20181393 Ver 1_More Information Received_20181119

Strickland, Bev
From: Suzanne Herron <[e-mail]>
Sent: Monday, November 19, 2018 3:29 PM
To: Homewood, Sue; [e-mail]
Cc: 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;
Suzanne Herron
Subject: RE: [External] RE: Request for Additional Information: PNG Line 446, Belews Creek Gas
Line; Guilford, Rockingham, and Stokes Cos.; SAW -2018-00885
David —
During our discussion on Friday, you requested additional information on why Duke Energy would not allow Piedmont to
use the ROW adjacent to the existing Duke overhead line ROW for temporary workspace. Below is the original comment
and response. Below that is the additional response.
Comment: The application indicated that by citing the new Right of Way (ROW) adjacent to an existing Duke overhead
line ROW the applicant has provided for Avoidance and Minimization. Please explain why the existing overhead line
ROW cannot be utilized as a temporary construction corridor to further avoid and minimize impacts to streams,
wetlands, and buffers.
Response: In the early stages of project design, it was proposed to Duke Energy that this project could use the overhead
electric line ROW as temporary workspace to provide additional avoidance and minimization to environmental impacts.
Unfortunately, Duke Energy denied the use of the existing electric ROW for parallel temporary workspace for
construction of this project. However, as a minimization measure, there are existing electric line ROW access roads that
are planned to be utilized.
Additional Response: Duke Energy's policies regarding the use of their electric transmission line right of way are based
upon preventing injuries, providing reliable power to their customers and protecting their assets from damage. To
prevent injuries, Duke Energy minimizes allowable uses of their right of way. Using the approximately 40' of right of way
for temporary work space would place construction personnel and equipment in very close proximity to the buffer zone
required to protect against alternating current voltages on the order of 250,000 volts. The risk to personnel would be
increased substantially. In addition to personnel injuries, these restrictions reduce the probability of contact between
construction equipment and the transmission lines that could result in the loss of power to industrial and residential
customers. This contact could also damage the transmission lines or related infrastructure. Repairing this damage
would involve bringing vehicles onto right of way areas that currently see minimal use, and would disturb the current
ground cover.
Altering the elevation inside right of way is generally banned, as this changes the offset distance between the electric
lines and the earth. Inadequate offset distance results in increased probability of arcing. Therefore spoil piles are
prohibited. The foundations for the towers are susceptible to being damaged by nearby excavation activities, therefore
no construction activities are allowed within 25' of any structure. This would reduce the allowable area for temporary
work space in the vicinity of towers to less than the 40 feet that is required for safe construction. No opportunity would
exist to obtain additional temporary work space when required for topsoil management on the Duke side of the
construction space, which would result in the need to have temporary work space on the other side of the construction

space, defeating the purpose of using the electric right of way (this additional temporary work space would probably
have to be wider than 25' in order to provide for vehicle travel).
Please let me know if you have additional questions or comments.
Suzanne
Suzanne Herron, PE, CPESC
Environmental Practice Lead
Energy Land & Infrastructure, LLC (PLLC in NQ
1420 Donelson Pike, Suite A-12
Nashville, TN 37217
[phone] Office
[phone] Cell
Suzanne. [e-mail]
From: Suzanne Herron
Sent: Friday, November 09, 2018 3:28 PM
To: 'Homewood, Sue'; [e-mail]
Cc: Roden Reynolds, Bryan K CIV (US); Alicia DePalma - Piedmont Natural Gas ([e-mail]);
Dietrich, Ned (Ned.Dietrich @duke-energy.com); Lemons, Elizabeth Pressley ([e-mail]); Keith
Gualtieri
Subject: RE: [External] RE: Request for Additional Information: PNG Line 446, Belews Creek Gas Line; Guilford,
Rockingham, and Stokes Cos.; SAW -2018-00885
Sue —
Attached is the response to the request for additional information. Please let me know if you have additional questions.
Suzanne
Suzanne Herron, PE, CPESC
Environmental Practice Lead
Energy Land & Infrastructure, LLC (PLLC in NQ
1420 Donelson Pike, Suite A-12
Nashville, TN 37217
[phone] Office
[phone] Cell
Suzanne. Herron(@eli-Ilc.com
From: Homewood, Sue [mailto:[e-mail]]
Sent: Monday, November 05, 2018 4:34 PM
To: Suzanne Herron; [e-mail]
Cc: Roden Reynolds, Bryan K CIV (US); Alicia DePalma - Piedmont Natural Gas ([e-mail]);
Dietrich, Ned (Ned.Dietrich @duke-energy.com); Lemons, Elizabeth Pressley ([e-mail]); Keith
Gualtieri
Subject: RE: [External] RE: Request for Additional Information: PNG Line 446, Belews Creek Gas Line; Guilford,
Rockingham, and Stokes Cos.; SAW -2018-00885
Please see the attached request for more information.
Thanks,

Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
Sue. [e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Suzanne Herron <[e-mail]>
Sent: Friday, November 2, 2018 3:50 PM
To: David. E. [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: [External] 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 NQ
1420 Donelson Pike, Suite A-12
Nashville, TN 37217
[phone] Office
[phone] Cell
Suzanne. [e-mail]
From: Bailey, David E CIV USARMY CESAW (US) [mai Ito: David. E.Bailey2(a)usace.army.mi1]
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.depalmaCa)duke-
energy.com)
Subject: Request for Additional Information: PNG Line 446, Belews Creek Gas Line; Guilford, Rockingham, and Stokes
Cos.; SAW -2018-00885
No
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 (http://www.saw.usace.army.mil/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;
b. Impact Site 2: Belews Lake;
c. 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?
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?
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?
Stream 33: Stream impacts are shown via shading even outside of the permanent easement. Can
impacts be limited to the permanent easement footprint?
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;
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]
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