20140957 Ver 2_Clarification Email Addendum RE RRO S&EC Plan_20171215

Burdette, Jennifer a
From: Wade Hammer <[e-mail]>
Sent: Friday, December 15, 2017 2:24 PM
To: Burdette, Jennifer a
Cc: Spencer Trichell; Richard B Gangle; Stu Buchanan
Subject: [External] ACP - NCDEQ 401/Buffer Permitting (E&S Coordination)
Attachments: NCDEQ_34ResponseItems_20171214.xlsx
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
Jennifer,
Atlantic Coast Pipeline, LLC (Atlantic) received a Letter of Disapproval from the North Carolina Department of
Environmental Quality (NCDEQ), Division of Energy, Mineral and Land Resources dated November 6, 2017. Attached
to the letter were 34 reasons that the NCDEQ provided for disapproving of Atlantic's erosion and sediment control plans
submitted. Atlantic has reviewed the reasons and is working to address the 34 reasons included with the letter. The
attached spreadsheet provides an explanation as to how Atlantic intends to respond to each item.
Please contact Spencer or me if you have questions.
Sincerely,
Wade
Wade Hammer
ERM
1000 IDS Center, 80 S. 8` St I Minneapolis I MN 155402
T+612-359-5684 I M+612-554-1970
E wade. hammer(Werm.com I W www.erm.com
This electronic mail message may contain information which is (a) LEGALLY PRIVILEGED, PROPRIETARY IN NATURE, OR OTHERWISE PROTECTED BY
LAW FROM DISCLOSURE, and (b) intended only for the use of the Addressee (s) names herein. If you are not the Addressee(s), or the person responsible for
delivering this to the Addressee (s), you are hereby notified that reading, copying, or distributing this message is prohibited. If you have received this electronic
mail message in error, please contact us immediately at [phone] and take the steps necessary to delete the message completely from your computer
system. Thank you,
Please visit:
ERM's web site: http://www.erm.com
This message contains information which may be confidential, proprietary, privileged, or otherwise protected by law from disclosure or use by a third party. If you
have received this message in error, please contact us immediately and take the steps necessary to delete the message completely from your computer system.
Thank you.
Please visit ERM's web site: http://www.erm.com

Comment
Number
Comment
Response
1
Provide a copy of the USACE 404 permit and DWR 401 certifications for the office file. Provide a copy of the
Atlantic has submitted an application for 404, 401, and riparian buffer authorizations and Atlantic
DWR Buffer Authorization. Submit documentation with maps showing location and extent of impacts to
will supply copies of the authorizations once these are received. Documentation will be
streams and wetlands with any special conditions pertaining to erosion and sediment control and restoration of
submitted showing the location and extent of impacts to streams and wetlands for any special
affected areas. Identify the streams, wetlands, and buffers on the plan sheets. The existing scale is 1 "= 200'.
conditions pertaining to erosion and sediment control and restoration of affected areas.
Provide additional plan sheets for the areas impacting streams and buffers so that these areas can be
Streams, wetlands, and buffers will be identified on the plan sheets and additional details are
represented at a larger scale and the streams and buffers can be clearly identified. Additionally, this will allow
being added as requested. A construction method column will be added to the stream table to
the engineer to provide a clearer depiction of proposed erosion and sediment control measures in these areas.
address stream crossing type and symbols will be added to the master legend sheet. The
A table is provided for the stream locations and stream types. Add a column to identify the type of stream
stream at the Smithfield Contractor Yard will be identified. General Construction Note #8 will
crossing to be installed at each of these locations. Add a symbol in the legend to identify each of the types of
include streams and wetlands.
measures to be installed (stream crossings, turbidity curtains). The stream adjacent to the Smithfield
Contractor Laydown area is riot identified. This stream is within the Neuse River Basin and should have buffer
zones identified. General Construction Note #8 should include streams and wetlands. (GS 113A -54.1(a))
2
Provide a detailed/specific construction sequence that coordinates the timing of land- disturbing activities and
Atlantic will update the construction sequence to address timing of land disturbance, stream
the installation and removal of all proposed erosion and sedimentation control measures. The construction
crossing maintenance, trench dewatering, secondary containment for filter bags, filter sock
sequences provided do not address the installation and removal of all measures. The construction sequence
and water bar maintenance, and water impoundment sites. The legend will be updated with
instructed the contractor to leave measures in place. Identify the party responsible for removing the measures.
appropriate symbols/icons.
