20161079 Ver 1_NOV Response_20171030

October 30, 2017
N.C. Division of Water Resources
450 Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
Attention: Ms. Sue Homewood
U.S. Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Attention: David Bailey
Reference: Follow -Up to Restoration Activities
Notice of Violation 2017 -PC -0630
PNG Southern Alamance System Enhancements
Gibsonville, North Carolina
DWR project No. 2016-1079
USACE Action ID No. 2016-02226
S&ME Project No. 7435-16-053
Dear Ms. Homewood and Mr. Bailey:
This correspondence is in follow-up to your September 27, 2017 Notice of Violation and Recommendation
for Enforcement letter regarding the Piedmont Natural Gas (PNG) project referenced above. The project
is located near the Town of Gibsonville (Guilford County) and the City of Burlington (Alamance County),
North Carolina. The approximate center of the project is located at 36.060619° N, -79.552300° W (Figure
1). The project was authorized under Nationwide Permit (NWP) No. 12 from the U.S. Army Corps of
Engineers (USACE) and the corresponding North Carolina Water Quality Certification from the N.C.
Division of Water Resources (DWR) on November 28, 2016.
Based on a September 22, 2017 site inspection that you conducted, it was determined that a temporary
work bridge pad had been installed within Back Creek (Stream Crossing #5) resulting in unauthorized
temporary impacts. In addition, unauthorized impacts were also observed at three other streams (#4, #6
and #7). Crossings #1-3 were not observed during the site visit. The location of each of the subject
crossing was depicted on Figure 1 in our October 9, 2017 response letter.
S&ME (Joey Lawler) met with representatives of PNG and Distribution Construction, LLC at the project site
on October 4, 2017 in order to review the subject stream crossings and determine appropriate measures
for restoring compliance. Results of our site visit, along with the proposed measures that will be
undertaken by PNG to bring the crossings back into compliance, were identified in our October 9, 2017
response letter. The restoration work was completed by October 20, 2017. PNG then notified S&ME, who
conducted a follow-up site visit on October 25, 2017 to document the completed work. A summary of
observations at the subject stream crossings is provided below. Photographs of the subject crossings
taken during the follow-up site visit are also provided (Appendix I).
S&ME, Inc. 19751 Southern Pine Boulevard I Charlotte, NC 28273 1 p 704.523.4726 1 f 704.525.3953 1 www.smeinc.com

Follow -Up to Restoration Activities S&ME Project No. 7435-16-053
PNG Southern Alamance System Enhancement October 30, 2017
Crossing #1 (36.061132°N, -79.564203°W) — Excessive riprap originally observed in the channel
bed was removed to more closely approximate the amount that was present prior to construction.
Crossing #2 (36.061160°N, -79.560723°W) - Excessive riprap originally observed in the channel
bed was removed to more closely approximate the amount that was present prior to construction.
Crossing #3 (36.061257°N, -79.548002°) — This stream and wetland crossing were conducted by
horizontal directional drill with no travel lane or maintenance corridor established. Accordingly,
this crossing was not impacted and remains undisturbed.
Crossing #4 (36.061929°N, -79.543163°W) — A small pipe overtopped with gravel was originally
observed at this crossing. The pipe and gravel were removed and the streambanks restored in
accordance with the project's original restoration plan.
Crossing #5 (36.062343°N, -79.538164°). Riprap was initially observed in the streambed under-
laying an equipment bridge. The riprap and bridge were removed and the stream banks restored
in accordance with the project's original restoration plan.
Crossings #6 and #7 (36.061890°N, -79.533015°W / 36.0613631N, -79.536150° ). The pipes and
riprap originally observed in the stream channels were removed and the streambanks restored in
accordance with the project's original restoration plan.
Based on our observations, we concluded that the restoration activities were completed in accordance
with the project's original Restoration Plan, which was included with our October 9, 2017 response letter.
The project should now be in compliance with the applicable NWP/Water Quality Certification conditions.
Thank you for your assistance in this matter. If you have questions or need additional information, please
feel free to contact us at 704.523.4726.
Sincerely,
5&ME
Jo P.W.S.
Project Manager
[e-mail]
Senior Review by Chris Stahl, PE

Appendix I
Post -Restoration Photos

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View of Crossing 1 facing downstream (south). Riprap in excess of that which was observed in the channel prior to
construction was removed.
Al
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View of Crossing 2 facing downstream (south). Riprap in excess of that which was observed in the channel prior to
construction was removed.
Project No.: 7435-16-053 SITE
Follow -Up to Restoration Activities
Taken by: S&ME i PNG Southern Alamance PHOTOGRAPHS
System Enhancement Photo Page 1
Date Taken: 10.25.2017 S
I � g

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View of Crossing 4 facing up stream (north). A pipe was removed and the streambanks restored.
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60
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View of Crossing 5 facing downstream (south). Riprap and an equipment bridge were removed and the streambanks
restored.
Project No.: 7435-16-053 SITE
Follow -Up to Restoration Activities
Taken by: S&ME PNG Southern Alamance PHOTOGRAPHS
Page 2
System Enhancement Photo Pa
Date Taken: 10.25.2017 � g

Second view of Crossing 5 facing west.
View of Crossing 6 facing south. Riprap and a pipe were removed and the streambanks restored.
SITE
PHOTOGRAPHS
Photo Page 3