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August 9, 2013
N.C. Division of Water Resources
Washington Regional Office
943 Washington Square Mall
Washington, North Carolina 27889
Attention: Mr. Roberto Scheller
Senior Environmental Specialist
Reference: PNG Line 513 Right -of -Way Reclamation
Multiple Eastern North Carolina Counties
S &ME Project No. 1357 -13 -007
Dear Mr. Scheller:
RECEIVED
AUG 12 2013
DWQ-WARO
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On behalf of Piedmont Natural Gas (PNG), S &ME, Inc. (S &ME) hereby submits this
notification for mowing and aboveground vegetation removal activities within their
existing Line 5B natural gas pipeline right -of -way (ROW).
The subject ROW originates at a tie -in with PNG's existing Line 5A natural gas pipeline
near the Cape Fear River in Fayetteville, Sampson County, and extends generally
northeast to an existing PNG station near Snow Hill in Greene County. As such,
approximately 24 miles of the subject ROW is located within the Cape Fear River Basin,
where riparian buffer rules are not in effect. The portion of the line that is located in the
Neuse River basin, where most streams are subject to riparian buffer rules, begins
approximately 1.2 miles south of Highway 55 near Newton Grove in Sampson County,
and extends to the ROW's terminus north of Griffin Road and West of Highway 58 near
Snow Hill, Greene County, North Carolina. The portion of Line 5B that is located within
the Neuse River basin is the primary subject of this information submittal.
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For your reference, the entire Line 5B ROW location is depicted on the attached Vicinity
Map (Figure 1). Portions of Line 5B ROW that are located within the Neuse River Basin
are further depicted on the appropriate USGS Topographic Maps (Figures 2A -21). Note
that soil survey streams that intersect the existing ROW have been digitized and are also
depicted on the topographic maps.
This letter and accompanying figures are being provided to the North Carolina Division
of Water Resources (NCDWR) pursuant to your July 23, 2013 telephone conversation
with our Joey Lawler. Accordingly, we understand that the snowing and aboveground
vegetation removal activities proposed by PNG should be exempt from Neuse River
Basin riparian buffer regulations provided that the work is limited to their existing 50-
foot wide ROW. The Line 5B ROW was originally acquired and the gasline constructed
S &ME, INC. / 9751 Southern Pine Boulevard / Charlotte, INC 28273 -5560 / p 704.523.4726 / 704.525.3953 / w .smeinc.com
PNG Line 5B ROW Reclamation S &ME Project No. 1357 -13 -007
Multiple Eastern North Carolina Counties August 9. 2013
in 1959, prior to the date the buffer rules went into effect. The Line 5B reclamation work
will not entail acquisition or clearing of any new or additional ROW, nor will it constitute
a change in the ongoing use or purpose of the existing ROW.
GENERAL PROJECT INFORMATION AND BACKGROUND
The portion of the ROW subject to this information submittal is located in the Inner
Coastal Plain physiographic province, in the Neuse River Basin (03020201). General
land use in the vicinity of the project corridor consists of a mix of low density residential
areas, pasture, forest, and clear -cut areas. Portions of the project corridor are located
close to areas composed of commercial and light industrial development.
To adequately perform their routine maintenance and pipeline inspection operations,
PNG is performing reclamation activities within their existing Line 5B ROW. The
reclamation work entails mowing and above - ground removal of woody vegetation within
their existing utility line ROW. Some areas only require side - trimming or bush - hogging,
while others will require hand - clearing where vegetation may have grown up at the
periphery of the ROW.
Portions of Line 5B abut a separate PNG natural gasline project that is currently under
construction. The line under construction is identified as the Line 5B Looping Project,
and wa's authorized under DWQ Express Project No. 13 -0101. Areas where the two
ROWS abut are being used as temporary work space for construction of the Line 5B
Looping project, and as such, these abutting areas are excluded from the reclamation
work associated with the remainder of Line 5B. Accordingly, portions of Line 5B that
abut the Looping Project are not depicted on aforementioned topographic maps.
