlands for the purpose of regular inspection and maintenance by
equipment rather than by hand methods or by other measures that would result in
no impacts and/or temporary impacts such as timber mats etc and
2 Clarify if there are streams or wetland areas proposed to be temporarily impacted
SWE INC / 9751 Southern Pine Boulevard / Charlotte NC 28273 5560 / p 704 523 4726 f 704 525 3953 / www smeinc corn

Application for NWP 12 and WQC 3884 S &ME Project Number 1357 12 002 Phase 01
Proposed Carlson Dairy Road Maintenance Project July 27 2012
As indicated in the original application dated June 12 2012 the purpose of the proposed
project is twofold The first and foremost purpose involves public safety associated with
the amount of soil cover over the existing Class 3 natural gas transmission pipeline
PNG is required by Department of Transportation regulations' to maintain a minimum
depth of cover of thirty six inches over the Carlson Dairy Road natural gas transmission
line The existing soil cover depth varies between twenty six and thirty inches due to
maintenance of the right of way (ROW) after the wetland was created by the
impoundment of adjacent Lake Higgins Also should an emergency situation with the
adjacent natural gas regulator station or the pipeline itself require immediate access to the
ROW through the existing wetland area PNG would not have enough time to place mats
within the wetland area
In addition to complying with minimum federal natural gas pipeline safety standards and
facilitating safe access to the existing natural gas line ROW adjacent to Carlson Dairy
Road the proposed activities are necessary in order to address requests from adjacent
landowners who have expressed concern regarding frequent ponding within the ROW
The ponding is exacerbated by PNG maintenance equipment that routinely becomes
bogged down within the area when attempting to gain access to high ground portions of
the ROW As a result the area has become rutted and continues to pose a problem for
both PNG maintenance personnel and concerned landowners alike
The North Carolina Department of Transportation has identified a failed storm drain
culvert that outfalls into the wetland area In order to facilitate coordination of repairs to
the existing 36 inch collapsed storm drain culvert the North Carolina Department of
Transportation will schedule their repairs concurrent with the proposed wetland fill
placement PNG is planning to compensate for the permanent loss of the 0 10 acre of
wetland through purchase of mitigation bank credit within the project watershed from
Restoration Systems
The June 12 2012 application contained a Restoration Plan which is generally included
with NWP 12 applications as a majority of such projects typically involve only
temporary impacts However as no temporary impacts will occur as a result of the
proposed activities the Restoration Plan is not applicable to this project and will not
require implementation
S &ME on behalf of PNG requests that you consider the above additional information in
order to continue review and authorization of the proposed Carlson Dairy Road
Maintenance Project Should you have questions regarding this information please do
not hesitate to contact us at 704 523 4726
Thank you for your assistance with this project
' Code of Federal Regulation Title 49 Transportation Part 192 — Transportation of Natural and Other Gas
by Pipeline Minimum Federal Safety Standards Y 192 ,27 Coyer
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Application for NWP 12 and WQC 3884 S &ME Protect Number 1357 12 002 Phase 01
Proposed Carlson Dairy Road Maintenance Project July 27 2012
Sincerely
S &ME
D,,O Z�,—
Darrin M Peine QEP
dpemeAsmeinc com
Natural Resources Department Manager
Dane Horna P E VP
DHornan,smeinc com
Senior Reviewer
oey Lawler P W S
awler smeinc com
Natural Resources Senor Project Manager
CC Andy Clark P L S Regional Land Surveyors
Neil Moser P E PNG
Thomas Brown USACE Raleigh Office
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