Provide a construction sequence for each type of stream crossing and address how each of the crossings will
be maintained for pipeline construction and other construction activities. Specify how the trench will be
dewatered. The sediment laden runoff may not bypass erosion and sedimentation control measures. Specify
the type of secondary containment to be used for the filter bag Specify how the filter bags will be disposed of.
Address the use of secondary containment. 8SRF, compost filter socks, and water bars are within the footprint
of the pipe installation. Address how these measures are to be installed and maintained during the trenching
and pipe installation. Include the Water Impoundment Site in the construction sequence. (GS113A-57(3), 15A
NCAC 048 .0105, 15A NCAC 04B.0106(5))
3
Provide a legend with symbols/icons to identify all sediment and erosion control measures. Measures are to be to
Atlantic will update the legend with appropriate symbols/icons and a scale will be added to the
scale. Properly align measures on the plan sheets (examples are the construction entrance on Sheet 5 shown within
access road detail sheets. Atlantic will work with NCDEQ to clarify erosion control measures and
the public road, the water bars and 8SRF are in the footprint of the construction entrance on Sheet 7, the installation
illustrate them at scale based on the request, where revisions maintain clarity of the information
of 8SRF and compost filter socks along the wetland perimeter and streams is unclear due to the scale of the plans).
on the sheets. Wood mats will be identified either on alignment sheets or detail sheets where
Provide a symbol for the wood mats, various stream crossings, and streambank restorations provided in the plan
use of wood mats is planned. There will be no new disturbed area therefore a new Financial
detail sheets. Include these measures on the plan sheet. Identify a standard engineering scale on the Access
Responsibility/Ownership (FRO) Form is not required.
Road Detail sheets. A revised Financial Responsibility/Ownership Form and additional fee may be necessary, if the
total disturbed acreage exceeds the original submittal. (GS113A-57(3), 15A NCAC 04B .0105, 15A NCAC 04B
.0106(5))
4
Clearly show the limits of disturbance throughout the project, and include all proposed erosion and sedimentation
Atlantic will revise the Limits of Disturbance (LOD) line -type on all drawings and a note will be
control measures and land disturbing within the defined limits. The limits of disturbance are not clear due the
added to each plan sheet stating that ESC symbols are shown for clarity only and they are to be
symbols used for the erosion and sedimentation control structures. Adequate space must be provided for the
installed within the LOD. Adequate space will be provided for installation, maintenance, and
installation, maintenance, and removal of the structures. The plan states that pipeline will be assembled on site. The
removal of structures within the LOD. LOD marking will be shown and a description of how it will
plan also states that secondary containment will be provided for filter bags used for dewatering the trenches.
be flagged. The construction sequence will specify the location within the LOD for pipeline
Adequate space is to be provided for these activities. A revised Financial Responsibility/Ownership Form and
assembly. Secondary containment for filter bags will be added to the detail. There will be no
additional fee may be necessary, if the total disturbed acreage exceeds the original submittal. (GS 113A-57(3), 15A
new disturbed area therefore a new FRO Form is not required.
NCAC 04B .0105, 15A NCAC 04B.0106(5))
5
Provide design calculations for cross sections and method of stabilization for the planned channels and the
Atlantic does not plan to construct new ditches. A contingency plan for newly formed ditches will
temporary diversions. The description provided for the minor and major road upgrades and the photos shared
be drawn up and notes will be added to the construction sequence.
during the conference call earlier this month support that ditch calculations are needed to determine the need and
spacing for erosion and sedimentation control measures (erosion control matting, check dams and other measures).
Include appropriate permissible velocity and/or shear stress data. Provide liners/matting where indicated. If
liners/matting are to be installed, provide a plan detail, construction specifications, and maintenance requirements.
