20171396 Ver 1_More Info Received_20171219

December 19, 2017
NCDEQ — Division of Water Resources
Water Quality Regional Operations Section
2090 U.S. Hwy. 70
Swannanoa, NC. 28778
Attention: Amy Annino
Environmental Specialist
Reference: Response to Request for Additional Information
PSNC Cliffside Lateral Pipeline Project
DWR Project # 20171396
Rutherford and Cleveland Counties, North Carolina
S&ME Project No. 7435-16-061
Dear Ms. Annino:
This letter is in response to your December 15, 2017 request for additional information received from the
NC Department of Environmental Quality (NCDEQ) - Division of Water Resources (DWR) regarding the
PSNC Cliffside Lateral Pipeline Project. NCDEQ-DWR determined that our application was incomplete and
could not be further processed until items listed in this letter were addressed.
The following paragraphs presents NCDEQ-DWR comments in bold italics followed by our responses in
standard text:
1. The October 27, 2017 submittal indicates that all streams within the proposed greenfield
segment of the project cannot be crossed at near -perpendicular angles (i.e. 75-105 degrees) as
required in Condition 3 of Water Quality Certification 4133. The Division understands the difficulty
in re -orienting crossings within, or adjacent to, the existing overhead electric utility line. However,
it is not clear why the crossings cannot meet the noted tolerance within the greenfield segment
and/or why the greenfield segment was not designed to cross streams at near perpendicular angles.
Please specify which stream crossings within the greenfield segment cannot meet this threshold and
provide additional detail as to why there are no practical alternatives to the proposed crossing
orientations. (15A NCAC 02H.0506(t) and (g)].
There are four "greenfield" stream crossings, defined herein as those crossings that occur within new
easement that does not parallel the existing powerline. Those crossings and the reasons why the new
pipe is not proposed for installation within the tolerance specified by the aforementioned Water Quality
Certification are identified in Table 1 on Page 2 of this letter.
S&ME, INC. / 9751 Southern Pine Blvd / p 704.523.4726 f 704.525.3953 / www.smeinc.com

Response to Request for Additional Information S&ME Project No. 7435-16-061
PSNC Cliffside Lateral Pipeline Project December 19, 2017
Table 1. Summary of Proposed Greenfield Stream Crossings
All of the remaining crossings occur where the new easement will parallel and abut the powerline
easement. As such, not all of those streams are crossed within the tolerance identified in the
aforementioned WQC, as indicated previously.
2. The October 27, 2017 submittal indicates that the proposed project will not meet Condition 4 of
Water Quality Certification 4133, which requires that the construction corridor be limited to 50 feet.
The submittal proposes to limit the construction corridor to 65 feet at stream and wetland
crossings, with the exception of one crossings that will require additional temporary workspace in
excess of 170 feet. Please provide additional detail regarding the need for the additional 15 feet of
construction corridor and what type of activities will occur within the construction corridor adjacent
to streams and wetlands. (15A NCAC 02H.0506(f) and (g)].
On a recent project that involved installation of gasline of a similar diameter (Phase I of the PSNC T-01
Replacement), the width of the construction corridor was limited to 50 feet at stream and wetland
crossings. However, during that project, this reduction in workspace created significant safety and
constructability issues for the contractor. To minimize potential safety concerns, PSNC and the contractor
determined that 65 feet represents the minimum amount of workspace necessary to accommodate the
following elements, all of which are necessary within that space: Installation of silt fence or other erosion
control devices, along with appropriate offsets, within the boundaries of the easement; placement of
timber mats or equipment bridges for the travel lane in such a manner that allows sufficient boom and
Shifting the proposed alignment north would result in a less perpendicular
crossing, would impact a meander in S1, and would result in additional impacts
1
9
to Stream 2. Shifting the alignment further south would also result in a less
perpendicular crossing and would impact Wetland A.
While Stream 2 will not be crossed by the new pipe, it is a tributary to Stream 1,
and may be temporarily affected by placement of a timber mat crossing during
2
10
construction. Shifting the alignment north would result in additional impacts to
Stream 1, and shifting the alignment south would cause additional impacts to Sl,
as indicated above.
Direct impacts to this stream will be avoided, as it will fall within the path of the
Broad River HDD. Existing vegetation along the bank will be hand -cleared in
22A
24
order to establish the new easement. The HDD path and new easement were
aligned to cross the Broad River in the manner proposed in order to avoid a
parallel stream channel to the west and a closed ash landfill to the east.
The easement crosses the subject stream at an approximate 700 angle (nearly
within the proposed tolerance of 75° — 105°). Topography north of the proposed
crossing steepens significantly and would create additional construction
S24
25
constraints. Moving the easement in that direction would also place the pipe
closer to a wetland and former ash basin. Shifting the pipe further south result
in additional impacts to Stream 24 and would not result in a more perpendicular
crossing.
All of the remaining crossings occur where the new easement will parallel and abut the powerline
easement. As such, not all of those streams are crossed within the tolerance identified in the
aforementioned WQC, as indicated previously.
2. The October 27, 2017 submittal indicates that the proposed project will not meet Condition 4 of
Water Quality Certification 4133, which requires that the construction corridor be limited to 50 feet.
The submittal proposes to limit the construction corridor to 65 feet at stream and wetland
crossings, with the exception of one crossings that will require additional temporary workspace in
excess of 170 feet. Please provide additional detail regarding the need for the additional 15 feet of
construction corridor and what type of activities will occur within the construction corridor adjacent
to streams and wetlands. (15A NCAC 02H.0506(f) and (g)].
On a recent project that involved installation of gasline of a similar diameter (Phase I of the PSNC T-01
Replacement), the width of the construction corridor was limited to 50 feet at stream and wetland
crossings. However, during that project, this reduction in workspace created significant safety and
constructability issues for the contractor. To minimize potential safety concerns, PSNC and the contractor
determined that 65 feet represents the minimum amount of workspace necessary to accommodate the
following elements, all of which are necessary within that space: Installation of silt fence or other erosion
control devices, along with appropriate offsets, within the boundaries of the easement; placement of
timber mats or equipment bridges for the travel lane in such a manner that allows sufficient boom and

