20120072 Ver 6_Modifications_20130226

February 18, 2013
U.S. Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, North Carolina 28801 -5006
Attention: Mr. Steve Kichefski
N.C. Division of Water Quality
401 Wetlands Unit
512 North Salisbury Street
Raleigh, North Carolina 27604
Attention: Ms. Karen Higgins
Reference: Second Request for Revision of Crossing Method
PNG Line # 170 Project
Cabarrus, Iredell and Mecklenburg Counties, North
S &ME Project No. 1357 -10 -022
Action ID No. 2012 -00298
DWQ Project No. 12 -0072
Dear Mr. Kichefski and Ms. Higgins:
T i �
FEB 2 6 2013
S &ME, Inc. (S &ME) wishes to submit a request to revise a proposed crossing method
associated of one jurisdictional stream at the Piedmont Natural Gas (PNG) Line # 170
Project. The overall project entails construction of approximately 8.8 miles of natural gas
transmission pipeline in Cabarrus, Iredell and Mecklenburg Counties, North Carolina.
The location of the overall project corridor is depicted on the Site Vicinity Map (Figure
1), and the location of the stream subject to the proposed change is shown on a USGS
topographic map (Figure 2) and a 2010 Aerial Photograph (Figure 3).
This stream subject to this proposed revision is identified as Stream 7.1, and is located off
of Rocky River Road in Mecklenburg County, North Carolina. Photographs of the
subject stream are included as an attachment to this letter. The 30 -inch pipe was
originally proposed for installation beneath the stream by horizontal directional drill
(HDD). The proposed drill originated at Station 289 +42 and extended east to Station
303 +75. The contractor began drilling operations on November 6, 2012, and since that
time, numerous problems related to the presence of sub - surface rock were encountered.
The problems have become so acute that the contractor is close to submitting this
attempted drill as a failure. Accordingly, we are appealing for a variance to abandon the
S &ME, INC / 9751 Southern Pine Boulevard / Charlotte, NC 28273 -5560 / p 704.523.4726 IF 704.525.3953 / www.srnemc corn

_y
Second Request for Revision of Crossing Method S &ME Project No. 1357 -10-022
PNG Line # 170 Project February 18 2013
HDD efforts and install the pipe by conventional isolation (dam and pump - around)
methods.
Conventional installation of the pipe is a more viable option at this point due to a number
of factors. The present pilot hole has been drilled to a depth necessary to accommodate
the appropriate radius of curvature for 30 -inch pipe. The depth is also sufficient to
minimize the risk of an inadvertent release of drilling fluid to the environment, or a "frac-
out." However, this depth also exposes the drill to extremely dense formations of rock.
Attempting to drill a new hole at a more shallow depth would significantly increase the
risk of a frac out within the stream. Review of available subsurface geotechnical
information indicates that the overlying material would require use of drilling mud at a
pound -force per square inch (psi) that is not suitable for the less stable sub - surface. As
such, the risk of the drilling mud finding voids and capillaries to funnel to the surface
would increase substantially.
The contractor has indicated that the work can performed with less risk to the stream
channel by first isolated the proposed work area with coffer dams and a clean-water
bypass, and installing the pipe conventionally "in the dry." In order to minimize
impacts to the channel itself, the contractor can conduct the pre -work necessary to install
the pipe in advance of the actual stream crossing. Once the area is suitably prepped, the
actual excavation and installation of the pipe should not require more than 48 hours to
complete. Stabilization and restoration of the streambanks can commence immediately
following installation of the pipe. The restoration will be conducted in accordance with
the project's existing restoration plan, using natural channel materials rather than rip -rap
or hard- armoring.
The contractor will be able to perform the work within the currently authorized 70 -feet of
workspace, and as such, no additional impacts will be incurred as a result of this chance
in crossing method. The revised drawing that depicts the change in crossing method and
location is attached for your consideration.
Thank you for your time and consideration of this request. Again, please note that
because the change in the method of construction does not involve additional stream
impacts beyond those currently permitted for this crossing, this letter is being submitted
at your request for record - keeping purposes. If you have questions, please feel free to
contact us at 704.523.4726.
Sincerely,
S &ME
3e�y L r, S.
Project anager
[e-mail]
ar
ONUM—ce, E. P. �)
Natural Resources Department Manager
[e-mail]
Senior Reviewed by Julie Bennett- Hudel, P.G., LEED AP
2