Identify the type of liner and the location of the liner to be installed. Include the installation of liners in the construction
sequence. (GS 113A-57(3), 15A NCAC 04B.01 13)
6
Provide the acreage for each of the disturbed areas (towers and laydown areas). The acreage of each of the project
Atlantic will review Contractor Yards, Metering and Regulating Stations, and Compressor
areas is needed to determine the adequacy of the sediment and erosion control measures. Identify the location of
Stations, and will update plan sheets with acreage and evaluate structures.
these structures on the plan sheets. (GS 113A-57(3))

7
Drainage areas exceeding one acre must have a properly designed surface dewatering device. Sediment basins
with rock dams and sediment traps are not permissible for drainage areas greater than one acre. Remove
references and details associated with these structures. Provide an appropriate structure. Identify the basins with
terminology used in the plan detail structure. Specify if the structures are skimmer basins or skimmer basins with
riser structures. Provide supporting documentation for sizing including dimensions, orifice size, and dewatering time
within 2-5 days. Provide design calculations, a plan detail, construction specifications, and specific maintenance
requirements for these structures. Provide a method to identify the basins and associate them with the design
calculations. (113A-57(3), 15A NCAC 04B.01 05, 15A NCAC 04B.01 06(5), and NCG01 Section 11.13. (4)(a))
Atlantic is reviewing Contractor Yards, M&R Stations and the Northampton Compressor Station
(Aboveground Facilities) plan sheets to confirm that surface drainage control measures are
8
Include the baffles, skimmer, and emergency spillway locations within the footprint of the basins on the plan sheets.
Include the top width and length of the basin, side slopes, and length of the weir on the plan sheets. Include the
sized and designed to adequate levels for the drainage area. Specifications and calculations will
installation of the basins and temporary diversions in the construction sequence. GS 113A-57(3), 15A NCAC 046
be provided along with revised plan sheets for review and approval. Drawings for Aboveground
0113)
Facilities will include design specifications for basins that will include baffles, skimmers,
emergency spillways, dimensions, maintenance schedules for basins and associated design
9
Provide anti -flotation calculations for the riser structures. Provide the inside and outside length and width of the riser
and height of the riser. Provide the dimensions of the anti- flotation block. These dimensions are to be included on
structures will be outlined, and the installation for these basins will be included in the construction
the plan sheet. riser inside and outside dimensions and anti -flotation block dimensions on the (GS 113A-57(3), 15A
sequence narrative or illustration.
NCAC 04B.01 13)
10
Construction specifications for the basins are to include the spacing of the porous baffles, excavation requirements,
embankment construction, spillway construction, and skimmer installation. The basin plan details should include a
gravel pad for the skimmer to rest upon and a rope attachment for maintenance. Include the dewatering time in the
Basin Schedule tables. Provide a plan detail, construction specifications, and maintenance requirements for the
skimmer and baffles. (GS 113A-57(3), 15A NCAC 04B.01 13)
11
Provide stable conveyance of the runoff entering each of the proposed basins. (15A NCAC 04B.0106(4))
12
Provide design calculations for proposed and existing culverts and storm sewers (include HW, TW, and outlet
Atlantic plans to replace/extend existing culverts (if needed) in like kind (i.e., same diameter,
velocities). The table indicating the size of the culvert based on drainage areas is not adequate. The access roads
material type, etc.). As an alternative, an outlet stabilization table is included with outlet
and driveways detail is to include pipe inlet protection and identify the rock ditch checks as check dams to be
stabilization detail specifying dimensions based upon a worst case (full flow) velocity for specific
consistent with the plan detail for this structure. Provide a table with the pipe sizes and proposed outlet stabilization
pipe diameters. Access road and driveway details will include pipe inlet protection and will
specifications for each pipe. (GS 113A-57(3), 15A NCAC 04B .0113)
identify rock ditch checks as check dams. Atlantic will provide a table with pipe sizes and
proposed outlet stabilization specifications for each pipe.
