20072087 Ver 1_Certified Return Receipt_20081022

W A T ?9QG
____-I
Michael F Easley, Governor
William G Ross Jr, Secretary
North Carolina Department of Environment and Natural Resources
Coleen H Sullins, Director
Division of Water Quality
October 22, 2008
CERTIFIED MAIL
Return Receipt Requested
7001 2510 0000 6682 7027
Mr Mike Stanley, Operations Supervisor
Piedmont Natural Gas
2611 Greengate Drive
Greensboro, North Carolina 27406
Subject: Gas line relocation adjacent to Bridge No 140, SR 2215
Gabnel's Creek, Randolph County
Dear Mr Stanley
On Wednesday, October 15, 2008, the Division of Water Quality (DWQ) was notified that a contractor for Piedmont
Natural Gas was relocating a utility line at the subject location According to the notification, thus work involved the
excavation of a trench through the bed of Gabriel's Creek The report also indicated that the contractor was pumping
turbid water from within the work area and discharging it directly to the stream rather than into a settling basin or silt bag
In response to this notice, Ken Averrtte of the Fayetteville Regional Office of DWQ visited the site on Friday, October 17,
2008 He met on-site with numerous N C Department of Transportation officials as well as Mr Jerry Nealy, fob
superintendent for Distribution Construction Company (DCC) of Greensboro, the contractor for this gas line relocation
The in-stream component of the utility relocation was essentially complete at the time of the visit According to Mr
Nealy, the water being pumped from the work area on October 15 was settled water contained within the excavation that
was removed prior to commencement of the day's work within the put This water was the accumulation of leakage
through the diversion dam that had been installed upstream of the work area This "pump around" arrangement is typical
when doing such work in order to achieve compliance with U S Army Corps of Engineers permits and corresponding
DWQ 401 Water Quality Certifications On the prompting of DOT inspectors at the scene, DCC reportedly implemented
measures to seal the leaks through the dam and pump all of the streamflow around the work area During his visit, Mr
Aventte observed no evidence of significant water quality issues or stream standard violations The diversion dam was
still in place and the pumps in operation on an as needed basis There was no evidence of stream flow into the work area
and only a very low flow observed downstream of the bridge, likely caused by water flowing through fractured rock
It is the contention of NCDOT that work was in progress within the excavation while the put water was being pumped
directly to the stream, resulting in the discharge of turbid water and possibly violating stream standards In either event,
the fact that water was being pumped directly from the work area to the stream is ample cause for concern Water Quality
Certification No 3699, the general certification for utility lines, specifically requires that work in or adjacent to stream
waters shall be conducted in a dry work area While DCC had employed an appropriate "pump around", the direct
discharge of untreated water from the work area violates the intent of the general certification Mr Nealy was advised at
the time (by Mr Averrtte) that such practices were not acceptable by the DWQ and that in the future, all pit water
discharges must go into an approved settling basin or silt bag
Noe Carolina
Naturally
North Carolina Division of Water Quality 225 Green Street - Suite 714 Fayetteville, NC 28301-5043 Phone [phone] Customer Service
Internet h2o enr state nc us FAX [phone]
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
Mr Mike Stanley
October 22, 2008
Page 2
The purpose of this correspondence is to advise Piedmont Natural Gas of the situation that occurred on October 15, and to
request that PNG ensure that all of their employees and/or contractors comply with applicable rules when working in or
around wetlands and waters of the State
At this time, the Fayetteville Regional Office has deterrmned that no further action is warranted concerning tlus event
This decision is based on the following factors
1 The prompt cooperation of Mr Nealy and DCC
2 The absence of significant stream flow
3 The fact that DWQ personnel were not on scene to document stream standard violations
If you have questions, or if tlus office can be of assistance, please contact Ken Aventte at [phone]
Sincerely,
Belinda S Henson
Regional Supervisor
Surface Water Protection Section
cc Mr Barry Harrington, NCDOT
Mr Jeff Loflin, NCDOT, Randolph Co Res Engineer
Mr Doug Wilson, Operations Mgr, PNG
Ms Judy Coble, PNG
Mr Art King, NCDOT, Div 8 DEO
(Mr Bn7ari W_renn.::)
Ms Sue Homewood, WSRO
401 file (M Stanley PledmontNatGaS doc)