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HomeMy WebLinkAbout20140957 Ver 1_Add Info Rec'd with KH notes_2017092204 0% OR owl a . . . . .. ...... . .. .... . ..... Atlantic Coast Pipeline North Carolina Department of Environmental Quality Response to Information Request for 401 Water Quality Certification Dated September 14, 2017 September 22, 20 17 Response to NCDEQ Reguest for Additional Information dated Selptember 14, 2017: The North Carolina Department of Environmental Quality (NCDEQ), Division of Water Resources (Division), sent a -Request for Additional Information" to Atlantic Coast Pipeline, LLC (Atlantic), dated September 14, 2017, to address public comments from a public comment period held by the Division between June 16 and August 19, 2017, and to address public comments from public hearings held on July 18 and 20, 2017. Consistent with a previous request for information submitted to Atlantic dated June 28, 2017, the Division stated that Atlantic's response to the September 14 request was necessary to process Atlantic's application. requesting an Individual Water Quality Certification/Buffer Authorization for the Atlantic Coast Pipeline Project (ACP or Project), Atlantic has reviewed the NCDEQ request for additional information and is providing the followina, responses and attached infort-nation according to the NCDEQ request. Each of the requests for information, as numbered in the NCDEQ request, is provided below, followed by Atlantic's response in italics: I . The proJect involves nUrnerOLIS strearn crossings that have the potential to affect dov\ nstream water q ual iv, both temporari k d Uri na construction and permaneritl Your application and responses to the Division provide th(--)rOLIgh (Yeneral descriptions of the plans for the project, however more site-specific detail is necessary to ensure that downstream �xater quality is protected. Provide tile additionaIjustification requested below: a. Add a column to the \Vetland arid Waterbody Crossing table (appendix C- I for each .vaterbod� more than 3)0 feet in width that provides site specific reasons whv each crossing could riot be completed Using the HDD method or a conventional bore to avoid impacts to the stream channel. Allunlie's Resl.)onse.- Atlantic revievved waterbodies that are not already proposed to be crossed via the HDD niethod or the conventional bore inethod that have an ordifuny high water mark vvidth qfgreater than 30ftet based onfield studies completed.for the Atlantic Coast Pipelme North C31-0fina Department of Environmental Quality Pesponse to Information Request for 40 1 Water Quali" Certification Dated September 14, 2017 September 22, 2017 provitle a staging area./br the pullbacksection, ffthe pullback section is fi,ibricatett on the west sitle, then either Snipes Roact will need to be close(l thiring pullback (48-96 hours) avid multiple nficl�vvelels will he reqUire(l, thus inereasinl(), risk ofri�lected vvelels that 14'011*1 require repair to unacceptable levels. Finallv, there are resi(lenccs a(�jacenl to where the HD�D equipinew. woulel be setup, which woukl be subjected to noise levels that are Much higher and qflonger fluration than those associated with conventional pipeline construction. Jzist�ficationfi)r no Conventional Bore: 117 orcler to 7iiiiiiinif e the impacts to the waterbo(ly, si�fficient depth qfcover will be neet-leti. In or(ler to aehieve sqf .ficient (lepilt of cover, the installation will need to be deep (e.g., greater than l5fiet), resulting in cleep bore pits. Since the bore pits will neetl to be built in saluraled amb'orflootletl wetlaiuls, sigiz�.ficant geostaticll�)I(lr-ost(itiepre,,vsi�tr�?s�t,illbee7icottiitere(l. Bore pits (lesignetl to withstan(I these types qfpresswres �ypically require ilriven sheet piling ancl signylcant bracing awl concretc-floors, Construction qfthese 4pes qf'bore pits will be time