13
Identify the crossing methods for all road crossings. Provide plan details, construction specifications, and
Atlantic will identify all road crossing methods including bore pits and open cuts, and will include
maintenance requirements for all crossing types. Identify the location and type of the road crossings on the plan
plan details, construction specifications, and maintenance requirements for all crossing types.
sheets. (GS 113A -57(3),15A NCAC 04B
.0113)
14
The access roads and driveways detail is to include pipe inlet protection and identify the rock ditch checks as check
Atlantic will provide a note on the plan sheets that refers to the detail sheets for access roads
dams to be consistent with the plan detail for this structure. Provide a table with the pipe sizes and proposed outlet
and driveways. A table with pipe sizes and proposed outlet stabilization specifications for each
stabilization specifications for each pipe. Identify the type of road cross section that applies to each of the access
pipe will be provided.
roads. If cross-section varies, indicate which detail applies where. (GS 113A-57(3), 15A NCAC 04B .0113)
15
The Access Road Sequence is to include culverts, outlet stabilization, pipe inlet protection, matting, seeding, and
Atlantic will add culverts, outlet stabilization, pipe inlet protection, matting, seeding, and check
check dams; these were not included in this sequence. The plan states that the construction right-of-way (ROW)
dam information to the construction sequence, and will confirm all measures can be installed
may be used to access they project. Provide adequate measures and space to accommodate this alternative.
within the LOD. A plan detail, construction specifications, and maintenance requirements for the
Provide a plan detail, construction specifications, and maintenance requirements for the stone outlet included in this
stone outlet will be included in the construction sequence. Roadside ditch calculations will not be
sequence. Provide road side ditch calculations to determine which measures are needed to stabilize the ditch. (GS
included as no new roads are being constructed.
113A- 57(3),15A NCAC 04B .0113)
16
Provide inlet and outlet protection for all temporary pipes. Provide design calculations and construction
Atlantic will provide construction specifications for the inlet and outlet stabilization structure and
specifications for the existing and proposed outlet stabilization structures on the plan sheets. Construction
will include fabric underlayment, the width of the apron at the pipe outlet and at the end of the
specifications for the outlet stabilization structure are to include fabric underlayment, the width of the apron at the
apron, the length of the apron, the stone size, and depth of stone and will add the information to
pipe outlet and at the end of the apron, the length of the apron, the stone size, and depth of stone. (GS 113A-57(3),
the construction sequence and plan detail.
15A NCAC 04B.01 13)
17
Provide design calculations, a plan detail, construction specifications, and maintenance requirements for secondary
Atlantic will provide design calculations, a plan detail, construction specifications, and
containment structure to be used in dewatering the trenches. This containment structure must be adequately sized
maintenance requirements for secondary containment structure to be used in dewatering the
for the filter bag. (GS 113A-57(3), 15A NCAC 04B .0113)
trenches and will add the information to the construction sequence.
18
Provide a seeding plan for temporary seed (include entire calendar year), permanent seed, riparian seed, and
Atlantic will provide the temporary seeding plan for the entire year, label the plan detail for each
wetland seed. Clearly label the plan detail for each of these seeding plans. Specify the method and rate of material
of the seeding plans, and specify the method and rate of material to be used in tacking the
to be used in tacking the mulch. (GS 113A-57(2), 15A NCAC 04B.0106(3), NCG01 Section IIB (2))
mulch.

19
Include the NPDES 7/14 -day groundcover stabilization requirements table on the plan. Indicate on the plan any
Atlantic will include the NPDES 7/14 -day groundcover stabilization requirements table on the
areas that may require soil stabilization within 7 days. This requirement applies to swales, slopes, ditches, and
plan and will indicate areas that may require soil stabilization within 7 days with a call out or
temporary diversions. All areas requiring 7 -day ground cover must be specifically identified on the plan via leader
hatching on the plan. Note 5 will be updated to be consistent with ground stabilization
line, hatching or some other method. Note 5 under the Seeding Stabilization is not consistent with the ground
requirements.
