20180087 Ver 2_FINAL Response NOV-2018-SS-0028_20180716

Strickland, Bev
From: Winston, Cynthia C <[e-mail]>
Sent: Saturday, July 14, 2018 2:53 PM
To: Homewood, Sue
Cc: Morris, Tom E.
Subject: [External] Piedmont Natural Gas - Line 443 Notice of Violation
Attachments: Line 443 - FINAL Response NOV-2018-SS-0028 071318.pdf
Ms. Homewood —
We appreciate your time earlier this week to discuss the ongoing work for Line 443 in Clemmons, North Carolina. As we
discussed during the meeting, significant progress has been made to restore the site and accelerate pipeline installation
so that permanent seeding can be completed. Although the Notice of Violation (NOV) that was received from the
Division of Water Resources did not require a written response, we would like provide the attached document
summarizing our activities. As mentioned in the letter, remediation of the offsite pond is scheduled to start during the
week of July 16, 2018. A hardcopy will also be sent to your office via certified mail.
If you have any questions or concerns about this correspondence or need additional information about the project,
please don't hesitate to let me know.
Cyndi
Cynthia Winston, P.E.
Duke Energy I Permitting and Compliance, Carolinas
410 S. Wilmington Street I Raleigh, North Carolina 27601
Office: [phone] 1 Cell: [phone]

Piedmont
Natural Gas
July 12, 2018
Ms. Sherri V. Knight, P.E.
Regional Supervisor, Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources
North Carolina Department of Environmental Quality
450 West Hanes Mill Road, Suite 300
Winston Salem, North Carolina 27105
Subject: Piedmont Natural Gas
4720 Piedmont Row Drive
Charlotte, NC 28210
Clemmons Area Upgrade Line 443
Davie County
401 Water Quality Certification DWR#20180087
Response to Notice of Violation and Recommendation for Enforcement
NOV-2018-SS-0028
Dear Ms. Knight:
Piedmont Natural Gas (Piedmont) is constructing a 6 -inch natural gas transmission line from
Mocksville, North Carolina to Bermuda Run, North Carolina. This 8 -mile segment of pipeline
(Line 443) is being constructed along a 50 -foot right of way. At the conclusion of the project,
the line will be used to back -feed natural gas to the Winston-Salem, North Carolina area. Line
443 will conclude at a regulator station and tie-in to existing infrastructure to provide natural gas
at 60 psi near Highway 158.
This correspondence is providing a response to the Notice of Violation (NOV) referenced above
for the Line 443 project. Although the July 3, 2018 NOV did not require a written response,
Piedmont is providing this response to highlight the significant improvements that have been
made at the site.
Specifically, the NOV outlines reported sediment releases that were made to the wetlands and
unnamed tributaries of Leonard Creek, Elisha Creek, Dutchman Creek, Noland Creek and Cedar
Creek, all of which are Class C waters of the state. The violations that were noted include the
following:
1. Title 15A North Carolina Administrative Code 02B. 0211 (2) requires that "The waters
shall be suitable for aquatic life propagation and maintenance of biological integrity,
wildlife, secondary recreation, and agriculture; sources of water pollution which preclude
any of these uses on either a short-term or long-term basis shall be considered to be
violating a water quality standard."

Ms. Sherri V. Knight
July 12, 2018
Page 2
2. Title 15A North Carolina Administrative Code 02B. 0211 (12) requires that "Oils;
deleterious substances; colored or other wastes: only such amounts as shall not render the
water injurious to public health, secondary recreation or to aquatic life and wildlife or
adversely affect the palatability of fish, aesthetic quality or impair the waters for any
designated uses;"
3. Title 15A North Carolina Administrative Code 02B. 0231 (b)(1) Liquids, fill or other
solids or dissolved gases may not be present in amounts which may cause adverse
impacts on existing wetland uses; (5) Hydrological conditions necessary to support the
biological and physical characteristics naturally present in wetlands shall be protected to
prevent adverse impacts on:
(C)The chemical, nutrient and dissolved oxygen regime of the wetland;
(D) The movement of aquatic fauna;
(F) Water levels or elevations
4. 401 Water Quality Certification #20180087 was issued to you on March 13, 2018 and
reissued as #20180087v2 on May 8, 2018. These approvals authorized the use of General
Certification No. GC0004133 for the project. Condition No. 11.5 states that all
construction activities shall be performed and maintained in full compliance with the
Sediment and Pollution Control Act.
The correspondence requires the following to address these violations:
1. Immediately take all appropriate actions as identified by the Division of Energy, Mineral,
and Land Resources to retain sediment on site.
2. The Division is in receipt of a Sediment Removal Plan dated June 26, 2018 for
restoration of a stream, wetlands and private pond which are tributaries to Noland Creek
and are identified as Stream 19 on site plans. The Division has already approved this
sediment release plan by email correspondence dated June 29, 2018. You shall notify the
Division upon commencement of stream/wetland/pond restoration activities.
Piedmont Response
As referenced above, the project also received a NOV issued by the Division of Energy, Mineral,
and Land Resources (DEMLR) dated June 21, 2018. Our response to this NOV has been
included as Attachment A to this letter. Our response to DEMLR provides a detailed summary
of the ongoing activities at the site and the restoration efforts that have been completed on the
right-of-way. These efforts are continuing and the project schedule has been modified to
accelerate pipeline installation in the areas of the corridor where the referenced stream crossing
are located. Once the pipeline is installed, final seeding can be installed, which is the best
measure to prevent any further releases. Additionally, the following actions have been taken:

Ms. Sherri V. Knight
July 12, 2018
Page 3
• Water bars have been reconstructed in accordance with the approved design.
Additional sediment basins have been added to the lowest end of the slope to provide
additional retention and a mechanism for settling.
• Where needed, the project added matting and/or excelsior wattles in the mid-section
of the water bar to minimize scouring and to deliver polyacrylamide, if needed.
• Best management practices have been implemented throughout the site. This
includes measures such as tracking spoil piles to provide a compact surface and
minimize the amount of loose soil. The tracks will also provide "mini" water bars to
help slow the flow of water, and seed along with adequate quantities of mulch are
being applied.
• The pipeline installation sequence was modified to allow for the trenching,
installation, and backfill to be completed in the sensitive areas that have had the
majority of the release events.
• Construction entrances have been cleaned and additional stone added to each entrance
to minimize track -out from the site.
• The use of "F -hooks have been evaluated on the silt fence at the bottom of the
slopes. These hooks along with wattles and polyacrylamide will provide additional
capture and settling.
• Site documentation has been updated concurrent with the site restoration to ensure
that the plans accurately reflect site conditions.
In addition to completing the efforts that were presented in our response to DEMLR, a plan to
restore impacted wetlands, a stream, and a private pond which are tributaries to Noland Creek
was developed and presented to DWR. As this off right-of-way effort proceeds, we will provide
periodic updates to your office. Currently, this work is scheduled to begin on July 16, 2018. We
will notify you prior to commencement of stream/wetland/pond restoration activities. To date,
efforts have been focused on stabilizing the right-of-way to minimize the likelihood of additional
releases prior to beginning remediation of these offsite locations. A copy of the restoration plan
is also included in Attachment A to this letter.

Ms. Sherri V. Knight
July 12, 2018
Page 4
Closing
As detailed in this correspondence and in Attachment A, the Piedmont project team has taken
significant effort to return the site to conditions as required by the approved E&SC plans. All
project personnel have been coached on the importance of permit compliance and maintaining
good housekeeping practices throughout the site. We encourage DEQ personnel to return to the
site to observe these improved conditions. If you have any questions or need any additional
information, please do not hestiate to contact Ms. Cynthia Winston, P.E. at [phone] or
[e-mail].
Sincerely,
Victor M. Gaglio /
Sr. Vice President, Chief Operating Officer Natural Gas
CC: Tom Morris
Cynthia Winston

r6liPiedmont
Natural Gas
Attachment A
July 3, 2018 Correspondence with NCDEQ-DEMLR

(� DUKE
ENERGY,
July 3, 2018
Mr. Matt Gantt
Division of Energy, Mineral, and Land Resources
North Carolina Department of Environmental Quality
450 West Hanes Mill Road, Suite 300
Winston Salem, North Carolina 27105
Subject: Piedmont Natural Gas
Duke Energy Corporation
4720 Piedmont Row Drive
Charlotte, NC 28210
Clemmons Area Upgrade Project — 6" Transmission Line
ESC Permit DAVIE-2018-012
Response to Notice of Violation — Sedimentation Pollution Control Act and
General Permit No. NCGO10000 (Received June 25, 2018)
Dear Mr. Gantt:
Piedmont Natural Gas (Piedmont) provides the following response to the Notice of Violations
sent by the Department to Piedmont, dated June 21, 2018. Piedmont is constructing a 6 -inch
natural gas transmission line (Line 443) from Mocksville, North Carolina to Bermuda Run,
North Carolina. This 8 -mile segment of pipeline is being constructed along a 50 -foot right of
way. At the conclusion of the project, the line will be used to back -feed natural gas to the
Winston-Salem, North Carolina area. Line 443 will conclude at a regulator station and tie-in to
existing infrastructure to provide natural gas at 60 psi near Highway 158. Due to rapid growth
and increased usage in the area, the existing pipelines cannot not meet demand at the needed
pressures.
Sediment Release Events from the Project
To complete this effort, approximately 94 acres of land disturbance is required. This work is
being done under Permit No. DAVIE-2018-012. The project began in April 2018 and is
scheduled to be placed in service by August 2018. Given the steep terrain of the proposed route,
and an exceptionally wet Spring, the project has experienced a series of off right -of way
sediment releases. Each of these reported events is summarized below:
• On Monday, May 21, 2018, an erosion and sediment control inspection was conducted
following several consecutive days of rain. There were four areas where sediment
reached waters of the state as follows:
1. Station 43+08 — Delineated Wetland
2. Station 89+54 — Delineated Wetland and Stream — Stream S8
3. Station 149+83 — Delineated, Wetland Stream and Pond — Stream S 12
4. Station 201+03 — Delineated Wetland — Elisha's Creek

