20181393 Ver 1_USACE Request for Additional Information_20181105

Strickland, Bev
From: Bailey, David E CIV USARMY CESAW (US) < [e-mail] >
Sent: Monday, November 05, 2018 1:21 PM
To: Suzanne Herron
Cc: Homewood, Sue; Roden Reynolds, Bryan K CIV (US); Alicia DePalma - Piedmont
Natural Gas ([e-mail]); Dietrich, Ned (Ned.Dietrich@duke-
energy.com); Lemons, Elizabeth Pressley (Eliza [e-mail]); Keith
Gualtieri; Cahoon, Steve
Subject: [External] RE: Request for Additional Information: PNG Line 446, Belews Creek Gas
Line; Guilford, Rockingham, and Stokes Cos.; SAW -2018-00885
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an
attachment to Report Spam.<mailto:[e-mail]>
Hi Suzanne, and thank you for your response to our request for additional information. I have not reviewed all of the
information you submitted, however I want to give plenty of time for PNG/Duke Energy to provide the information I
requested in item #1 below. It is my understanding that Line 446 (Belews Creek Gas Line Project) would not have
independent utility separate from natural gas-fired turbine infrastructure planned at the Belews Creek Steam Station;
that is, PNG would not build Line 446 but for the natural gas-fired turbines planned for the site. As such, we require
information that shows all infrastructure required to operate natural gas-fired turbines planned for the site. This should
include grading plans for the natural gas-fired turbines as well as any pipelines connecting the new Metering and
Regulating (M&R) Station on the Belews Creek Steam Plant property with the natural gas-fired turbines. Any potentially
jurisdictional streams, wetlands, and open waters should be shown on the plans to determine any potential impacts.
My primary contact for Duke Energy on the power generation side is Steve Cahoon (cc'd on this email); I suggest that
PNG coordinate with him to provide this information. Otherwise, please provide a more detailed description of the
independent utility of Line 446.
In the coming days I will have a chance to review the updated plans you sent. At that time I will request any additional
information necessary to process the PCN if needed. Thanks, and please let me know if you have any questions.
-Dave Bailey
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE -SAW -RG -R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Phone: [phone], Ext. 30.
Fax: [phone]
Email: David. [e-mail]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: http://corpsmapu.usace.army.mil/cm_apex/f?p=136:4:0
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-----Original Message -----
From: Suzanne Herron [mailto:[e-mail]]
Sent: Friday, November 2, 2018 3:50 PM
To: Bailey, David E CIV USARMY CESAW (US)<[e-mail]>
Cc: Homewood, Sue <[e-mail]>; Roden Reynolds, Bryan K CIV (US)
<Bryan.K.Roden [e-mail]>; Alicia DePalma - Piedmont Natural Gas ([e-mail])
<[e-mail]>; Dietrich, Ned (Ned. Dietrich @duke-energy.com) <Ned.Dietrich @du ke-
energy.com>; Lemons, Elizabeth Pressley ([e-mail]) <Elizabeth.Lemons@duke-
energy.com>; Keith Gualtieri <[e-mail]>; Suzanne Herron <[e-mail]>
Subject: [Non-DoD Source] RE: Request for Additional Information: PNG Line 446, Belews Creek Gas Line; Guilford,
Rockingham, and Stokes Cos.; SAW -2018-00885
David -
We have addressed the comments below. Please see the revised plans and letter that are attached. Please let us know
of other questions.
Thanks!
Suzanne
Suzanne Herron, PE, CPESC
Environmental Practice Lead
Energy Land & Infrastructure, LLC (PLLC in NC)
1420 Donelson Pike, Suite A-12
Nashville, TN 37217
[phone] Office
[phone] Cell
Suzanne. [e-mail] <mailto:[e-mail]>
From: Bailey, David E CIV USARMY CESAW (US) [mai Ito: David. [e-mail]]
Sent: Monday, October 15, 2018 3:31 PM
To: Suzanne Herron; Dietrich, Ned