consuming aml will result in a(Iclitional (listurbances and impacts to the local residences especiall-v when compareti to the muchfitoer, linear "cut antl covet, " Construction. b. Man,,, crossings are proposed to be installed usIn,, the open cut method that do not make accommodations for the vxork to be completed in the dry or Without eXPOSUre to flo\,,in�., water. Provide a site-specificjUStification for not �\orkln- in the dry and a crossin,'-, plan for each open cut crossings pro These plans t:� - posed. ' Should include turbidity curtain locations. and upstrearn/do�\nstreain water qualit� sarnplino locations for tUrbiditN and total dissolved solids (sanipting, for total dissolved solids is on1v required vvithin 'Kater Supply Watershed areas). Atlanlic's Response: Ailanfic is workin, to make motlificalions to the erosioi7 una' sethinent control (hwiving�� (it proposecl open cul locations alnl will provicle up(laictl drawings (mtl a response bY 3 Atlantic Coast Pipeline North Carolina Department of Environmental Quality Response to Information Request for 401 Water Quality Certification Dated September 14, 2017 Septem her 22, 20 17 ii. Your JUI-V 12. 20 17 response to the Division indicated that the open cut method vNas proposed tbr several crossings dUe to tile presence of illUndated wetlands. Mam, of these vNetiands do not appear to he inundated based on aerial photograpir, and identification of a discrete channel b�, the Field survey. Provide documentation that the adjacent \vetlands are inundated beyond the discrete channel for each ofthese crossinos. Allaillic "Y Re,�Pollse: Atlantic reviewed wetlands acljacent to the 27 ivaterho(�y crossings that were listed in Table 4 of the July 12, 2017 response document as crossingV that noteti., This is an inumlated wetland with a ivaterbociv channel contained ivithin the wetland ancl,,vill there/6re be treated as a ivettand crossing (hiring construction ./bllowin,- the FERC Proce6hire�s'. " Sixteen qfthese erossings inch(cled ac�jaeent wetlan&v with 17y(,h-o1ogv indicators that (lemonstrate inun(lation during the grou,-ing season or where photos in(licate that stan(fing ivater 141(111; present at the time qfthefiiehl stutiy. L� t �mheeqsfbr the 16 wetlands are inclutled in Appen(fix A. Datasheetsfi)r the remaining I I waterbot:lies i(lentifietl in Table 4 qfthe July 12, 2017 response tiocutnew as waterboclies �,vith ac#acent inundated 14-etlancls where revicivet/ by,litlantie, an(I fielcl eon(litions tlocumerile(l at the time offleN soalies vvere not in inun(iateJ Thits, 61atasheetsfior these areas not inchide(I. Furthermore, Atlantic has conducted.fia-ther review of,these I I tvaterbo(lies an(I cletermined that the construction method to cross can be changedftom the previously proposetl opcn cu t to a dry crossin g ivhere perceptibleflo-tv exists i ising either a clani andpiump orfliane crossing tnethodfi)r these erossing�, PVaterbo(lies changingfi-oni open cut to (lam andpump orflume inch0e: 0 shIhOO8 MP20.1 • swioO01- YUP 67.7 • swio002-.,VP 67.8 • si4,,ioOO5- HP 69.3 • swio013-YUP 70.9 • swioOl I- MP 71. 0 • siviot)12- MP 71. 0 • sjopOOI- MP 84.6 • #oo003-,VP 85, 9 • Yjob003 - MP 103.9 Aflufvic's Resl.)oi-7,,N�el- The crossii7g inethoo' is elel)encleni on the siream comlitiolIs it, the tiii'le (�f crossin- The &fm ancipim,q) method i,vifl be use�l olstreains with u /owet;4whcok- *S 0-1b I flol.t. rate al the iiine where Iminjos curt he eftectiveN ll�ye(l 0 the iraier al'otani the woi-ky1mce an(II)rovitle uninierrul:fte(Iflow. 