stabilization requirements. General Construction Note #4 is not
consistent the with Ground Stabilization requirements. (GS 113A-57(2), 15A NCAC 04B
.0106(3), NCG01 Section IIB (2))
20
Provide additional erosion and sedimentation control measures as required to protect all public and private property
Atlantic has provided erosion and sediment control measures suitable to protect all public and
from damage. Concentrated flow must be diffused using some type of erosion control measures to prevent
private property from damage. Atlantic has reviewed the alignment sheets and placed additional
streambank erosion. Provide a silt fence outlet or other measures at low points along the silt fence. Provide
measures where the grade exceeds 5%. A side containment railing will be included along timber
additional measures where the grade exceeds 5%. Provide a side containment railing along the timber mat to
mats and maintenance requirements will be added to the plan.
prevent sediment from leaving the mat and entering the water body. - Provide maintenance requirements, to include
how these mats will be cleaned to prevent sediment from entering the water body. (113A-57(3), 15A NCAC 04B
.0105)
21
Identify where the pipeline will be bored, where the bore pits are located, and provide/delineate adequate space for
Atlantic has added bore pit locations to alignment sheets and horizontal directional drill bore
the operation. Provide a plan detail, construction specifications, and maintenance requirements for the pits and
locations have been identified. Erosion and sediment control measures will be added around
erosion and sedimentation control measures that are required. Drilling fluid cannot be discharged near a stream or
bore pits, and the construction sequence will be updated to address drill fluid disposal
wetland. Specify detailed disposal parameters (disposal areas, protective measures, disposal/discharge methods
parameters.
and rates, etc.) that will protect the stream, all public, and private property from damage. (GS 113A-57(3), 15A
NCAC 0413 .0113)
22
Provide maintenance requirements for all proposed sediment and erosion control structures, including the structures
Atlantic will provide maintenance requirements for erosion and sediment control measures that
proposed for stream crossings and streambank stabilization. (GS 113A-57(3), 15A NCAC 04B .0113)
are planned for use.
23
Provide a specific plan detail, specific construction specifications, and specific maintenance requirements for the
Atlantic has determined that the Neuse River crossing will be constructed using the horizontal
method used for crossing the Neuse River. Provide a specific construction sequence to address this phase of
directional drill (HDD) method. Atlantic will provide the site-specific drawing for the Neuse River
construction. Provide additional erosion and sedimentation control measures as required to protect the stream, all
HDD to the NCDEQ.
public, and private property from damage. Sheet pilings may be needed to provide an adequately dry space to work
in. Provide a detailed construction specifications and maintenance requirements for the selected structure. Specify
the type of coffer dam to be installed for each stream. (GS 113A-57(3), 15A NCAC 04B .0113)
24
Provide a plan detail, specific construction specifications, and specific maintenance requirements for the USFWS
stream crossing identified in the legend. Include the use of this structure in the construction sequence. (GS 113A-
Atlantic will provide plan details, maintenance requirements, and add to the construction
57(3),15A NCAC 0413 .0113)
sequence for the USFWS stream crossing identified in the plan sheet legend and the water bar
outlet and water bar breaker.
25
Provide a plan detail, specific construction specifications, and specific maintenance requirements for the water bar
outlet and water bar breaker. Include the use of these structures in the construction sequence. (GS 113A-57(3),
15A NCAC 0413 .0113)
26
Provide a plan detail and construction specifications for silt fence types that complies with the skirt trench
Atlantic has reviewed the Erosion and Sediment Control Planning and Design Manual and will
requirements per the Erosion and Sediment Control Planning and Design Manual. The skirt is to be trenched in at
provide detail and construction specifications for silt fence types to comply with the skirt trench
least 8 inches vertically and 4 inches
requirements outlined in the manual.
horizontally. Specify under which conditions the various silt fence and 8SRF types are to be installed. (GS 113A-
57(3), 15A NCAC 0413 .0113)
27
Provide maintenance requirements for the silt bag. Specify that these structures are to rest on a stone pad or soft
Atlantic will provide maintenance requirements and construction specifications for the silt bag, as
dirt (no roots, branches, or sharp objects). Include the use of this structure in the construction sequence. (GS 113A-
well as include it in the construction sequence.
