20140957 Ver 2_More Info Requested Unsigned_20171019

WaterResources
ENVWONMIENTAL QUALITY
October XX, 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 was requested by the Division on
June 27, 2017 and received on July 12, 2017. Two public hearings were held on July 18 and 20,
2017 in Fayetteville and Rocky Mount, respectively, with a public comment period from June 16
— August 19, 2017, 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.
Based on the comments received, additional information was requested by the Division on
September 14, 2017 and responses were received by the Division on September 22 and 29,
2017. Department of Environmental Quality, Division and Atlantic Coast Pipeline (ACP)
representatives also met on September 29, 2017 to discuss the additional information that was
received by the Division on September 22, 2017. On October 16, 2017, the Division received
follow-up information because of that meeting.
The Division has determined that the following additional information is necessary to continue
to process your application [15A NCAC 02H .0502(c), 15A NCAC 02B.0233(8) and .0259 (8)1:
1. In the Division's September 14, 2017 letter, site-specific justification for not working in
the dry and a crossing plan for each open cut crossings [sic] proposed was requested
(1.b.i.). ACP's response on September 2 91h provided site-specific crossing plans for
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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perennial crossings only and a general justification for not planning to work in the dry.
The justification cited that dry crossings would require more time and more traffic
within the adjacent wetland potentially leading to more compaction of wet soils and
duration of time the waterbody and wetland are exposed to the disturbance. This
Office believes additional measures to ensure the excavation is not exposed to flowing
water would prevent sedimentation impacts that may impact downstream water quality
well beyond the work area, which outweighs the additional time and traffic required
within the work area. Additionally, the Division has received other gas line project
applications in the same area crossed by the ACP, which propose to complete all stream
crossing using a dry method including crossing of intermittent streams and streams
within wetland areas. Change the crossing method of all stream crossings to a dry
method. This Office recommends the use of mats to avoid soil compaction within
wetland areas. ACP may also propose provisions to use the open cut method without
these work -in -the -dry methods upon verification by Division staff that the stream is dry
and expected to remain dry throughout completion of the pipeline installation and
restoration prior to beginning the individual crossing.
a. Crossing plans for each open cut proposed were provided in response to Lb.i.
Modify the scale on the profile of each sheet to reflect the range of elevation on
the specific plan sheet instead of the range of elevation for the entire project.
b. A narrative description was provided for turbidity and TDS sampling protocol in
response to Lb.i. Modify/incorporate the following into your sampling protocol:
i. The second monitoring event will occur 2-6 hours after start of instrearn
construction.
ii. During construction: if monitoring shows turbidity exceeclances and/or
TDS violations, work will stop until the source is identified and
remediated. Measures will be re-evaluated moving forward to ensure
further exceeclances and/or violations do not continue.
iii. Records of all turbidity and TDS sampling will be retained by Atlantic for a
period of _ and provided to the Division of Water Resources upon
request.
iv. There is no averaging for stream standards; remove language regarding
4 -day average for post -construction monitoring.
v. In addition to the perennial waterbody crossings identified by Atlantic,
this sampling protocol will be employed at intermittent streams if water
is present in the right of way at the start of construction activities for that
crossing.