7- O'k Theflumc melho(l ivill be USM titsireavns ii,,ith lorgerflow rales al the time 011 01, it'here pumj')s cannot be staget] on the bajiks. The eilvironnfew�ll inspeefors Avo/-kinl- irith the siie conso-Liction sulmi-visor wifl mitke the (letei-lilination on the aj,?j)rojjriwe n7eiho(I to eivplolv. Because Atlantic Coast Pipeline North Carolina Department ofErivironmental Quality Response to Information Request for 401 Water Quality Certification 7 September 22, 201 Dated September l4, 201 0 ssaoOOI- MP 1169 iii. YOLII-,]Llly I 120 17 response to the Division also stated that Lltl]iZill(f a dr,� method for several stream CrOSSjIIL1,S MwOUld result in more impact for a longer dUration. Provide an explanation or the additional impact and dUration of the impact compared to Using a dry rnet.hod. including specif:-Ic plans shov�in- the additional irripact, Atlawic's Re.%[)onse: The walerbodics hi theJul-1v 12, 2017 resj)onse whel-e Atlantic noled that a dr -v 4:,possillo would result hi nl.oi-e i711PoCt'fi);- (I 10,7gel- (hilyltioll (Ire iWerinitteut strCarns that are 3 to 9 1�et wide. In accof-d(wee ti;ith the FERC Procedures, in- strew?7 COl?StT1lCIiOIl CIL'tiVitieS (11 e�Wh ol'these e)-ossing will he limited to 24 houl-s. The equi[miew used to excavate the ti-cnch vvil/ be operatedfi-ont onc of - both beinks ofthe i,v( aerbodY, and wil/ not of)erate if, the stream T"emI)orai-v sidectist Inateried e.wavated.11-olw the trench will be p�aced on the bank above the high water inark (at least 10ftetfi-oin the et4ge ofthe Ivater). (-�se Qf(l (11-y' CrOSSb7g iiiethod ut these locations would require additional time und Streaf-ii bed/bank impacts to accominodette the iii.stallation and rentoitil q0he matel-ials needed to isolate ihefloiv qfthe strealn (e.a., sandbags), Due to the si-e ol'these crossings, it �vus detennined thut 'flitines, the ol')ell-ellt (�J'OL.Ysillg rnethod would have the least iinpact olf the sirewris tind Ilse Of'o dry ci-ossi I lig ineihod vvould not reduce overall en vil-ol unei I tal iMIMCtS. 0!� iv. Both dam and purnp and flUrIle method are listed lor many stream crossin-s, Provide the criteria for selectiny one method over the other, including, v�,ho �kill make the decision and When the decision Oft vill he made. Aflufvic's Resl.)oi-7,,N�el- The crossii7g inethoo' is elel)encleni on the siream comlitiolIs it, the tiii'le (�f crossin- The &fm ancipim,q) method i,vifl be use�l olstreains with u /owet;4whcok- *S 0-1b I flol.t. rate al the iiine where Iminjos curt he eftectiveN ll�ye(l 0 the iraier al'otani the woi-ky1mce an(II)rovitle uninierrul:fte(Iflow. 7- O'k Theflumc melho(l ivill be USM titsireavns ii,,ith lorgerflow rales al the time 011 01, it'here pumj')s cannot be staget] on the bajiks. The eilvironnfew�ll inspeefors Avo/-kinl- irith the siie conso-Liction sulmi-visor wifl mitke the (letei-lilination on the aj,?j)rojjriwe n7eiho(I to eivplolv. Because Atlantic Coast Pipeline North Carolina Department offrivironmental Quality Response to Information Request for 401 Water Quality Certification Dated September 14, 2017 September 22, 2017 dischargc rales cannot accliralcli" he preclicted al this time, the decision i,vi// be rnao'c at the fime qfcrossing,-, v. The typical dia-rams for each stream crossing method indicate that a temporai-, bridge -�% i I I be instal led -i I.- needed'". Provide the criteria to determine if a temporary bridge " i I I be needed. I I.- a temporar,, bridge isn't needed. explain ho,�% equipment will operate without crossing back and forth vJthin the stream channel. Z__ Ailanfic 's Response: Temporary, brid-el�; are ulsv�l of a inqjorit.t., ofthe stream crossin,!��s to allow cquil:7inew and crews to inove alon',, the right ol ivaY in a logical manner, Atlainic will instaht leny)orarl; brio�ges (it till streams that can accommotkife a sin(yle sj)on or sinij)le in-streom sunj,�orl(s), Sfream crossin�(,,s where the banks are �Jcej?