57(3),15A NCAC 0413 .0113)
28
Provide a plan detail, construction specifications, and maintenance requirements for the coir log that complies with
the requirements of the Erosion and Sediment Control Planning and Design Manual. Coir Log detail should specify
wood mulch or compost rather than backfill dirt. Describe when to use Coir Log over Compost Filter Sock for
unforeseen field conditions. Detail should specify that the stake is at least 3 inches above the log. Specify the
diameter of the log. Specify the spacing based on the slope angle of and the coir log diameter. Specify the size of
the stakes. Stakes are to be hardwood. Overall construction specifications should include installing on level ground
(no clumps, tree roots, etc.) Provide a symbol in the legend for the pipe inlet and identify where these structures are
to be installed. (GS 113A-57(3), 15A NCAC 0413 .0113)
Atlantic will provide plan detail, construction specifications and maintenance requirements for

29
Provide a plan detail, construction specifications, and maintenance requirements for the compost filter sock. The
k'v"' "'C `'"" '"y a"u "'LCI v ai ivua UULCUIa ai c II0LVU ii 1 Li is i caavi i Ni UV IUVU uy a1 iu
Atlantic will review and provide within the plan details and construction sequence information that
compost filter sock detail should specify that the stake is 12 inches into the ground (below the log), with 3 inches
addresses the NCDEQ detailed specifications for these two erosion and sediment control
above the log. Specify if the installation of the sock is to be entrenched (8 -foot max spacing between stakes) or not
entrenched (4 -foot max spacing between stakes). Provide a plan detail and construction specifications for the
measures.
entrenched sock. Specify the diameter of the sock. Specify the spacing based on the angle of the slope and sock
diameter. Specify that wood mulch or compost or other material is to be blown in to Yi the height of the sock. Specify
the size of the stakes. Stakes are to be hardwood. For sections longer than 200 feet, provide a plan detail and
construction specifications for the sleeving technique. Overall construction specifications should include installing on
level ground (no clumps, tree roots, etc.) Specify if the socks are to be seeded and remain in place.
30
Provide a plan detail, construction specifications, and maintenance requirements for the turbidity curtain. Three
Atlantic will provide plan details, maintenance requirements, and construction specifications for
types of curtains are mentioned in the plan, but only two details are provided. Specify the type of structure to be
each of the three types of silt curtains outlined in the plans, and Atlantic will identify the preferred
installed at each proposed location. (GS 113A-57(3), 15A NCAC 04B .0113)
type for use where identified on the plan sheets.
31
Provide a plan detail, construction specifications, and maintenance requirements for the earthen berm associated
Atlantic will provide plan details, maintenance requirements, and construction specifications for
with the slope breaker detail. Specify where this structure will be installed. (GS 113A-57(3), 15A NCAC 04B .0113)
each of the earthen berms associated with slope breakers and identify where the structures are
planned for installation.
32
The stream bank stabilization construction specifications are to identify the type of matting to be installed at each
Atlantic will provide construction specifications for stream bank stabilization matting and seeding,
stream bank. Specify the type of seed and seedbed preparation to be used. The matting is to be installed using
and where rip rap stabilization is planned, Atlantic will provide construction sequencing for these
hardwood stakes that are at least 12 inches in length. Provide a detailed construction specifications and a detailed
planned locations.
construction sequence for the rip rap streambank stabilization. (GS 113A-57(3), 15A NCAC 04B .0113)
33
Provide a note on the plans to contact the DEMLR Raleigh Regional Office at least 48 hours prior to commencing
the land -disturbing activity for each section of the project. Delineate and number the work sections on the plans.
The contact number is [phone]. The note has been added, but the work sections have not been identified.
Atlantic will comply with the request to add a note to contact DEMLR Raleigh Regional Office at
(15A NCAC 04B .106(b))
least 48 hours in advance for each section of the project, and to provide two copies of the plan
set that illustrate modifications, including a means to identify changes in the resubmittal of the
34
Provide two copies of the plan set (one full-size and one half-size), showing the modifications required for approval.
To facilitate DEMLR review, bubble, highlight, or otherwise identify the changes to your resubmittal. Provide one
plan sheets.
copy of additional items (such as design calculations). Provide a cover letter referencing the project name, project ID
number, and purpose of submittal. (G.S. 113A-57(4))