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2. In the Division's September 14, 2017 letter, this Office questioned whether all the
wetlands adjacent to stream crossings were actually inundated (Lb.2.). ACP's response
on September 22 n, stated that 11 stream/wetland crossing were changed to a dry
crossing method, but that 16 of these crossings included adjacent wetlands with
hydrology indicators that demonstrate inundation during the growing season or where
photos indicate that standing water was present at the time of the field study. During
our meeting on September 2 91h , Division staff pointed out that none of the data sheets
reflected that the wetlands were inundated and the photographs provided did not show
inundated wetlands. In ACP's October 13 1h clarification, contended that most of these
waterbodies are less than 20 feet in width and are not large enough to warrant the use
of dry construction techniques, it would be very difficult to achieve a dry ditch
condition, additional workspace would be required. Again, the Division has received
other gas line project applications in the same area crossed by the ACP, which propose
to complete all stream crossing using a dry method including crossing of streams within
wetland areas. Change the crossing method of these 16 stream crossings to a dry
method. ACP may also propose provisions to use the open cut method without these
work -in -the -dry methods upon verification by Division staff that the wetland is
inundated prior to beginning the individual crossing.
3. In your response to 1.b.v you state:
"[sltreom crossings where the banks are deeply incised and narrow would be an example
where a temporary bridge would not be used."
In your response to 2 you state:
"flln instances where streambanks are incised prior to construction, Atlantic would grade the
banks to a stable slope and toper the new contours into the adjacent, undisturbed conditions
outside of the right-of-way as part of the restoration of streambanks."
In your response provided on October 13 you state:
"Atlantic does not anticipate crossing incised streams in North Carolina, and therefore Atlantic
is not providing a typical drawing for incised stream restoration."
a. Explain this discrepancy.
b. If Atlantic is not crossing any incised streams in North Carolina, under what
circumstances would a temporary bridge not be used?
c. If Atlantic is not crossing any incised streams in North Carolina, under what
circumstances would stream banks not be restored to preconstruction
conditions?
4. In your response to Lc you state you anticipate using Type 1 but will use Type 2 if Type
1 is unsuccessful.
a. Explain why you "anticipate" but do not know with confidence what type of
restoration you will use at each crossing.
b. What is the timeframe Atlantic will determine if stabilization is unsuccessful?
What is the timeframe within which Type 2 will be installed?
c. You state that rock riprap or geogrid will not be place below the ordinary high
watermark, however the plans provided in Appendix B show riprap below the

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ordinary high watermark. Correct this discrepancy in either the narrative or the
plans. Note that placing rip rap below the ordinary high water mark may require
a permit from the U.S. Army Corps of Engineers and a certification from the
Division.
d. In your response to 2. you state "[ilf waterbody flow forces require greater
stabilization, Atlantic would use riprop or a geogrid type material, as outlined in
response to item 1.c. above.", which is different than using Type 2 only if Type 1
fails. Explain this discrepancy.
e. Two types of restoration plans were provided however they were not assigned
to each stream crossing as requested. Assign Type 1 orType 2 to each stream
crossing listed in your impact table.
5. In your response to 2. you state "Atlantic will use clean rock over culverts for access across
the majority of streams crossed by the pipeline that are otherwise too wide to be crossed by a
single timber mat bridge." What is "too wide"?
6. Also in your response to 2. you state "[tlimber mats supported byflumes will be usedfor
access across streams crossed by the pipeline that have too much flowfor use of clean rock over
culverts." What is "too much flow"?
7. In 6.c. the Division requested a cumulative impact analysis for Johnston, Cumberland
and Robeson Counties, however we received a cumulative analysis only for the
construction footprint of the three M&R stations within those counties.
a. As previously requested, provide a qualitative cumulative impact analysis for all
of Johnston, Cumberland and Robeson Counties not just the construction
footprint of the M&R stations. Refer to the Division's Cumulative Impact Policy
for the 401 and Isolated Wetland Permitting Programs (Ver2.1, dated April 10,
2004) for guidance, available online:
https://files.nc.gov/ncdeg/Water`/`20Quality/Surface`/`2OWater`/`2OProtection/4
01/Policies Guides Manuals/CumulativelmpactPolicy.pdf.
b. Note this analysis is for pastor reasonably anticipated future impacts, which
would include expansion of the pipeline beyond the current terminus in Robeson
County.
c. Attachment 1 in the cumulative impact analysis:
i. There were several duplicate entries. Remove any duplicate projects
from the Table.
ii. There are several Atlantic projects listed (e.g. Atlantic Coast Pipeline
Office Building, Atlantic Coast Pipeline Utility Services, etc.). These
should be part of the current application under review, not listed within

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the Table as projects that may have a cumulative impact. Remove these
from the Table and confirm that these projects are included within the
current application under review.
iii. Add a column to indicate which projects have or you anticipate to have
impacts to surface waters.
8. Provide an HDD design for the Neuse River crossing and updated impact tables to reflect
elimination of the impact to the river and additional impacts to surface waters and/or
wetlands that will be necessary to accomplish the crossing with the HDD method.
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.
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 Permitting 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—Addlnfo3.docx