�tv incised antl norroiv wouhl be an exalrijVe vvhere a Iemj)ororY woul�l not be used. In this ca.s'e the excavation equil-miew woul(lperlbrin the work 1�om the banks hi., reaching into the tvaterbod,v. vI. Provide construction drw,,�in,,s. including COnStrUCtiOn sequencing for the NeLlse River crossin(_),. Atlamic's Resj)onse: AtIMItiC Will utilize the HDD method to cross the Neuse River. - OKY A Provide a restoration plan for all stream crossings. This can be accomplished by iding a site-specific plan for each crossing, or by providing a typical provi restoration plan for each different type of restoration (e.g., 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) and assigning which restoration plan will be used at each stream crossing, Atlanfic's Re.V)onse: Allontic has providea' �yj�ical details slaMAII-61 Wolerbodl,' CrOSSilIg restoration andreslore'aion ofwaterbotfies ivith ripral) stabilizalioll (A[)I,�endix B)� The fvj?c of'resloration to be pel:lorrned (.11 each Ivalerbo4-1v 6 Atlantic Coast Pipeline North Carolma Department of Environmental Quality Response to Inforniation Request fot-401 Water Quality Certification Dated September 14. 2017 Sep tember 22, 20 t 7 crossing in North Carolina is anticipalecl to bc I'ipc I I/( I )r till ivaicrboefles. TV17e I restoration will involvc siamlard restoration ancl stahiliZ611iol'I of s1rearn banks. I'vpe 2 resioration. as 61epicte(] in the typical tirenvin',,, ivoul(l onlv be used ifwahili--ation (,?f a walerbody was unsucccSslul (Ind require(I USC (�I'riprup or geo'grid Inalerial (dom-, the lnmks. Rock riprup, or geogria` inalcrials wouLl not be place(I beloit, the planc ofthe orclinar-v high walcrTnark. d- Provide a plan to monitor all stream and Wetland restoration through two growing seasons once vegetation is established. Explain your method for determining n whether the success criteria provided in your application are met. Ailantic's Response: A tlantic Will Monitor Wetland restoration.tbr three years qfter construction, which is required I�y the Federal Energy, Regulator -Y Commission 's (FERC) Wetland and VVaterbodv Construction and Miti.gation Procedures, Section VI. D. 4-6, which state., - Wetland revegaetation shall be considered succes�fid if all qf theJbIlowing criteria are sati#ied: a. the qf fected wetland sati,�fies the currentJederal de finitionfin- a wetland (i.e., soils, hYfIrology, and vegetation); h. vegetation is at least 80 percent qfeither the cover docutnented.f6r the wetland prior to construction, or at least 80 percent of the cover in adjacent wetland areas that were not disturbed by construction; c. if'natural rather than active revegetation was used, the plant species coinposition is consistent with ear�v suc-cessional wetlandplant communities in the qf 'f�,cted ccoregion; and d. invasivespecies and noxious weeds are absent, unless they are abundant in adjacent areas that ivere not disturbed �v construction. Within 3 years after construction, fi/(-- a report With the Secretat- y ident�,h7ing the status ofthe wetland revegetation �f forts and dociancining success as dqfined in section T71.D.5, above. The requirement to.file wetland restoration reports with the Secretary does not app�y to projects constructed under the automatic authorizatio"n, prior notice, or advance notice provisions in the FERCs regulations. 7 10 Atlantic Coast Pipeline Nortli Carolina Department of Environmental Quality Response to Information Request for 40 1 W'ater Qu�fity Certification Dated September 14, 20 17 September 22, 2017 For any wetland vt7here revegcIation. is not succes#id at the end q13 ' years qfter construction, develop and iinplenient (in consultation with a pr(#Lysional �vctland ecologist) a retnedial revegetation plan to actively revegetate ivetlands. Continue revegetation e .f ,fin-ts andfile a report annually documenlingprogress in these wetlands until wctland re -vegetation is succesyiiL In addition, -tvaterbodv bank restoration will be nionitored accordiikg to the FERC U�qlantl Erosion Control, Revegetation, and Maintenance Plan (FERC Plan), Section VII.A. I and VII.A. 4, t+'hich requires that A Ilantic.