Mr. Matt Gantt
July 3, 2018
Page 2
• On Monday, May 28, 2018, Duke -Energy's Environmental Field Support, was notified
by the project's Environmental Field Inspection sub -contractor, about erosion and
sediment control release following consecutive days of rain on already saturated soils.
The sediment releases occurred at the following locations:
1. Station 43+47 — Delineated Wetland
2. Station 55+36 — Stream
3. Station 89+54 — Delineated Wetland and Stream — Stream S8
4. Station 98+87 — Stream
5. Station 149+83 —Delineated Wetland, Stream, and Pond —Stream S12
6. Station 168+00 — Stream
7. Station 187+40 — Stream
8. Station 201+03 — Delineated Wetland — Elisha's Creek
9. Station 215+03 — Stream
On Monday, June 4, 2018, Duke -Energy's Carolina's Permitting and Compliance
department was notified by the NC Department of Environmental Quality of impacts to a
property owner's pond, adjacent wetlands and a stream that resulted from the same storm
events causing the sediment releases reported on May 29, 2018.
• On Tuesday, June 13, 2018, Duke -Energy's Environmental Field Support was notified by
the project's Environmental Field Inspection sub -contractor about erosion and sediment
control releases following an intense rain event that occurred the previous evening.
Despite the addition of extra erosion and sediment control BMPs the previous week, there
were multiple sediment releases as follows:
1.
Station 55+82 —
Stream
2.
Station 89+54 —
Delineated Wetland and Stream — Stream S8
3.
Station 168+00
— Stream
4.
Station 187+24
— Stream
5.
Station 201+03
— Delineated Wetland — Elisha's Creek
6.
Station 215+03
— Stream (rock/flume crossing)
7.
Station 293+80
— Sediment release to wetland
On Friday, June 22,
2018, Duke -Energy's Environmental Field Support was notified by
the project's Environmental Field Inspection sub -contractor about additional impacts at
the following locations after overnight storms passed through the area:
1. Station 89+54 —
Delineated Wetland and Stream — Stream S8
2. Station 168+00
— Stream
3. Station 215+03
— Stream (rock/flume crossing)
4. Station 248+90
— North of Sain Rd., Creek crossing (McLamrock Pond) soils impact
5. Station 319+86
— Upland soils impact in wetland

Mr. Matt Gantt
July 3, 2018
Page 3
• On Tuesday, June 26, 2018, Duke -Energy's Environmental Field Support was notified by
the project's Environmental Field Inspection sub -contractor about erosion and sediment
control releases following an intense rain event that occurred the previous evening.
1. Station 39+73 — Sediment release to stream
2. Station 43+47 — Sediment release to wetland
3. Station 55+76 — Sediment release to stream
4.
Station 89+61 — Sediment release to stream
5.
Station 150+39
— Sediment release to stream
6.
Station 167+50
— Sediment release to stream
7.
Station 183+00
— Sediment release reached off right-of-way pond
8.
Station 187+43
— Sediment release to stream
9.
Station 201+07
— Sediment release to wetland (Elisha Creek)
10. Station 214+61
— Sediment release to stream
Notice of Violation
On June 25, 2018 Piedmont received a Notice of Violation (NOV) for the reported events. The
document cites violations of the Sediment Pollution Control Act (SPCA) and the General Permit
(NCG-010000) to Discharge Stormwater under the National Pollutant Discharge Elimination
System (NPDES) for Construction Activities (i.e., Construction Stormwater General Permit). In
this NOV, a response to the violations is required within 10 days from receipt of the document
via Certified Mail.
Specifically, the NOV outlines five infractions of the SPCA and one violation of the
Construction Stormwater General Permit. These are as follows:
1. Failure to conduct land -disturbing activity in accordance with the approved erosion and
sedimentation control plan. (G.S. 113A-57(5)).
2. Failure when a land -disturbing activity that will disturb more than one acre is undertaken
on a tract, to install sedimentation and erosion control devices sufficient to retain the
sediment generated by the land -disturbing activity within the boundaries of the tract during
construction upon and development of the tract. (G.S. 113A-57(3)).
3. Failure to take all reasonable measures to protect all public and private property from
damage by such land -disturbing activities. (15A NCAC 4B .0105).
4. Failure to install and maintain all temporary and permanent erosion and sedimentation
control measures as required by the approved plan or any provision of the SPCA, and rules
adopted thereunder, during or after the development of a site. (15A NCAC 4B .0113).
5. Failure to retain along a lake or natural watercourse a buffer zone of sufficient width to
confine visible siltation by natural or artificial means within the 25percent of that portion of
the buffer zone nearest the land -disturbing activity. (G.S. 113A-57(1)).
6. Failure to operate and maintain control measures. The Permittee shall at all times properly
operate and maintain all control measures and systems of treatment and control (and related
appurtenances) which are installed or used by the permittee to achieve compliance with the
conditions of this general permit. (NCG 010000, Section IV, 1).

Mr. Matt Gantt
July 3, 2018
Page 4
The document requires that the following actions be completed within 10 days of receiving this
NOV and that Piedmont provide additional detail on the following items in reference to the
SPCA:
1. Remove all accumulated sediment from silt fence and silt fence outlet areas. Reinstall all
silt fence outlets per the construction detail shown on sheet 28 of 32 of the approved
plans dated February 16, 2018.
Response: There are approximately 140 silt fence outlets shown on the design plans.
Crews have been working diligently on the right-of-way to remove all accumulated
sediment. As a temporary measure to minimize the likelihood of additional releases,
some silt fence outlets had been reinforced with straw bales on the outlet side of the
structures. As crews have been working the length of the project, the straw bale
measures are being removed and the outlets are being repaired to the referenced
specification. Specifically, wattles are being installed at the outlet structures and the
openings are being reinforced with a woven wire backing. Where there is adequate space
on the right-of-way, sediment pits are being added to the inlet side of the silt fence outlet
(per detail shown on sheet 28 of 32). In many cases, coir -fiber baffles have been added
to the sediment pits to aid in the capture and settling of suspended material. These baffle
details are not shown on the detail but provide added sediment measures as a best
management practice.
2. Repair all of the damaged water bars along the project alignment and reconstruct them
per the construction detail shown on sheet 30 of 32 of the approved plans dated February
16, 2018.
Response: As mentioned earlier, this project right-of-way is characterized by a number
of steep slopes. On each of these slopes, water bars are used to slow the flow of water
and to direct the flow to a silt fence outlet. During the course of construction, some of
these water bars shifted from their intended design (i.e. height, compaction, and slope).
The contractor has been working to reconstruct all of these water bars in accordance with
the approved design. As mentioned in Item No. 1, additional sediment pits have been
added to the lowest end of the slope to provide additional retention and a mechanism for
settling.
Where needed, the project's Environmental Engineer with S&ME will direct the
contractor to add excelsior wattles with excelsior splash pads (if needed) in the mid-
section of the water bar and to apply polyacrylamide to aid in sediment dropout. The
addition of polyacrylamide is not referenced on the plans but is being applied as a best
management practice.

