20140957 Ver 2_More Info Requested_20171026

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October 26, 2017
Atlantic Coast Pipeline, LLC
Attn: Ms. Leslie Hlartz
707 E, Main Street, 19th, Floor
Richmond, VA 23219
Subject: REQUEST FOR ADDITIONAL INFORMATION
Atlantic Coast Pipeline
Dear Ms, Hartz:
S. J A Y N1 N1 I � R N4 A N
DWR Project #14-0957 v2
Northampton, Halifax, Nash,
Wilson, Johnston, Sampson,
Cuimberland and Robeson Counties
On May 8, 2017, the Division of Water Resources (Division) received your application dated
May 3, 20'17, 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, pulbilic comment period from June 16
— August 19, 2017, to receive public comments o'in the proposed project. Comments received
are available for review at the following link:
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Based on the comments received, additional information wars requested by the Division on
September 14, 2017 and responses were received by the Division on September 22 and 29,
2017. Department of Environmental Quality, Division and Atlantic Coast Piipeline (ACIP)
representatives met on September 29, 2017 to discuss the additional information that was
received by the Division on September 22, 2017. On October 16, 2017', the Division, received'
folllow-up information from that meeting.
The Division hias determined that the following additional information is necessary to continue
to process your application [15A NCAC 0,2H .0502(c), 15A NCAC 02B.0233(8) and .0259 (8)):
1. In the Division's September 14, 2017 letter, site-specific justification for not working in
the dry and a crossing plan for each open cult crossings [sic] proposed was requested
(1.b.ii.). ACP's response on September 291h provided site-specific crossing plans for
perennial crossings only and a general justification for not planning to work in the dry.
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Atlantic Coast Pipeline, LLC
Request for Additional information
DWR Project # 14-0957 Q
Page 2 of 5
The justification cited that dry crossings would! require more time and more traffic
within the adjacent wetland potentially leading to more compaction of wet soils, and
duration of time the waterbody and wetland are exposed to the disturbance. Additional
measures to ensure the excavation is not exposed to flowing water would prevent
sedimentation impacts that may impact downstream water quality well beyond: the
work area, which outweighs the additional time and traffic required within the work
area. Additionally, a review of past natural gas pipeline projects previously certified and
applications iin review, some of which are located in areas also crossed by the proposed
project and involve pipelines up to 30 inches in diameter, shows that they all comply
with the requirement to complete stream crossings using a dry method. This includes
crossing intermittent streams and streams, within wetland areas,
a,. Change the crossing method of all stream crossings to a, dry method. Provide
an updated impact table reflecting which type of dry method will be used at
each crossing.
b. This Office recommends the use of mats to avoid soil compaction within wetland
a rens.
c. ACP may propose provisions to allow for the use of the open, cut method instead
of work -in -the -dry method's for specific stream crossings that are dry at the start
of construction and are expected to remain; dry thirolughout completion of the
pipeline installation and restoration. This will require approval by Division staff
prior to beginning the individual crossing.
2. In the Divisiion's September 14, 2017 letter, this Office asked whether all the wetlands
adjacent to stream crossings were actually inundated (1.b.2.). ACP's response on
September 22nd stated that 11 stream/wetland crossing were changed to a dry crossing
method, but that 16 of these crossings included adjacent wetlands with, hydrology
indicators that demonstrate inundation during the growing season or where photos
indicate that standing water was present at the time of the field study. During our
meeting on September 29', Division staff pointed out that the data sheets provided did
not reflect that the wetlands were inundated and photographs provided did not show
inundated wetlands, In ACP's October 13th clarification, ACP stated that most of these
waterbodies are less than 20 feet in width and are not large enough to warrant the use
of dry construction techniques, that it would be very difficult to achieve a dry ditch
condition, and that additional workspace would be reqluired. Again, other natural gas
pipeline projects certified by the Division have been, able to comply with the
requirement to complete stream crossings using a dry method even when crossing
streams, within wetland areas.
a. Change, the crossing method of these 1,6 stream crossings to a dry method.
Provide an updated impact table ireflecting,which type of dry method will be,
used at each crossing.
b. ACP may propose provisions to allow for the use of the open cut method instead
of work -in -the -dry methods for specific crossings that are dry at the start of
construction and are expected to remain dry throughout completion, of the