- Conductfi)llow-ul,') inspections ofall disturbed areas, as necessatj�, to deterinine the success qfreve�(,,vtation and address landowner concerns, At a inininunn, conduct inspections after thefirst and secondgrowing seasons. 2. Revegetation in non-agricultural areas shall be considered succes#id upon visual surve - v the densiq, and cover of'non-nitisance Vegetatzon are similar in density and cover to a4jacent undisturbed land�. In agricultural areas, revegetation shall be considered sticces,�fitl �vhen upon visual surve ' v, crop groivth and vigor are shnilar to ad�iacent undisturbedportions qfthe samcfield, unh�ss the easement agrectnent spec�fies othervvise. Continue revegetation c� .flbrts until revegetation is successfid. 3. (This item is notapplicable to ivaterhodY hank restoration) 4, Restoration shall be considered succes,�fid Y'the right-(#-I'Vqv su�f�ce condition is similar to adiacent undisturbed lands, construction debris is reinoved (nnh�ss othervvise approved 1) - v the laiuhnvner or land nianaging agcl7C ' V per section K.A. 6), revegetation is succes,�fiil, andproper drainage has been restored. CAAk;-- x � � 17. 2. 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 not using the standard method. Allantic's Re.�I)onse: A tlan tic can provide the _follo iving clarVication as to th e i ise qfs tandard niethod� and when deviations inay be necessary. 00 Atlantic Coast Pipeline North Carolina Department of Environmental Quality Response to Information Request for 40 1 Water Quality Certification Dated September 14, 2017 September -12, 20 � 7 The supplemental intbrination to the application states that ­brit�zic� 'inav' include clewn rock.fill over culverls, limber mats supported hyflinnes, railear flatbed's" flexi- float apparatusc-�s, or other types qfspans. " For clar�fication, Atlantic will use clean rock over culvertsfin- acce�ss across, the intiiority ol' streams crossed by the pipeline that are othe7ivise too wi .. tobecrossedkva singletinibermatbric-4ge, Tiiiibei-rii(itystippoi,ted�y.flit),Ilcslvillbciti,edfi)i- access across streams crossed kv the pipeline that have too inuch.flow.jor use q/ clean rock over culverts. Railcar heds �,vifl he used fi)r (k,cess across Streams crossed bY, the pipeline that are greater than 40fi?et wide and cannot accolnn,to(late a center support. Timber mats will be usedfior access across Sinallerstrearns crossed by the pipeline where a Sil7gle M.at can span the width of the stream. Flc-w�float apparatuses are notproposed. No other �vpes qfspans are proposed. The supplemental in1brination to the application states that llwaterpumpsfibr withdraTving lqdrostatic test water, 'ma ' y'need to be operated continuouslt,' oil. the banks qf"waterbodies and 'mqv'require rqfiteling in place. " A dantic has ident�fled the need to operate ii,,aterpumps continuously, thereky requiring that rqfiteling occur ivithin 100ftet of . ivalerbodies. Punips ivould be rqfiieled in secondary containment structures andfitel won/(/ not be stored within 100,A-ct of the etke qI'the vvaterboity or ae�jacent wetlands. The supplemental iiffiormation to the application states that "stream banks ivill then be restored 'as near as practical'to prcconstruction conditions and stabilized " A tlantic used the qualifier 'cis near cis practical' to rqflect the./act that some streambanks cannot, or should not, be put back to preconstniction Contours, In instances where streanibanks are ineisedprior to construction, .47' A t1antic would grade the banks, to a stable slope and taper the new contours into y4mp the adjacent, undisturbed eonditions outside of the right-qf-way as part of —)� k e-c:1V'C-A restoration qf streanihanks. r 4%ji Thesupplemental iiifbi-mation, to the application states that "Stabilization measures will include seeding, instalkition qferosion control blankets, or installation qfriprap materialv, 'as appropriate'. " A flantic plans to utilize standard restoration measures Tvith erosion control blankets. ffwaterbo(�Vflow .forces require grealer stabilization, Atlantic would use riprop oi- a geogrid �Ype inaterial, as outlined in response to item I. c, above. 