Mr. Matt Gantt
July 3, 2018
Page 5
3. Complete ground stabilization of inactive areas per the NPDES Construction Storm
Water Permit. The table that specifies NPDES ground cover requirements is shown on
sheet 3 of 32 of the approved plans dated February 16, 2018.
Response: As the crews are repairing the silt fence and silt fence outlets. They are
completing temporary and permanent stabilization of the project when possible around
the pipeline construction activities.
To date, the pipeline work is complete from Station 01+00 through Station 89+61, and
from 142+50 to 193+00. Therefore, seeding contractors have completed permanent
stabilization for these areas. In other areas of the project, Piedmont along with S&ME's
engineer will be evaluating the right-of-way topography to combine best management
practices to determine temporary stabilization in an effort to improve the performance of
the right-of-way. This includes measures such as tracking spoil piles to provide a
compact surface and minimize the amount of loose soil. The tracks will also provide
"mini" water bars to help slow the flow of water, and seed along with adequate quantities
of mulch are being applied.
Although not directly related to ground stabilization, the pipeline installation sequence
has been changed to allow for the trenching, installation, and backfill to be completed in
the sensitive areas that have had the majority of the release events. By completing
construction in these areas sooner, it has allowed seeding contractors to apply permanent
seed in these areas ahead of the current schedule.
Temporary seeding will be completed at the following rates: millet at 50 lb/acre,
limestone 2,000 lb/acre, 7501b/acre of 10-10-10 fertilizer, and straw mulch. The seeding
contractor will ensure that appropriate rates to achieve a 90-100% coverage of exposed
soil with the straw mulch are achieved. In areas of welding, the straw mulch is being
removed on a daily basis to prevent potential fire hazards.
Regarding final stabilization, rolled erosion control product (RECP) on all slopes of 50% will
be used. The RECP will be designed with properties to accommodate these aggressive
slopes. Curlex 1 or SEC 150 Bio net, as specified in the plans, meets this requirement. Any
final slopes greater than 50% will require a more robust RECP. Installation with anchor
trench and extensive stapling will be completed per detail on Sheet 32.
4. Submit an acceptable restoration plan to this office for review and approval. The
restoration plan must address areas where sedimentation has been deposited off of the
approved right-of-way for the project. According to correspondence received from Duke
Energy received on June 15, 2018, these areas would include, but not limited to, stations
55+82, 89+54, 168+00, 187+24, 201+03, 215+03, and 293+80.
Response: Given the similar terrain at each of these locations and that the water flow
exits into similar natural features (i.e., wetlands and streams), the restoration plan for the
referenced locations and stations that have had releases since the beginning of
construction is the same and is as follows:

Mr. Matt Gantt
July 3, 2018
Page 6
• Water bars are being properly installed on slope faces. In addition to a properly installed
water bar, silt fence outlets are being repaired to conform with the design specifications,
and where possible, sediment pits are being installed per the plans to allow for on right-
of-way retention (detail shown on sheet 28 of 32). Coir -fiber baffles have been added to
provide additional settling mechanisms as a best management practice.
• Contract personnel have been educated on the benefits of polyacrylamide products to
provide flocculation of sediment which will also enhance on right-of-way settling of any
material.
• Collected sediment on bridges is being collected and removed.
• Good housekeeping practices are being reinforced with all contract personnel. As
structures are repaired and cleaned following a rain event, collected material is being
placed in up -gradient locations where it is less likely to overwhelm the structures in
future rain events.
• Construction entrances have been cleaned and additional stone added as needed to each
entrance to minimize track -out from the right-of-way.
• The use of "F -hooks have been evaluated on the silt fence at the bottom of the slopes.
These hooks along with wattles and polyacrylamide will provide additional capture and
settling. Polyacrylamide will be used on up -gradient sediment control measures,
reserving the outlet locations for final settling after seeding is applied and Curlex is
applied to the water bars.
Contract personnel have been working diligently to ensure the right-of-way is in compliance
with the approved design plans and that additional measures have been installed. The project
team has had the S&ME environmental engineers walk the right-of-way to provide additional
guidance, as well as, a recognized industry expert to provide observations. Effective July 4,
2018, the repairs and best management practices mentioned herein are being installed during the
pipeline construction activities or have been completed.
Under the violations of the Construction Stormwater General Permit, Piedmont is required to
address the following as part of their response:
1. The date by which the corrective actions listed above have been or will be completed.
Response: The project is still in active construction and restoration efforts are on-going.
The contractor is working diligently in a safe and responsible manner to complete the
restoration per the project plans and specifications. As of July 4, 2018 the contractor has
temporarily or permanently restored the exposed right-of-way paying particular attention
to the water crossings and other environmentally sensitive areas. Construction personnel
have been coached on the project expectations and the permit requirements to help
prevent future occurrences. Additionally, inspections of the right-of-way have been
increased.