.�
Second Request for Revision of Crossing Method SBME Project No. 1357 -10-022
PNG Line # 170 Proiect February 18 2013
Attachments:
• Figure 1: Site Vicinity Map
• Figure 2: USGS Aerial Photograph
• Figure 3: 2010 Aerial Photograph
• Revised Jurisdictional Waters of the U.S. Impact Plan (Sheet 21 of 24)
Cc:
• Michael Burkhard, NCDENR Mooresville Regional Office
• Adam Long, PNG
3

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21
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60
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County "
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Davidson
21
Stream
Crossing Location E�
David
7
Cab rrus
M cklenburg County
C o u n Caldwell
73
21
--------- cl-
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REFERENCE:
THE BACKGROUND GEOGRAPHIC INFORMATION SYSTEMS (GIS) LAYERS WERE OBTAINED FROM THE
STREETMAP USA DATASET. THE PROPOSED PIPELINE ROUTE WAS DERIVED FROM DATA PROVIDED BY
MCKIM AND CREED, INC. PLEASE NOTE THIS MAP IS FOR INFORMATIONAL PURPOSES ONLY. IT IS NOT Cree
MEANT FOR DESIGN, LEGAL, OR ANY OTHER USES. THERE ARE NO GUARANTEES ABOUT ITS ACCURACY.
S&ME, INC. ASSUMES NO RESPONSIBILITY FOR ANY DECISION MADE OR ANY ACTIONS TAKEN BY THE USER Pipeline Route
BASED UPON THIS INFORMATION.
SCALE: AS SHOWN SITE VICINITY MAP FIGURE
NO.
DATE: 02.14.13 Request for Revison to Crossing Method
DRAWN BY COL s &ME PNG - Line # 170
�HECKED BY: WWW.SMEINC.COM Multiple Counties, North Carolina
L JH PROJECT NO:
B 1357-10-022