9 Atlantic Coast Pipeline North Carolina Department of Environmental Quality Pesponse to Information Request for 401 Water Quality Certification Dated Septernber 14, 2()17 September 22. 2017 The sul?j)leniental inforivation to the uJ)plication statcs that "a hinitett ainount of sti unj� renioval and gralling 'InaY' be conducted in other areas i,('requireel bY sqft-��y relaled issucs . " At wetlands crossing�s ivhere the landscaj)e is not level or Conditions e:Vist that prevent the level al-7plication qftirnber nzats over VVethIRds soils, sotne stuml.) retnoval inay be necessary in order to produce a level and saIL- travel corridor andprevent equipinentfi-oin sliding (?ff'qf'tirnber niats. The removal Qf'stualps it,oulcl occur on (in as needed basis to support s4i' cotistritctiotiai7i-li7otasa.vta7i(14ii-elprtictice, Conclitiot7si,��i'llbeassesseti(lit)-iii�, construetion to deterniine where stuny) reffioval is required. 3. Provide a list of the drinking water well testing parameters. 47 .411(11111 - C'S Reslx)n,�c: u1aer vrel[,; wiihin 150-fi ol'the lilnit oftlisfurbunce (L ()D) (H -C YOIII[Vetl UMI tes/e�/Jbr IIH, totalsusliclule(l S010S., 101(d clissolvcti soli�ls' comh1cliviti" Ulkalinil v. aci&l -, v, sullates. oil',greasc, phenolic, iron, inanganese. alurninun?jecal colitbrin, c�oly?er, lea(l, nickel. sih)er, thallium, �inc, chromium, ar�cnic, inercurv, selenium, cvanicle, calch-IIII 11 '(1-ne's h /In, hartIness, chlori(,les, waiinonlv, cm1mitinz. anclhervfliunz� 4. Provide the [�),cations and rate of discharge ofhydrostatic test water. Atlantic �S Resj)onse: 7he table helow 1)rovit/es the milej)osl location, rale (?,/ clischarg-c, an(I t ' tj)e qfj-�v(lrostcaic test that ,vill generate the (lischart�e vvaier (inuitiline or HDD (Irillseo-inern). C" Table I Hytlro,watic Test Discharge Locations by -i'litepost, Rate of Dischaj�ge and Source of Mdrostatic Test water ill North Caralhia Drsc har e L,�),-,fflon AP -2 Rae ot Disc�� Hvd)-ovatic 0 00 500�� Mainflne Hveh-olest "-- 5000'2)'n Mainlim Hvell-olesi -8,2 9. 90 HDD PrvLc s I 12,89 NI'ainline Hwirolest 13.96 Hvdrotesi "68 .5000 Mainline Hvdrwest 34,40 1500 ZV111 HDD Pi -etesi H Atlantic Coast Pipeline North Carolina Department of Environmental Quality Response to Information Request for 401 Water Quality Certification Dated September 14, 2017 September 22, 2017 (one for Northampton, Halifax, Nash, Wilson, and Johnston Counties, on for Sampson, Cumberland, and Robeson Counties), but there may be an exemption from NPDES Stormwater permitting. a. Provide all Sediment & Erosion Control plans for the project using the following link: https�//edocs.deq.nc.(��ov?/Forms/`Supplemental-Inf-'oit-mation-Fomi, AtIantic's Response,- �'�cditnent and Erosion Control plans were iplooded.lbr the ACP in Morth C'arolino to the web- link provided on Seplember 20, 2017. The uploaded aterials that weresuhniiited to the M,'DEO files include the application m, '7 JUosJ-(ezo* DEMLR Raleigh and FaYelteville regional ffices on 13 Vlarch 201 / (rev 1) andrevisedapplication moterials that were submittedto the Raleigh and 0 Favetteville regional o 017 ffices on 28 A ugust 2 / (rev 2). b. Provide an overview of the sediment and erosion control measures you plan to implement as part of you Sediment & Erosion Control Plan, including if there are any measures or steps you plan to voluntarily take above the minimum requirements (e.g., implementing the requirements in Section 11.13 of the NCGOlOOOO Construction Stormwater General Permit, etc.). Atlantic's Response: The erosion and sediment control measures idenl�fledfior use on the Project were selected in accordance with the requirements in the FERC Plan and Procedures, and the Xorth Carolina