Response to Request for Additional Information S&ME Project No. 7435-16-061
PSNC Cliffside Lateral Pipeline Project December 19, 2017
dipper arm swing radius of excavation and pipe -lowering equipment; trench excavation and sloping to a
width and depth necessary to accommodate placement of the new pipe and avoid cave-ins or undermine
adjacent equipment work space, and; space for temporary placement and separate stockpiling of topsoil
and subsoil.
Workspace exceeding 65 feet in width was necessary at S17/WX, which was this the only practicable
location for the Second Broad River HDD entrance location. Justification for this the additional workspace
at this location, along with assessment of several alternative locations, was provided in the original
submittal. Measures will be undertaken to limit the temporary impacts to the stream and wetland at this
location. The reach of stream located within the footprint of the exit pad will be piped, and construction
mats placed atop the wetland and piped stream. Following completion of the drill, the affected stream
and wetland area will be restored in accordance with the project's restoration plan.
3. There appear to be pre-existing culverts in the vicinity of stream crossings S11/WF, S20, S21/WN.
What is the pipeline construction approach in these areas with regard to the pre-existing culvert?
For example, will the pipeline be placed under the culvert will the culvert be permanently removed,
temporarily removed and returned to its original location, etc...? (15A NCAC 02H .0502(a) (4)].
The existing culvert at S11/WF will not be affected by pipe installation, as only a portion of the culvert is
located within the temporary workspace portion of the easement, and the pipeline will be installed east of
its location. The culvert at S20 will not be affected, as it is primarily located within the temporary
workspace portion of the easement, and the pipe will be installed north of its location. Similarly, the
culverts at S21/WN are located within the temporary workspace, and will not be affected by installation of
the pipeline. Efforts to prevent damage to the existing culverts, such as clear demarcation with signage,
barricade fencing, or other measures, will be employed as necessary. In the event that any of the existing
culverts are inadvertently damaged during construction, the damaged culvert will be replaced with a new
pipe of the same diameter dimension at the same location.
4. Proposed crossing S14 appears to cross the some stream two times, followed by immediately
crossing S13, resulting in what appears to be avoidable impacts. Please reconfigure the orientation
of the pipeline to one crossing of the stream or clearly explain why two crossings of the same
stream are unavoidable. [15A NCAC 0214.0506(fl and (g)]
At this location, the proposed pipeline parallels and abuts the existing powerline easement. Because
there is a meander in Stream 14 at this location, it will be crossed twice by the new pipe. Shifting the
alignment east and away from the existing powerline for a sufficient distance to allow for elimination of
one of the Stream 14 crossings would impact two populations of federally -protected dwarf -flowered
heartleaf (Hexastytis naniftora) documented approximately 50 feet east of the proposed alignment.
Moving the pipe to the opposite side of the existing powerline easement would result in two crossings of
S13, and impacts to another stream (S15) that is a tributary to S13.

Response to Request for Additional Information S&ME Project No. 7435-16-061
PSNC Cliffside Lateral Pipeline Project December 19, 2017
Thank you for your consideration of this additional information submittal. If you have questions or we can
provide anything else, please feel free to contact us at 704.523.4726.
Sincerely,
5&ME
Joey Lawler, PWS
Project Manager
Senior Reviewed by Chris Stahl, PE
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