Mr. Matt Gantt
July 3, 2018
Page 7
2. A plan of action to prevent future violations.
Response: As mentioned above, the project is still in active construction. Right-of-way
personnel have been coached on the project expectations and permit requirements to help
prevent future occurrences. The contractor has brought in additional environmental
crews including Sequoia Services to support right-of-way restoration and specialized
seeding contractor, Sides Seeding to support the right-of-way restoration. Expectations
are reinforced and documented as part of the daily pre job brief to ensure personnel are
aware of the requirements. Duke -Energy's and S&ME's Environmental Field Support
personnel are visiting the right-of-way more frequently to provide oversight and a fresh
set of eyes to review ongoing activities.
Example installations of the control measures has been completed on the right-of-way so
that project personnel can see what the final measure should look like.
3. A plan for restoration of sedimentation damage.
Response: The contractor is working to remedy off right-of-way sediment in using hand
tools to minimize any additional impact to the environmentally sensitive areas.
There has been one sediment impact to a neighboring pond. S&ME has developed a
restoration plan for the pond which has been reviewed and is in agreement by the pond's
landowner and Sue Homewood of the Department of Water Quality. A copy of this
document is included as Attachment A to this correspondence.
4. Reasons why a civil penalty should not be assessed.
Response: As the Department evaluates the need for a civil penalty, Piedmont requests
consideration of the following additional information relevant to the factors set out in
G.S. 143-215.6A(c).
Due to the rapid response described above, there will be no lasting harm to the natural
resources of the State, to the public health, or to private property resulting from the
violations. Impacts to streams and wetlands have been corrected by the thorough
removal of the released sediment. To the extent latent impacts are identified in the next
several months, they will be addressed in cooperation with DEQ.
The rapid response further ensured that the violation was brief. The company has been
transparent about the issues on the right-of-way and made timely verbal and written
notifications to DEMLR, DWR, and ACOE. Further, the company has invested a
significant amount of resources to ensure that impacts were quickly addressed. We
recognize the importance of implementing quality erosion and sediment control
measures. Our employees and contractors are trained to avoid releases regardless of costs
or impacts to project schedule. The releases have been accidental and unintentional, and
Piedmont is implementing the steps described above to ensure that it does not happen
again.

Mr. Matt Gantt
July 3, 2018
Page 8
Closing
As detailed in this correspondence, the project team has taken significant effort to return the
right-of-way to conditions as required by the approved E&SC plans and have been coached on
the importance of permit compliance and maintaining good housekeeping practices throughout
the right-of-way.
To be fully transparent, we do not have all E&SC measures completed as required by the
direction of the NOV. We are proactively applying best management practices in the areas that
are still in construction in a safe and deliberate manner. We are committed to doing this with the
highest level of quality in the most expedient way. With the dry weather we have had over the
past week or so, we have made substantial progress to clean the areas where off right-of-way
sediment occurred and to install the E&SC measures per plan.
We ask for some leniency from the state during the upcoming site inspections. I am confident
that you will notice tremendous progress and would respectfully request additional time for
effective completion of all E&SC measures as required by the NOV. As a result of this incident,
we will be applying best management E&SC practices to all of our natural gas projects. We
appreciate your collaboration in helping us improve our performance.
We encourage DEQ personnel to return to the right-of-way to observe these improved
conditions.
If you have any questions or need any additional information, please do not hestiate to contact
Ms. Cynthia Winston, P.E. at [phone] or [e-mail].
Sincerely,
1� - X.
Victor M. Gaglio
Sr. Vice President, Chief Operating Officer Natural Gas
CC: Tom Morris

Piedmont
Natural Gas
Attachment A
Corrective Measures and Proposed Sediment Removal Activities
Neighboring Pond

DUKE
ENERGY
June 26, 2018
North Carolina Department of Environmental Quality
Winston Salem Regional Office
450 West Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
Attention: Tim Latham
Senior Environmental Specialist
Subject: Piedmont Natural Gas
Clemmons Area Upgrade Project
Sediment Removal Plan
ESC Permit DAVIE-2018-012
USACE Action ID SAW -2018-00459
DWR Project No. 20180087
Dear Mr. Latham:
Duke Energy Corporation
4720 Piedmont Row Drive
Charlotte, NC 28210
Duke Energy hereby submits this Sediment Removal Plan in response to release of sediment to
an off right-of-way (ROW) property that occurred during construction of the Piedmont Natural
Gas Line 443 Pipeline Project. This plan was prepared to address clean-up and remediation
activities in accordance with the recommendations provided by Sue Homewood during her
June 5, 2018 site visit and assessment of the affected off ROW areas.
Background
Duke Energy is in the process of installing a segment of six-inch diameter steel natural gas
transmission pipeline that is approximately 7.2 miles in length in a 50' wide permanent ROW
easement. The construction contractor working on behalf of Duke is Progressive Pipeline.
The Erosion and Sediment Control (E&SC) Plan for the project was approved by the NC
Department of Environmental Quality (NCDEQ) on February 16, 2018
(Project ID Davie 2018-12). Temporary impacts to on-site waters and wetlands were originally
authorized by the NCDEQ - Division of Water Resources (DWR) on March 13, 2017
(Project No. 20180087), and by the US Army Corps of Engineers (USACE) on March 18, 2018
(SAW -201800459).
Clearing of the new easement began around April 23, 2018. Since that time, nearly ten inches
of rainfall has been recorded at the project site. During the week of May 14, 2018,
approximately 4.3 inches of rainfall were recorded, including a single three-inch rainfall event
that occurred in a period of less than two hours on May 18, 2018, and on May 26, a rain event
exceeding one inch in an approximately 45 minute period was recorded. Duke promptly notified
NCDEQ of several sediment releases associated with the respective rainfall events. The
project's environmental field support crews immediately mobilized to remove any resultant
Clemmons Area Upgrade Project
Sediment Removal Plan