- - TEMPORARY WORK SPACE
< _ _
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TEMPORARY IMPACT LIMIT
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PERMANENT CONVERSION UMIT/EASEMENT
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- TEMPORARY IMPACT UMIT
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NON - WOODED
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- _ �'CPSWIt.7A
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CROSSING MAT a
170 -ME -34.1
STREAM FLAG TABLE
FLAG
I LENGTH
I BEARING
NORTHING
EASTING
CPSWII.01A
131.26'
j4109'53'E
N 531359.41
E 1470289.02
PSW11.02
4.44'
1 S3012'22
N 531249.55
E 1{70342.76
PSW11.03
51.41'
1'
N 63119196
E 1470375.18
PSW11.04
00,8er
S25108'3eE
N 631146.03
E 1470393.77
PSWI 1.05
BD.44'
11'
N 631084.19
E 1470424.12
PSWI1.06
7'
•
N 631032.48
E 1470455.42
PSVALO
- TEMPORARY WORK SPACE
1 '4
N 630995.40
E 1470470.07
PSWIl.OaA
47. Y
1'
N 630963.61
E 1470476.92
SW71.09 A
166.17'
S25'46'01"E
N 630925.88
E 1470505.89
W11.10
N 630776.24
E 1470578.13
SW11.03
N30'30'08'W
N 630361.72
E 1470890.18
SWI1.02
54_W.
N28, 7'
N 630406460
E 1470863.72
SW11.01
7 .7T
N37 ,29'40'W
N 630482.66
E 1470832.70
CPSWI1.01
MV
N31 3'40'W
N 630525.18
E 1470784.75
SW1 1 .0281
96.6a'
N36',13'16*W
N 630593.99
E 1470742.76
PSW11.
11 .e '
N ,4 '
N 63067261
E 1470688.77
PSWII.
1
't "W
N 630785.86
E 1470626.96
PSWII.
.31'
N 41 ' 1'W
N 63088280
E 1470571.05
PS11'11.
N21-0,V57-W
N 630925.63
E 1470541.60
SW11.0
14.17'
4131 49'W
N 63095163
E 1470530.89
PSW114
1
4' 4' 'W
N 630985.87
E 1470523.41
PSW11.09
N T
N 630963.37
E 1470515.19
CPSWII.I OB
,67'
N 5' '49'W
N 631008.87
E 1470501.82
CPSW11.118
I I
N1 '08'47 -W
N 6310 32.92
E 1470490.29
CPSW11.128
4177
N 815 YW
N 63105299
E 1470484.85
CPSWI1.130
49.35'
N 4' 4'W
N 631089.78
E 1470465.08
CPSWI7.146
N 631133435
E 1470441.84
-, LINE
04 NOS
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NON- WOODED 170 -CA -37
hAS
GAS
�- GAS
GAS
cPSxnl.ae` - --
0_
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PE ENNIAL RPW
374 LF MPORARY IMPACT
0 LF P RMANENT IMPACT
(STREAM BED AMPACTS IN LINEAR FEET)
NOTES:
- ALL DISTANCES SHOWN ARE HORIZONTAL GROUND DISTANCES AND ARE IN FEET UNLESS OTHERWISE NOTED.
- THIS MAP DOES NOT CONFORM TO GS 47 -30, AS AMENDED. NOT INTENDED FOR RECORDATION.
- WETLANDS SURVEYED BY TRIMBLE "PATHFINDER" METHODS.
- THE SOLE PURPOSE OF THIS PLAT IS TO SHOW JURISDICTIONAL BOUNDARIES AS DELINEATED BY S &ME, INC
- BASIS OF BEARING IS NORTH CAROLINA STATE PLANE COORDINATE SYSTEM (NAD 03 /NSRS2007).
GRAPHIC SCALE
0 50 100 200
1 1 1 1
( IN FEET )
1 inch - 100 EL
VICINITY MAP
170 -CA -38
OAS
GAS
JOB NUMBER: 03139 -0113
JURISC CTKX4L WATERS OF THE U.S.
V' * ,y'TM 4
DWG, NUMBER:
FACT PLAN
&/�'p�M
V1V�'"1 \11V1 �..,L�GLIJ
21
SHEET NUMBER: 21 OF 24
OF
8020 TOWER POINT DRIVE
PROJ. SURVEYOR: JLS
PIEDMONT NATURAL GAS UNE
CHARLOTTE. NORTH CAROLINA 28227
TELE: (704) 541 -2586
DRAWN BY: AC
IREDELL, MECKLENBURG AND
FAX: [phone]
F -1222
COMPUTER FILE: 01/04 12
DATE: 01 04
CABARRUS COUNTIES, NORTH CAROLINA
GRAPHIC SCALE
0 50 100 200
1 1 1 1
( IN FEET )
1 inch - 100 EL
VICINITY MAP
170 -CA -38
OAS
GAS
H
LEGEND
_
TE 0FORARY CHANNEL IMPACT
OTEMPORARY
IMPACT AREA
CJ
PERMANENT CONVERSION AREA
WETLAND AREA
$1.001
STREAM DEUNEATION FLAG
CPS1.OD1
COMPUTED POINT
W1.001
WETLAND DEUNEATION FLAG
WETLAND /STREAM BOUNDARY
EXISTING WOODS LINE
- GAS GAS
- PROPOSED GAS LINE
- OAS -OAS -CAS-
EXISTING GAS LINE
- -
PROPOSED EASEMENT
- -
EXISTING EASEMENT
- - - - - - - -
- IMPACT LIMIT
- ---
PROPERTY UNE
- -
- TEMPORARY WORK SPACE
H