Cc: Homewood, Sue; Roden Reynolds, Bryan K CIV (US); Alicia DePalma - Piedmont Natural Gas (alicia.depalma@duke-
energy.com)
Subject: Request for Additional Information: PNG Line 446, Belews Creek Gas Line; Guilford, Rockingham, and Stokes
Cos.; SAW -2018-00885
0
Thank you for your PCN and attached information, dated 9/28/2018 (received 10/2/2018), for the above referenced
project. I have reviewed the information and need clarification before proceeding with verifying the use of Nationwide
Permit 12 (Blockedhttp://www.saw.usace.army.miI/Portals/59/docs/regulatory/regdocs/NWP2012/NWP12_3-23.pdf).
Please submit the requested information below (via e-mail is fine) within 30 days of receipt of this Notification,
otherwise we may deny verification of the use of the Nationwide Permit or consider your application withdrawn and
close the file:
1) This project is considered single and complete with the natural gas-fired turbine to be located on the Duke Energy
Belews Creek station property. Please provide a plan sheet that shows the footprint of the proposed natural gas-fired
turbine infrastructure, including any proposed impacts to wetlands, streams, or other potential waters of the U.S related
to these facilities;
2) Provide a plan including any pertinent detail sections for typical stream impacts via trenching. Such plans should
including dewatering methods, lengths of time that trenches will be open in streams, and a specific stream restoration
plan (per Per Regional Condition 4.1.14) including how grade and contour will be re-established, stabilization methods,
and seeding/planting lists and specifications. Such details should be provided as an addendum that can be referenced in
permit Special Conditions;
3) Provide a plan including any pertinent detail sections for typical wetland impacts via trenching. Such plans should
including dewatering methods, lengths of time that trenches will be open in wetlands, and confirmation that the top 6
to 12 inches of the trench will be backfilled with topsoil from the trench. Per Regional Condition 4.1.9, provide a specific
wetland restoration plan including how grade and contour will be re-established, anti -compaction measures in soils
subject to construction traffic and matting, stabilization methods, and seeding/planting lists and specifications. Be sure
to specify wetland restoration differences in temporary and permanent easement areas. Such details should be provided
as an addendum that can be referenced in permit Special Conditions;
4) Will the stream crossings include discharging rip rap? If so, please confirm that any rip rap placed below the
ordinary high water mark will be placed such that the top of the rip rap will be no higher than the existing stream bed
elevation (see Regional Permit Condition 4.1.11).
5) Please group the various proposed aquatic resource crossings into "Impact Sites" on the plan sheets and reference
them on the impact tables. The Impact Site grouping should be clearly labeled the following on the plan sheets, and also
add a column with the corresponding Impact Site # on the impact sheets:
a. Impact Site 1: Wetland Impacts 26 A&B;
Impact Site 2: Belews Lake;
Impact Site 3: Stream 26;

d. Impact Site 4: Stream 21;
e. Impact Site 5: Wetland 27 A&B;
f. Impact Site 6: Stream 25;
g. Impact Site 7: Stream 20/35;
h. Impact Site 8: Stream 19;
i. Impact Site 9: Wetland 19, Pond 4, Wetland WV, Stream 16, Stream 17, Wetland 20A;
j. Impact Site 10: Stream 12;
k. Impact Site 11: Stream 13;
I. Impact Site 12: Stream 14;
m. Impact Site 13: Stream 33;
n. Impact Site 14: Stream 34 and Stream 32;
o. Impact Site 15: Stream 7/8, Wetland 9 A&B, Wetland 10&11, and Wetland 12 A&B;
p. Impact Site 16: Stream 6;
q. Impact Site17: Streams 3, 4, and 5, Wetland 6/7;
r. Impact Site 18: Stream 2/29, Wetland 5 A&B;
S. Impact Site 19: Stream 1, Wetland 1 A&B;
6) On the plan sheets, I suggest using a color other than blue to show culverts, as this is very similar to the color of the
stream lines themselves. This change would increase the clarity of the plan sheets;
7) Resource -specific comments from plan sheets:
a. Stream 1: Stream impacts are shown via shading even outside of the permanent easement. Can impacts be limited
to the permanent easement footprint?
b. Stream 7/8: can the LOD be kept from crossing Stream 7/8 near 375+00?
C. Stream 13: a stream impact is listed, but the appropriate shading is missing from the plan sheet;
d. Stream 17: this feature is within the LOD, but no impact is shown. Can LOD be moved to the east of Stream 17?
e. Stream 21: This feature is shaded as an impact, but the plans have a note that the stream will be avoided via jack
and bore. Can the shading be removed?
f. Stream 32: If pipeline will be jack and bored under NC Hwy 68, couldn't Stream 32 be avoided by extending the
jack and bore?
4

g. Stream 33: Stream impacts are shown via shading even outside of the permanent easement. Can impacts be
limited to the permanent easement footprint?
h. Wetland 3: the plan sheet shows a silt fence line running through this wetland, but the note shows no impact. It
appears that the silt fence line should be drawn inside the LOD and outside of this wetland;
i. Wetland 27: The impact table lists both temporary and permanent impacts, and adds these 2 numbers for the
permanent conversion column. However, the plan sheet only shows impacts in the permanent easement. Please
reconcile these differences;
8) Update your compensatory mitigation plan by specifying a mitigation to impact ratio (1:1 is typical for permanent
wetland conversion impacts) proposal;
9) Does PNG plan to use 3rd party inspectors to ensure permit compliance during construction?
10) For avoidance and minimization during construction, does PNG typically clearly sign the boundaries of wetlands,
streams and other waters for contractor clarity?
Sincerely,
Dave Bailey
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE -SAW -RG -R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Phone: [phone], Ext. 30.
Fax: [phone]
Email: David. [e-mail]
5

We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: Blockedhttp://corpsmapu.usace.army.miI/cm_apex/f?p=136:4:0
Thank you for taking the time to visit this site and complete the survey.