20140957 Ver 2_More Info Requested_20170914

Water ReEou?-ces
ENVIRONVrNIAL. QUALITY
September 14, 2017
Atlantic Coast Pipeline, LLC
Attn: Ms. Leslie Hartz
707 E. Main Street, 19th Floor
Richmond, VA 23219
Subject: REQUEST FOR ADDITIONAL INFORMATION
Atlantic Coast Pipeline
Dear Ms. Hartz:
ROY COOPER
N,IK'1IAEL S. RL_'GAN
S. JAY ZIMMERMAN
DWR Project #14-0957 v2
Northampton, Halifax, Nash,
Wilson, Johnston, Sampson,
Cumberland and Robeson Counties
On May 8, 2017, the Division of Water Resources (Division) received your application dated
May 3, 2017, requesting an Individual Water Quality Certification / Buffer Authorization from
the Division for the subject project. Additional information was requested by the Division on
June 27, 2017 and received on July 12, 2017. Two public hearings were held on July 18 and 20,
2017 in Fayetteville and Rocky Mount, respectively, with a public comment period from June 16
— August 19, 2017, to receive public comments on the proposed project. Comments received
are available for review at the following link:
bgp._//edocs.deq.n,cg,.,ov/­WaterResouEgglZD�/548242ZRQwl.a5,1�X
The Division has determined that the following additional information is necessary to continue
to process your application [15A NCAC 02H .0502(c), 15A NCAC 02B.0233(8) and .0259 (8)]:
The project involves numerous stream crossings that have the potential to affect
downstream water quality both temporarily during construction and permanently. Your
application and responses to the Division provide thorough general descriptions of the
plans for the project, however more site-specific detail is necessary to ensure that
downstream water quality is protected. Provide the additional justification requested
below:
a. Add a column to the Wetland and Waterbody Crossing table (Appendix C-1) for
each waterbody more than 30 feet in width that provides site specific reasons
why each crossing could not be completed using the HDD method or a
conventional bore to avoid impacts to the stream channel.
State of'North Carolina I Environmental Quality I Water Resources
1617 Mail Smice Center I Raleigh, North Carolina 27699-1617
9198076300

Atlantic Coast Pipeline, LLC
Request for Additional information
DVV8Project #14-8Q57v2
Page Zaf4
b. Many crossings are proposed tobcinstalled using the open cut method that do
not make accommodations for the work tobecompleted inthe dry orwithout
exposure toflowing water,
i Provide osite-specific justification for not working inthe dry and a
crossing plan for each open cut crossings pmoposed. These plans should
include turbidity curtain locations, and upstream/downstream water
quality sampling locations for turbidity and total dissolved solids
(sampling for total dissolved solids is only required within Water Supply
Watershed areas).
ik Your July 12,2O17response tOthe Division indicated that the open cut
method was proposed for several crossings due tnthe presence of
inundated wetlands. Many ofthese wetlands dOnot appear t0be
inundated based onaerial photography and identification 0fadiscrete
channel bythe field survey. Provide documentation that the adjacent
wetlands are inundated beyond the discrete channel for each Dfthese
crossings.
iii. Your July 12, 2017 response to the Division also stated that utilizing a dry
method for several stream crossings vvOU|d result in more impact for a
longer duration. Provide anexplanation ofthe additional impact and
duration ofthe impact compared tousing adry method, including
specific plans showing the additional impact.
iv. Both dam and pump and the flume method are listed for many stream
crossings. Provide the criteria for selecting one method over the other,
including who will make the decision and when the decision will bemade.
v. The typical diagrams for each stream crossing method indicate that a
temporary bridge will beinstalled "if meeded°. Provide the criteria to
determine if8temporary bridge will be needed. |fmtemporary bridge
isn't needed, explain how equipment will operate without crossing back
and forth within the stream channel.
vi. Provide construction drawings, including construction sequencing for the
Neuse River crossing.
r. Provide arestoration plan for all stream crossings. This can beaccomplished by
providing site-specific plan for each crossing, orbyproviding atypiCG|
restoration plan for each different type of restoration (e.g. restoration of
precunstructiuncontours, laying back banks Qnincised streams, orplacement of
r1prap to ensure streambank stability where the conditions at the crossing
warrant this protection) and assigning which restoration plan will be used at
each stream crossimg,.