Atlantic Coast Pipeline, LLC
Request for Additional information
DDR Project # 14-0957 v2
Page 3 of 5
pipeline installation and restoration., This will require approval by Division, staff
prior to beginning the individual crossing.
3. In your response to 1.b.v you state:
"[s]tream crossings where the banks are deeply incised and narrow would be an
example where a temporary bridge would not be used,"
In your response to 2 you state:
Wn instances where streombanks are incised prior to construction, Atlantic would
grade the banks to a stable slope and toper the new contours into the adjacent,
undisturbed conditions outside of the right-of-way as part of the restoration of
streombo,nks.,"
In your response provided on October 13 you state:
"Atlantic does not anticipate crossing incised streams in North Carolina, and therefore
Atlantic is not providing a typical drawing for incised stream restoration."
a,. Explain this discrepancy.
b. If Atlantic is not crossing any inciis,ed streams in North Carolina, under what
circumstances, would a temporary bridge not be used?
c. If Atlantic is not crossing any incised streams in North Carolina, under what
circumstances would stream banks not be restored to preconstruction
conditions?
cl. If Atlantic is crossing incised streams, provide a typical drawing for incised
stream restoration and a list of stream crossings that will employ this type of
restoration instead of Type 1.
4,, In, your response to 1.c you state you anticipate using Type I but will use Type 2 if Type
I is unsuccessful.
a. What is the timeframe Atlantic will determiine if stabilization is unsuccessful?
What is the timeframe within which Type 2 will be installed?
b. You state that rock riprap or geogrid will not be place below the ordinary high
watermark, however the plans provid'+edl in Appendix B show riprap below the
ordinary high water mark. Correct this, discrepancy in either the narrative or the
plans.Note that placing rip rap below the ordinary high water mark may require
a perm,iit from the U.S. Army Corps, of Engineers and a certification from the
Division.
c. In your response to 2. you state "[iff woterbody flow forces require greater
stabilization, Atlantic would use riprop or a geogrid type material, as outlined in
response to item 1.c. above.,", which is different than using Type, 2 only if Type 1
fails. Explain this discrepancy.
d. Two types of restoration Iplans were provided however they were not assigned
to each stream crossing as requested. Assign Type I or Type 2 to each stream
crossiing listed in, your impact table.

Atlantic Coast Pipeline, LLC
Request for Additional Information
D'WR Project # 14-0957 Q
Page 4 of 5
In your response to 2. you state "Atlantic will use clean rock over culverts for access
across the majority of streams crossed by the pipeline that are otherwise too wide to be
crossed by a single timber mot bridge." What is "too wide"?
6. Also, in your response to 2. you state ""[t]imber mots supported by flurries will be used for
access across streams crossed by the pipeline that have too much flow for use of clean
rock over culverts." What is "too much flow"?
7. lin 6.c. the Division requested a cumulative impact analysis for Johnston, Cumberland
and Robeson Counties, however we received a cumulative analysis only for the
constructiion footprint of the three M&R stations withiiln those counties.
As, previously requested, provide a, qualitative cumulative impact analysis for all
of Johnston, Cumberland and Robeson Counties not just the construction
footprint of the M&R stations. This analysis should incliucle potential secondary
and cumulative impacts (e.g. from anticipated development resulting from the
construction of the pipeline). 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:
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b. Note this analysis iis for past or reasonably anticipated future impacts, including
expansion of the pipeline beyond the current terminus, in Robeson County,
c. Attachment I i:n the cumulative implact analysis:
i. There were, several duplicate entries. Remove any duplicate projects
from the Table.
There are several Atlantic projects listed (e.g. Atlantic Coast Pipeline
Office Building, Atlantic Coast Pipeline Utility Services, etc.). These
should be part of the current application under review, not listed within
the Table as projects that may have a cumulative impact. Remove these
from the Table and confirm that these projects are included within the
current application under review.
iii. Add a column to indicate which, projects have or you anticipate to have
impacts to surface waters.
B. Provide an HDD design for the Neuse River crossing and updated impact tables to reflect
elimination of the impact to the river and additional impacts, to surface waters and/or
wetlands that will be necessary to accomplish the crossing with the HDD method.
"'Secondary impact" means actions, or actions directly linked to an activity, that may affect classified surface
waters or wetlands that would not occur but for the proposed activity.
"Cumulative impact" means environmental impacts resulting from incremental effects of an activity when added
to other past, present, and reasonable, foreseeable future activities regardless of what entities undertake such
other actions.

Atlantic Coast Pipeline, LLC
Request for Additional information
DDR Project # 14-0957 Q
Page 5 of 5
Pursuant to 15A NCAC 02H .0502(e) / 15A NCAC 02B .0233 / 15A NCAC 0213.0259, the applicant
shall furnish all the above requested information for the proper consideration of the
application. Please respond in writing withiiin 30 days by sending one copy of all the above
requested information to the 4011 & 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.
Sincerely,
Karen Higgins, Supervisor
401 & Buffer Permitting Branch
cc: Richard Dangle, Dominion Resources Services, Inc. (via richard.b,[e-mail])
Spencer Trichell, Dominion Resources Services, Inc, (via [e-mail])
USAGE Raleigh Regulatory Field Office
DWR 401 & Buffer Permitting Branch file
Filename: 140957v2AtlanticCoastPipeline(Multi)_401_IC—NRB—TAR—Ad