20140957 Ver 2_More Info Requested_20170911

WaterResources
ENVWONMIENTAL QUALITY
September 13, 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
MICHAEL S. REGAN
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 requested by the Division was
received on July 12, 2017. Two public hearings were held on July 18 and 20, 2017 in Fayettevile
and Rocky Mount, respectively, to receive public comments on the proposed project.
Comments received are available for review at the following link:
http://edocs.deg.nc.gov/WaterResources/o/fo1/548242/Row1.aspx. The Division has
determined that the following additional information is necessary to process your application
[15A NCAC 02H .0502(c), 15A NCAC 02B.0233(8) and .0259 (8)]:
1. The Division are concerned about the number of crossings that are proposed to be
installed using the open cut method that do not make accommodations for the work to
be completed in the dry or without exposure to flowing water. This type of crossing has
a high potential to introduce sediment into the stream channel causing degradation of
downstream water quality that may have lasting effects. This Office believes that
additional justification is necessary to ensure that water quality is protected.
a. Add a column to the Wetland and Waterbody Crossing table (Appendix C-1) for
each open cut, dam and pump, or flume explaining site specific reasons why the
crossing could not be completed using the HDD method or a conventional bore
to avoid impacts to the stream channel. Also, provide site specific examples for
minor and intermediate waterbodies, as defined by FERC, showing how these
two methods are not be feasible.
State ofNorth Carolina I Environmental Quality I Water Resources
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919 8076300

Atlantic Coast Pipeline, LLC
Request for Additional Information
DWR Project # 14-0957 v2
Page 2 of 4
b. In yourJuly 12, 2017 responsetothe Division, itwas indicated thatthe open cut
method was proposed due to the presence of inundated wetlands. Many of
these wetlands do not appear to be inundated since a discrete channel was
identified in the field survey. Provide documentation that the adjacent wetlands
are inundated outside the discrete channel for each of these crossings.
c. Your July 12, 2017 response to the Division also stated that utilizing a dry
method for many stream crossings would result in more impact for a longer
duration. However, impacts from sedimentation have a lasting impact to stream
channels. Provide an explanation of the additional impact compared to using a
dry method, including an example site-specific plan showing the additional
impact.
2. Provide site a specific crossing plan for all intermediate and major waterbodies as
defined by FERC that will be crossed using any other method than HDD or conventional
bore method. These plans should include turbidity curtain locations and upstream and
downstream water quality sampling locations for turbidity and total dissolved solids for
all crossings that will be accomplished using the open cut method.
3. Both dam and pump and the flume method are listed for many stream crossings,
provide the criteria for selecting one method over the other.
4. Provide a restoration plan for all stream crossings. These can be accomplished by
assigning a typical restoration plan for each different restoration plan that may involve
restoration of preconstruction contours, laying back banks on incised streams ' and
placement of riprap to ensure streambank stability where the conditions at the crossing
warrant this protection.
5. The typical diagrams for each stream crossing method indicate that a temporary bridge
will be installed if needed. Provide the criteria to determine if a temporary bridge will
be needed.
6. To minimize impacts to streams, reduce the construction corridor width at stream
crossing to 75 feet as is proposed for wetland crossings or explain why this isn't feasible.
7. Provide construction drawings stamped by an engineer for the Neuse River crossing.
8. The Division finds numerous places in the application where qualifiers are used when
citing methods to protect water quality (e.g. may, as appropriate, as near as practical,
where feasible). Propose a standard method and provide justification for each variation
from the standard.
9. Provide a list of the drinking water well testing parameters.
10. Provide the locations and rate of discharge of hydrostatic test water.
11. Provide all Sediment & Erosion Control plans for the project using the following link:
https://edocs.deg.nc.gov/Forms/Supplemental-Information-Form.

Atlantic Coast Pipeline, LLC
Request for Additional Information
DWR Project # 14-0957 v2
Page 3 of 4
12. Provide a plan to monitoring stream and wetland restoration through two growing
seasons once vegetation is established.
13. The Division has several questions and 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 and undertaken by entities other than ACP.
a. Provide a map of the existing transmission pipelines and their associated
distribution points in North Carolina.
b. Provide a map with all stormwater programs and 303d listed waters including
the parameter(s) for which they are impaired that are crossed by the proposed
pipeline.
c. Provide stream and wetland impacts and mitigation associated with the projects
listed in Table A-1 — Past, Present and Reasonably Foreseeable Future Projects
for the Atlantic Coast Pipeline and Supply Header Project.
d. Provide a quantitative cumulative impact analysis in accordance with the
Division's Cumulative Impact Policy for the 401 and Isolated Wetland Permitting
Programs (Ver2.1, dated April 10, 2004) for the portions of Robeson County that
are not included in a stormwater program and 303d listed waters in which
sedimentation has been identified as the pollutant.
Pursuant to 15A NCAC 02H .0502(e) / 15A NCAC 0213.0233 / 15A NCAC 02B .0259, the applicant
shall furnish all of the above requested information for the proper consideration of the
application. Please respond in writing within 30 days by sending two copies 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 [e-mail] or Jennifer Burclette at
919-807-6364 or [e-mail] if you have any questions or concerns.
Sincerely,

Atlantic Coast Pipeline, LLC
Request for Additional Information
DWR Project # 14-0957 v2
Page 4 of 4
Jeff Poupart, Supervisor
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
Filename: 140957v2AtianticCoastPipeline(Multi)_401—IC—NRB—TAR—Addlnfo2.docx