sediment that was observed in streams or wetlands crossed by the project. Remedial measures
and additional E&SC devices installed to inhibit further off-site sediment releases were
documented in a June 1, 2018 notification letter provided to NCDEQ by Duke.
In addition to Ms. Homewood's review of the cleanup efforts associated with those sediment
releases, a second purpose of the June 5, 2018 site visit was to observe more -recently
identified off-site impacts to Stream 19 and a pond located north of the easement. Stream 19 is
an unnamed perennial tributary to Noland Creek (DWR Index No. 12-102-12, Class C Waters)
and crosses the easement at a point approximately 850 feet north of Sain Road (35.927253° /
80.529650°) on Davie County Parcel No. 5749759853. The stream flows north of the easement
through a wooded portion of Parcel No. 5749769372 and eventually to an in-line pond located
on Parcel No. 5749772809, approximately 900 feet north of the easement. The general project
location of Stream 19 is depicted on the Site Vicinity Exhibit (Figure 1), and in further detail on a
Sediment Removal Plan Exhibit (Figure 2).
The release of sediment to Stream 19 was likely attributed to the May 18, 2018 event, when a
portion of silt fence was overtopped. Following the release, sediment was removed from the
stream channel by the contractor. However, additional sediment that was located in an
upstream area not visible from the easement was observed during the June 5, 2018 site visit.
Sediment located there was likely re -mobilized during the May 26, 2018 event and washed
downstream, eventually into the off-site pond. Because a majority of the sediment that washed
through Stream 19 settled out on the floodplain near the pond, well downstream of the
easement, the release was not originally observed by environmental support staff. Duke was
later made aware of the release by the property owner.
Site Observations
Present at the June 5, 2018 site visit were Sue Homewood (NCDEQ-DWR), Michael Reikowsky
and Chris Friel (Duke Energy), Cody Gavranovic (Chief Environmental Inspector with EnSite),
Joey Lawler (Natural Resources Project Manager with S&ME), along with personnel from
Progressive Pipeline.
Construction and E&SC maintenance activities was on-going within the subject portion of the
easement at the time of the meeting. An equipment crossing and associated E&SC measures
had been installed across Stream 19. Downstream of the easement, the upper reaches of
Stream 19 are located within a relatively confined valley. Segments of the stream exhibited a
slightly -incised channel, but areas of significant erosion or bank scour were not observed.
Lower reaches of the stream, from approximately 800' downstream of the easement to the
pond, are not incised, and the channel becomes more sinuous, with ample floodplain access. In
general, the channel width ranged from 3-6 feet, with the normal substrate ranging from sand to
mixed gravel/cobble.
Personnel present at the meeting walked the length of Stream 19 from the easement to the on-
site pond in order to observe its condition and note areas where cleanup activities were
warranted. Portions of the stream where sediment consisted of only a fine film were also noted.
In general, construction -related sediment in quantities that warranted removal and further
disturbance was observed at several locations, generally behind debris jams or similar channel
blockages.
2 Clemmons Area Upgrade Project
Sediment Removal Plan

Sediment accumulation was also observed within the floodplain of Stream 19 upstream of its
confluence with the off-site pond, and within a portion of the pond itself. In this area, sediment
appeared to range from one-two inches in depth on the flood plain.l[MTE11
Ms. Homewood and Mr. Lawler also walked Stream 19 upstream of the easement crossing and
observed conditions similar to those observed in the downstream portion. Additional sediment
was observed in a small wetland area (approximately 0.10 -acre) located approximately 200 feet
upstream of the easement. Sediment in this area likely originated from a silt -fence or outlet
failure along the adjacent cut slope on the east side of the easement.
Corrective Measures and Proposed Sediment Removal Activities
During the site visit, a two -phased approach to addressing the sediment release was proposed.
The first phase involved additional stabilization measures to prevent further erosion and off-site
sediment impacts. The contractor is also planning to selectively introduce environmentally
friendly flocculants as a passive treatment system on the project site to enhance sediment
settling on sediment control measures on the project site. No flocculants will be used in
jurisdictional areas. Remediation that requires work outside of the easement or on adjacent
properties affected by the release is being arranged with the respective owners by Duke
Energy.
Environmental field crews have been actively undertaking maintenance and installation of
additional E&SC measures since the time of the respective rain events. To provide immediate
protection and prevent further impacts, cleaning and maintenance was performed on the
existing silt fence outlet structures along the easement north of Sain Road. A second row of silt
fence was also installed along the east side of the easement at the base of the cut slope.
At the recommendation of Ms. Homewood, environmental field crews have installed four in -
stream check dams (staked filter socks) in Stream 19 to intercept additional remnant sediment
or that which was created during upstream cleanup activities. Two of the checkdams are located
at the downstream corner of the easement, and two others are constructed between the
easement and the off-site pond. The checkdams are being maintained and inspected on a daily
basis, and accumulated sediment removed. A Temporary Checkdam Detail is included in
Appendix I.
Environmental field crews will then remove sediment from the off-site wetland upstream of S19
in areas where greater than approximately '/2 inch can be discerned from the native substrate.
Sediment appearing to consist of a fine film or less than that which can be removed without
creating a greater disturbance may remain. Sediment removed from the wetland will be
transported to the easement or a suitable high ground location and stabilized. A Sediment
Stockpile Stabilization detail is included in Appendix I. Affected areas will then be seeded and
mulched with a native wetland seed mix (Appendix II).
The additional E&SC measures will remain in place until project completion and Land
Resources has approved their removal according to Construction Stormwater Permit NCG
010000. Duke Energy will notify NCDEQ so that work can be inspected. After installation, all
E&SC measures will be maintained in proper working order until the site is completely
stabilized.
3 Clemmons Area Upgrade Project
Sediment Removal Plan