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PNG considers establishment and regular maintenance of the existing ROW system an
important part of their responsibility to provide safe and reliable energy to the
communities they serve. To that end, maintaining at least 50 feet of easement in most
areas is required to support:
• Leakage surveys from ground mobile units or aerial technology.
• Aerial patrolling for possible encroachment activity near the pipeline.
• Aid in identification of possible repairs and maintenance.
• Promotion of damage prevention in that the easement can be more easily identified by
the public.
• Minimization of potential canopy encroachment, which creates visibility concerns.
• Minimum turn - around requirements for mechanized mowing and side - trimming
equipment.
PNG Line 513 ROW Reclamation S &ME Project No. 1357 -13 -007
Multiple Eastern North Carolina Counties August 9, 2013
PNG has agreed to reduce the width of the permanently- maintained ROW from 50 feet to
30 feet through buffered areas, wetlands and stream crossings. This will minimize the
maintained disturbance footprint in the future, and still allow PNG to maintain a
minimum ROW width deemed necessary to support the needs identified above.
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To identify jurisdictional areas within the ROW, S &ME conducted field reviews of the
project corridor over a period ranging from May to June 2013. Features that appeared on
the most recent version of the appropriate Natural Resources Conservation Service Soil
Survey or 1:24,000 scale (7.5 minute) quadrangle topographic maps were identified with
global positioning system (GPS) equipment. Where the specific origination point of a
regulated stream was in question, or the two resources identified above appeared
inaccurate, S &ME performed an on -site determination utilizing the standardized
methodology developed by NCDWR (formerly the NC Division of Water Quality). This
assessment involved use of the NCDWQ Stream Assessment Form (Version is 4.1 1,
effective September 1, 2010). S &ME has also delineated and demarcated all wetland
areas within the existing Line 94 ROW.
S &ME followed the procedures set forth in the 1987 U.S. Army Corps of Engineers
( USAAE) Wetlands Delineation Manual and the Atlantic and Gulf Coastal Plain Region
Supplemental Guidance. Limits of wetland areas within the existing ROW were
demarcated with flagging and identified with GPS equipment. Results of the field
assessment were provided to Regional Land Surveyors (RLS) for inclusion on PNG's
existing mapping and for dissemination to the reclamation contractors. Based on
guidance provided by the USACE, removal of aboveground vegetation associated with
the reclamation work does not require a permit, so long as discharges to wetlands or
stream do not occur.
Stream crossings have been avoided, and the proposed activities will be conducted so as
not to create a discharge (no pipes or fill material placed at stream crossings), although
timber construction mats have been used at wetland crossings to provide access for
equipment and prevent rutting and undue soil disturbance. Otherwise, mowing
equipment is able to work around existing streams by finding alternative access routes.
PNG contractors have been provided with maps identifying the streams and wetland
areas, along with Environmental Guidelines detailing methods by which vegetation
removal and maintenance activities should be conducted. The delineation will serve to:
• Establish boundaries within which all vegetation must be removed by hand above
ground level — no grubbing, stumping or other land disturbance is allowed without
prior authorization from the USACE and NCDWR.
• Demarcate areas within which timber mats or similar measures must be employed to
accommodate heavy equipment and prevent extensive rutting and soil disturbance.
PNG Line 5B ROW Reclamation S&ME Project No. 1357 -13 -007
Multiple Eastern North Carolina Counties August 9. 2013
• Establish boundaries within which application of rye grain or a native wetland seed
mix is required. PNG understands that application of fescue within wetland areas is
prohibited.
• Demarcate areas where streams should be bridged or crossed in such a manner that
prevents bank impacts.
CLOSING
Thank you for your guidance in regard to this project. If you have questions or need
additional information, please feel free to contact us at 704.523.4726.
Sincerely,
S &ME
Do" A P'e'�
Joey Lawler, Darrin M. Peine, QEP
Senior Project Manager Natural Resources Department Manager
Senior Review by Julie Bennett - Hudel, P.G., LEED AP
Attachments - Figures
CC. NCDWR Central Office
Andy Clark, PLS — RLS
Jim Kalish — PNG