Atlantic Coast Pipeline, LLC
Request for Additional Information
DWR Project # 14-0957 v2
Page 3 of 4
d. Provide a plan to monitor all stream and wetland restoration through two
growing seasons once vegetation is established. Explain your method for
determining whether the success criteria provided in your application are met.
2. There are numerous places throughout the application where qualifiers are used when
citing methods to protect water quality (e.g. may, as appropriate, as near as practical,
where feasible, when needed, etc.). Propose a standard method and provide
justification for each variation from the standard for each waterbody crossing not using
the standard method.
3. Provide a list of the drinking water well testing parameters,
4. Provide the locations and rate of discharge of hydrostatic test water.
S. The Division received numerous comments expressing concern over potential
sedimentation and turbidity from the construction of the pipeline. The Division
understands from the Division of Energy, Mineral and Land Resources (DEMLR) that the
proposed pipeline has submitted two Sediment & Erosion Control Plans for review (one
for Northampton, Halifax, Nash, Wilson, and Johnston Counties; one for Sampson,
Cumberland and Robeson Counties), but there may be an exemption from NPDES
Stormwater permitting.
a. Provide all Sediment & Erosion Control plans for the project using the following
link: https:Z/edocs.deci.nc.g.ov/Formsupplemental-Information-Form.
b. Provide an overview of the sediment and erosion control measures you plan to
implement as part of your Sediment & Erosion Control Plan, including if there are
any measures or steps you plan to voluntarily take above the minimum
requirements (e.g. implementing the requirements in Section II.. of the
NCGO10000 Construction Stormwater General Permit, etc.).
6. The Division requires additional information regarding cumulative impacts. It is
important to note that an analysis of cumulative impact is required regardless of
whether these projects are separate from the ACP, not within ACP's purview or
undertaken by entities other than ACP.
a. Provide a map of the proposed pipeline showing all existing transmission
pipelines and their associated distribution points in North Carolina.
b. Provide the shapefiles for the proposed pipeline route.
c. The application indicates Metering and Regulating stations will be constructed in
Johnston, Cumberland and Robeson Counties. Provide a qualitative cumulative
impact analysis for these counties. Refer to the Division's Cumulative Impact
Policy for the 401 and Isolated Wetland Permitting Programs (Ver2. 1, dated April
10, 2004) for guidance, available online:
https://flies,nc.gov/ncde /Water%20Qua lity/Su rface%20Water%2OPr2tectio nL4
01 Policies Guides Manual 3ZCumulative,l�actPoliicy.pdf.

Atlantic Coast Pipeline, LLC
Request for Additional Information
DWR Project # 14-0957 Q
Page 4 of 4
d. Based on the Division's review, the proposed pipeline will cross Moccasin Creek
[27-53-(0.5)] in Johnston County, which is a 303d stream impaired for benthos.
The proposed pipeline will also cross just upstream of the following 303d
streams:
Stony Creek 128-68b] in Nash County, which is impaired for benthos and
dissolved oxygen;
Tar River [28-(36)b] in Nash County, which is impaired for dissolved
oxygen; and
iii. Mill Creek [27-52-(1)b] in Johnston County, which is impaired for
dissolved oxygen.
Based on past and concurrent construction projects, provide a quantitative
cumulative impact analysis from construction activities for the 4 watersheds
listed above. Alternatively, provide a commitment to implement the
requirements in Section II.B. of the NCGO10000 permit, or other similar
additional best management practices, in these 4 watersheds.
Pursuant to 15A NCAC 02H .0502(e) / 15A NCAC 0213.0233 / 15A NCAC 02B.0259, the applicant
shall furnish all the above requested information for the proper consideration of the
application. Please respond in writing within 30 days by sending one copy of all the above
requested information to the 401 & Buffer Permitting Branch, 1617 Mail Service Center,
Raleigh, NC 27699-1617.
Please be aware that you have no authorization under the Section 401 of the Clean Water Act
or the Neuse or Tar -Pamlico Buffer Rules for this activity and any work done within waters of
the state or protected riparian buffers may be a violation of North Carolina General Statutes
and Administrative Code.
Contact Karen Higgins at 919-807-6360 or karen.hiZins @ncd.enL.go or Jennifer Burdette at
919-807-6364oriennifer.burdqte@Lnc�den�r. ov if you have any questions or concerns.
Sincerely,
Jeff Poupart, Chief
Water Quality Section
cc: Richard Gangle, Dominion Resources Services, Inc. (via [e-mail])
Spencer Trichell, Dominion Resources Services, Inc. (via [e-mail])
USACE Raleigh Regulatory Field Office
DWR 401 & Buffer Permitting Branch file
Filenarne: 140957v2AtianticCoastPipeline(Multi)__,401_IC—NRB—TAR—Addinfo2.docx