The second phase involves removal of construction -related sediment from the off-site pond and
portions of Stream 19 on the adjacent property. In addition to NCDEQ approval, the measures
proposed in this plan will also require approval from the subject property owner. We understand
that NCDEQ will allow sediment removal activities associated with the pond to be deferred until
such time as property owner approval has been obtained.
Sediment removal activities in the pond will first consist of installation of a Type I turbidity curtain
across the upper portion of the pond. The proposed location of the turbidity curtain is depicted
on Figure 2, or as otherwise determined by environmental staff in the field. The purpose of the
turbidity curtain will be to isolate the area of greatest sediment concentration from deeper, less -
affected portions of the pond, and inhibit further siltation that might otherwise occur during
cleanup activities.
Environmental field crews overseen by Duke's Energy's environmental support staff will then
employ buckets, shovels, and wheelbarrows to manually remove discernible construction -
related sediment from Stream 19 and the off-site pond, including additional sediment that may
have migrated downstream or has mobilized during performance of upstream cleanup activities.
The sediment will be removed to a point where the original soil surface can be observed, and
care will be taken to avoid removal of native bed materials. Minor amounts of introduced
sediment can be left in place to better preserve existing, native bed and pond -bottom material,
based on conditions and the judgement of personnel conducting the work. Personnel will then
transport the removed material to a suitable high ground location well away from the stream and
its associated floodplain. The stockpiled sediment will then be stabilized in accordance with the
detail provided (staked natural fiber wattles, mulched and seeded). Areas of exposed soil that
may be temporarily disturbed during performance of the work will be re -stabilized with seed and
mulch as appropriate upon completion of the sediment removal activities. If erosion control
matting is placed on any portion of the streambanks, it will consist of natural biodegradable mats
made of natural fibers (free of plastic netting).
In the event it is determined that the underlying pond substrate may be too fluid to allow safe
removal of construction -related sediment by hand labor, Duke Energy may re-evaluate the plan
and determine if use of a vacuum truck or pump system is practicable. In such an event,
NCDEQ and the property owner will be notified of the revised method of sediment removal.
Following removal of construction -related sediment from the upper reaches of the pond,
disturbed areas will be seeded with the native wetland seed mix, while disturbed upland
areas/streambanks, and adjacent floodplain of Stream 19, will be seeded with a native riparian
seed mix and allowed to naturally revegetate. A copy of the native seed mixes is included in
Appendix II. Following final stabilization of the easement, the temporary check dams will be
removed.
Duke Energy anticipates that sediment removal activities identified herein will commence as
soon as practicable upon approval of this plan by NCDEQ and the affected landowner, and will
be carried out to completion in an expeditious manner, pending weather conditions. Upon
completion of the work, conditions within Stream 19 and the off-site pond will be re -documented,
and NCDEQ will be notified such that the site can be reviewed for compliance and results of the
sediment removal activities assessed at your discretion.
4 Clemmons Area Upgrade Project
Sediment Removal Plan

We hope that this Sediment Removal Plan adequately addresses the concerns expressed by
NCDEQ and the affected landowner. Please do not hesitate to contact to answer questions or
provide additional information.
Sincerely,
Tom Morris, PE
Senior Project Manager
Attachments: Figure 1 — Site Vicinity Map
Figure 2 — Sediment Removal Plan Exhibit
Appendix I — Temporary Check Dam and Sediment Stockpile Stabilization Details
Appendix II — Wetland and Riparian Seed Mixes
Cc: Chris Friel
Kitty Nappen
Cynthia Winston
Melanie Gardner
Joey Lawler, S&ME
Bryan Roden Reynolds, USACE
Clemmons Area Upgrade Project
Sediment Removal Plan

Figures

qr
TYPE 1 TURBIDITY CURTAIN
(LOCATION TO BE DETERMINED
IN FIELD BY ENVIRONMENTAL STAFF)
..... ......
o r ,
POTENTIAL SEDIMENT STOGI(PILES ♦♦
(LOCATION T Bf DET RMI ED
IN FIELD BY!E,, .. MENTAL STAFF) ♦_�
Sig
SEDIMENT REMOVAL AREAS
WATER BARS
= SILT FENCE
>-- STREAM CENTERLINE
0 OPEN WATERS
® WETLANDS
YY•YPIPE CENTERLINE
ACCESS ROADS
0
NEW PERMANENT EASEMENT
.01
TEMPORARY ACCESS EASEMENT`
TEMPORARY WORKSPACE e
ADDITIONAL TEMPORARY WORK SPACE ,,} Ae,'
1
d REFERENCE:
THIS MAP IS FOR INFORMATIONAL PURPOSES ONLY. ALL FEATURE LOCATIONS DISPLAYED 0 200 400
ARE APPROXIMATED. THEY ARE NOT BASED ON CIVIL SURVEY INFORMATION, UNLESS
STATED OTHERWISE. (FEET)
i
_ N. mum
►soft__ y
,.. m
zLu
z
+ - *-j � z
s ► Q Q
MAPLE=KNODR W w O
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Q w
Ln
O
A v �
•' � z
- SCALE:
CHECK DAMS
(LOCATION TO BE DETERMINED 1 " = 200 '
IN FIELD BY ENVIRONMENTAL STAFF) DATE:
��. 6-25-18
l PROJECT NUMBER
7435-17-015
� � FIGURE NO.
p,

