HomeMy WebLinkAbout20140957 Ver 1_Add Info Rec'd with KH notes_2017092204
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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
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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.
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