Erosion and Sediment Control Planning and Design Manual. The baseline erosion andsedimentcontrol measures include temporary andpermanent wolerbars, trench plugs, belted silt retentionfiences and coir logs. In addition to the baseline erosion and sediment control measures, Atlantic has committed to ii-tiplementing enhanced erosion and sediment control - measures at 89 waterbody./wetland crossings ident�lzed as sensitive by the VA U,� Fish and Wildlife �5ervice (U,5FW,�). '�pecifical�y, compost,filtersock VC �O will be ulilized a/ these waterbot-�y crossings instead qfthe baseline erosion and sediment control measure (i.e., belted silt retenlionftnce). Compost filter sock is general�y recognized as having superior suspended solids filtering and removal e ffliciencv as compared to n7ost sediment barrier technologies and is qften used,for protection qf exceptionathigh qualitY environmental resources. The waterbodvAvetland crossings to receive 12 00 00 MO Atlantic Coast Pipeline North Carolina Department of Environmental Quality Response to Inforination Request for401 Water Quality Certification Ift Dated September 14, 2017 September 22, 2017 6� 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 under -taken 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, Atlantic',.s, Response.- . fip A map depicting existing transmission pipelines (based on GIS datafrom a commercial vendor, REXT4q) and the proposed ACP in North Carolina i's provided as Appendix C Distribution points along the ayisting systems, other than metering and regulating stations along the existing Transcontinental Gas Company system in western Alorth Carolina, which arc, included on thefigure, are not readily available, b. Provide the shapefiles for the proposed pipeline route. Allantic'S Response: A shapefile qf1he proposed pipeline route with mileposts in North Carolina has been provided to NCDEQ as a ZIP - file attachment to an email sent to ]VIs. Jennil�r Burdette on September 20, 2017. c. The application indicates Metering and Regulation stations will be constructed in Johnston, Cumberland, and Robeson Counties. Provide a qualitative cumulative impacts analysis for these counties. Refer to the Division's Cumulative Impact Policy for 401 and Isolated Wetland Permitting Program (Ver 2. 1, dated April 10, 2004) for guidance, available online: htlps: flfijes. ne.gov /ncdeq/Water1/o20Qaua I ity/S,urfac,e% 20Water%20 Pro tec tio r1/4 0 J/Policies Guides Manuals,'Cumulativelmi)actPolicv.-od Atlantic's Response. - Atlantic is working to complete a qualitative cumulative impacts- analysisjbr the counties ivith .11elering and Regulation stations. and 1,vill provide the updatedonolvsis hyLL-ptember 2 7 d. 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, 15 Adantic Coast Pipeline North Carofina Department ol'Envjrotinienta� Quality Respor)se to Informatim Request for 401 Water Quality Certificatioll Dated September 14- 2017 Septem ber 2 21. 20 17 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)b] in Nash County, which is impaired for dissolved oxygen;and I -52-(I)b] in Johnston County, which is impaired for Ill Mill Creek [27 dissolved oxygen. Based on past concurrent construction projects, provide a quantitative cumulative impact analysis from construction activities for the 4 watersheds listed above. Alternatively, provide a commitment to implement the requirements in Section H.B. of the NCGO 10000 permit, or other sirnilar additional best management practices, in these 4 watersheds. ,4ihmtic's Resj)onse'. Atlantic cominits to implementing the requirements in Section 11B t-Y'Ihe jVCGO10000pertni1 (or similar achlitional best managementpractices) in these 4 watersheds. vf A; Atlantic has provided these responses and will provide the remaining responses by September 29, 2017, within 30 days from September 14, 2017, per NCDEQ's request for adiltional infori-nation. 16