Appendix I - Temporary Check Dam and Sediment Stockpile Stabilization Details

=0
TOP OF BANK
■
12 -INCH FILTREXX®
COMPOST FILTER SOCK
(OR ENGINEER APPROVED
EQUIVALENT) r
2" X 2" X 36" WOODEN
STAKES PLACED T O.C.
(USE ADDITIONAL
STAKES AS NECESSARY)
CHECK DAM NOTES:
1. USE 12 -INCH FILTREXX® COMPOST FILTER SOCK OR ENGINEER
APPROVED EQUIVALENT.
2. 2 -INCH BY 2 -INCH BY 3 -FOOT HARD WOODEN STAKES SHALL
BE INSTALLED THROUGH THE MIDDLE OF THE COMPOST
FILTER SOCK. SPACE STAKES EVERY 3 LINEAR FEET. DRIVE THE
STAKE TO A MINIMUM OF 1 -FOOT INTO THE GROUND
LEAVING A MINIMUM OF 3 -INCH PROTRUDING ABOVE THE
COMPOST FILTER SOCK.
3. TO PREVENT WATER & SEDIMENT FROM FLOWING AROUND
MEASURES COMPOST FILTER SOCK MUST BE PLACED UPSLOPE
AT A 30 DEGREE ANGLE FROM THE ENDS OF THE MEASURES.
4. COMPOST FILTER SOCK CHECK DAM SHOULD BE INSTALLED
PARALLEL TO THE BASE OF THE STREAM.
5. LOOSE COMPOST MAY BE BACKFILLED ALONG THE UPSLOPE
SIDE OF THE COMPOST FILTER SOCK CHECK DAM, FILLING THE
SEAM BETWEEN THE SOIL SURFACE AND SOCK, IMPROVING
FILTRATION AND SEDIMENT RETENTION.
EXCESS SOCK MATERIAL TO BE DRAWN IN
AND TIED OFF TO STAKE AT BOTH ENDS
FLOW
TOP OF BANK
CHECK DAM MAINTENANCE:
1. INSPECT CHECK DAM DAILY AND AFTER EACH RAINFALL
EVENT THAT EXCEEDS 0.5 INCHES WITHIN A 24 HOUR PERIOD.
2. REMOVE ANY CONSTRUCTION RELATED SEDIMENT VISIBLE
DURING INSPECTION.
3. MAKE ANY NECESSARY REPAIRS IMMEDIATELY.
4. IF PONDING BECOMES EXCESSIVE, THE SOCK MAY NEED TO BE
REPLACED WITH ONE OF A LARGER DIAMETER OR A DIFFERENT
MEASURE. THE SOCK NEEDS TO BE REINSTALLED IF
UNDERMINED OR DISLODGED.
S. DO NOT REMOVE COMPOST FILTER SOCK FROM THIS AREA
WITHOUT PRIOR AUTHORIZATION FROM NCDWR.
6. DISTURBED PORTION OF STREAM BED AND BANKS SHALL BE
RESTORED TO PRE -CONSTRUCTION CONDITIONS DURING
FINAL RESTORATION.
TYPICAL COMPOST FILTER SOCK CHECK DAM DETAIL
NOT TO SCALE
COMPOST FILTER SOCK CHECK DAM
TYPICAL DETAILS
CLEMMONS AREA UPGRADE
MOCKSVILLE, NORTH CAROLINA
FIGURE NO.
NTS
DATE: D
DATE
PROJECT NUMBER

2"X2"X36
WOODEN STAKE!
SOCK..
NOTES:
1. SOIL STOCKPILE AREA SHALL BE PLACED ON A UPLAND SITE
AWAY FROM STREAMS, WETLANDS, AND OTHER
ENVIRONMENTALLY SENSITIVE AREAS. PLACE BEHIND A
WATERBAR OR BERM FOR ADDITIONAL PROTECTION, IF
PLACED WITHIN EASEMENT.
2. STAKE COMPOST FILTER SOCKS IN PLACE WITH 2" X 2" X 36"
WOODEN STAKES.
3. INSTALL 18 -INCH COMPOST FILTER SOCKS OR APPROVED
EQUIVALENT AROUND STOCKPILE AREA ON ALL DOWN
GRADIENT SIDES TO RETAIN SOILS IN DESIGNATED AREA.
4. TEMPORARILY SEED STOCKPILES WITHIN 7 DAYS.
5. INSPECTIONS OF COMPOST FILTER SOCKS SHALL BE
CONDUCTED ONCE EVERY CALENDAR WEEK AND WITHIN
24 -HOURS AFTER EACH RAINFALL EVENT THAT PRODUCES
1/2 -INCH OR MORE OF PRECIPITATION.
6. REMOVE SEDIMENT ACCUMULATED BEHIND THE COMPOST
FILTER SOCKS AND DO NOT ALLOW HEIGHT OF SEDIMENT
BUILD-UP TO EXCEED SO% OF THE COMPOST FILTER SOCK.
7. MAKE ANY NECESSARY REPAIRS OR REPLACEMENTS
IMMEDIATELY.
TYPICAL SEDIMENT STOCKPILE STABILIZATION
NOT TO SCALE
SEDIMENT STOCKPILE STABILIZATION SCALE: FIGURE NO.
NTS
DATE: MMD 2
III TYPICAL DETAILS DATE
CLEONS AREA UPGRADE - LINE 328 PROJECT NUMBER
MOCKSVILLE, NORTH CAROLINA -7,,,C 17 01C

Appendix II — Wetland and Riparian Seed Mixes

Appendix II - Wetland and Riparian Seed Mixes
Wetland Area Seed Mix
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