20140957 Ver 2_More Info Requested_20170913

WaterResources
ENVWONMIENTAL QUALITY
September 13, 2017
tD T NT
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Ac
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
Fayetteville 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. There are several 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 the potential to introduce
sediment into the stream channel that can cause degradation of downstream water
quality with lasting effects. Provide the additional justification requested below:
a. Add a column to the Wetland and Waterbody Crossing table (Appendix C-1) for
each open cut, dam and pump, or flume that provides site specific reasons why
each crossing could not be completed using the HDD method or a conventional
bore to avoid impacts to the stream channel.
State ofNorth Carolina I Environmental Quality I Water Resources
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919 8076300

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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 based on aerial photography and
identification of a discrete channel by the field survey. Provide documentation
that the adjacent wetlands are inundated beyond the discrete channel for each
of these crossings.
c. In your July 12, 2017 response to the Division, it was also stated that utilizing a
dry method for many stream crossings would result in more impact for a longer
duration. Provide an explanation of the additional impact and duration of the
impact compared to using a dry method, including example site-specific plans
showing the additional impact.
2. Provide a site-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. For all crossings that will be accomplished using the open cut method,
these plans should include turbidity curtain locations, and upstream/downstream water
quality sampling locations for turbidity and total dissolved solids (sampling for total
dissolved solids is only required within Water Supply Watershed areas).
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, including who will make
the decision and when the decision will be made.
4. Provide a restoration plan for all stream crossings. This 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 ' or
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.
a. If a temporary bridge isn't needed, explain how equipment will operate without
crossing back and forth within the stream channel.
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, including construction sequencing, stamped by a
licensed engineer for the Neuse River crossing.
8. There are numerous places throughout the application where qualifiers are used when
citing methods to protect water quality (e.g. may, as appropriate, as near as practical,
where feasible, when needed, etc.). Propose a standard method and provide
justification for each variation from the standard for each waterbody crossing.
9. Provide a list of the drinking water well testing parameters.

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DWR Project # 14-0957 v2
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10. Provide the locations and rate of discharge of hydrostatic test water.
11. The Division received numerous comments expressing concern over potential
sedimentation and turbidity from the construction of the pipeline. The Division
understands from the Division of Energy, Mineral and Land Resources (DEMLR) that the
proposed pipeline will be covered under two Sediment & Erosion Control Plans (one for
Northampton, Halifax, Nash, Wilson, and Johnston Counties; one for Sampson,
Cumberland and Robeson Counties), but is exempt from NPDES Stormwater Permitting
and therefore will not be covered under the NCGO10000 (Construction Stormwater
General Permit).
a. Provide all Sediment& Erosion Control plans for the project using the following
link: https://edocs.deg.nc.gov/Forms/Supplemental-Information-Form.
b. Provide an overview of the sediment and erosion control measures you plan to
implement as part of your Sediment & Erosion Control Plan, including any
measures or steps you plan to voluntarily take above the minimum requirements
(e.g. implementing the requirements in Section II.B. of the NCGO10000 permit,
etc.).
12. Provide a plan to monitor all stream and wetland restoration through two growing
seasons once vegetation is established.
13. The Division 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 or
undertaken by entities other than ACP.
a. Provide a map of the proposed pipeline showing all existing transmission
pipelines and their associated distribution points in North Carolina.
b. Provide a map of the proposed pipeline with all state stormwater programs
[Phase I & 11 (including tipped counties), Coastal Stormwater, Nutrient Sensitive
Waters (NSW), High Quality Waters (HQW), Outstanding Resource Waters
(ORW), Water Supply Watersheds] and 303d listed waters (including the
parameter(s) for which they are impaired) that are crossed by the proposed
pipeline.
The stormwater program reference GIS layer can be downloaded online:
https://deg.nc.gov/sw-maps.
ii. Contact Melanie Williams ([e-mail]) or Cam McNutt
(cam. mcnutt@ ncdenr.gov) to provide the GIS layer for 303d listed waters
if needed.
c. Provide stream and wetland impacts, and any required mitigation, associated
with the projects listed in Table A-1 — Post, Present and Reasonably Foreseeable
Future Projectsfor the Atlantic Coast Pipeline and Supply Header Project.

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d. The application indicates Metering and Regulating stations will be constructed in
Johnston, Cumberland and Robeson Counties. Johnston is a Neuse NSW county
and Cumberland is within Fayetteville's Phase 11 program; Robeson County is
neither. Provide a quantitative cumulative impact analysis for the portions of
Robeson County that are not in a High Quality Watershed (HWQ) or Water
Supply Watershed. Refer to the Division's Cumulative Impact Policy for the 401
and Isolated Wetland Permitting Programs (Ver2.1, dated April 10, 2004) for
guidance on cumulative impact analyses, available online:
https://files.nc.gov/ncdeg/Water`/`20Quality/Surface`/`2OWater`/`2OProtection/4
Ol/Policies Guides Manuals/CumulativelmpactPolicy.pdf.
e. Based on the Division's review, the proposed pipeline will cross Moccasin Creek
[27-53-(0.5)] in Johnston County, which is a 303d stream impaired for benthos.
The proposed pipeline will also cross just upstream of the following 303d
streams:
i. Stony Creek [28-68b] in Nash County, which is impaired for benthos and
dissolved oxygen;
ii. Tar River [28-(36)bl in Nash County, which is impaired for dissolved
oxygen;and
iii. Mill Creek [27-52-(1)b] in Johnston County, which is impaired for
dissolved oxygen.
Based on past and concurrent construction projects, provide a quantitative
cumulative impact analysis from construction activities of the pipeline for the 4
watersheds listed above, or alternatively provide a commitment to implement
the requirements in Section II.B. of the NCGO10000 permit or other similar
additional best management practices in these 4 watersheds.
Pursuant to 15A NCAC 02H .0502(e) / 15A NCAC 0213.0233 / 15A NCAC 02B .0259, the applicant
shall furnish all the above requested information for the proper consideration of the
application. Please respond in writing within 30 days by sending one copy 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.

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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,
Jeff Poupart, Chief
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