20181393 Ver 1_DEQ_Response_to_Questions_20181109

ENERGY LAND & INFRASTRUCTURE
November 9, 2018
Ms. Sue Homewood
North Carolina Department of Environmental Quality, Division of Water Resources
Winston-Salem Regional Office
450 W. Hanes Mill Rd., Suite 300
Winston Salem, NC 27105
RE: RESUBMITTAL - PRE -CONSTRUCTION NOTIFICATION PACKAGE
DWR# 20181393
PIEDMONT NATURAL GAS, LINE 446 BELEWS CREEK GAS LINE PROJECT
GUILFORD, ROCKINGHAM, AND STOKES COUNTIES, NORTH CAROLINA
Dear Ms. Homewood:
Enclosed please find the revised stream drawings based on your November 5, 2018 email with
comments on the September 28, 2018 Pre -Construction Notification (PCN) package requesting a
401 Water Quality Certification and Buffer Authorization for the Line 446 Belews Creek Gas Line
Project in Guilford, Rockingham, and Stokes Counties, North Carolina. I have addressed your
questions and comments below.
1) 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.
2) Comment: For all streams that drain to the Jordan Lake Watershed please provide a
detailed buffer impact table which includes impact site identifiers, impact amounts for Zone
1 and Zone 2, whether the impact is a perpendicular crossing (between 75 and 105
degrees angle) or non -perpendicular impact, the area of the buffer impact, the proposed
permanent maintenance corridor width, whether mitigation is required and required
amounts (after applying the appropriate Zone multiplier and subtracting any wetlands within
the buffer). Please ensure that buffer impacts are accounted for in "line of sight" clearings
are included in the Buffer Impact table.
Response: The streams that drain to the Jordan Lake Watershed are: Stream 1, Stream
2/29, Stream 3, Stream 6, and Stream 7/8. The attached table provides the requested
information.
1420 Donelson Pike, Suite A-12, Nashville, Tennessee 37217 www.Eli-lic.com 615.383.6300
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3) Comment: The plans provided include insufficient call outs about the Jordan Lake Buffer
Rules. Please add Zone 1 and Zone 2 buffers to the plan sheets or separate sheets. They
should identify buffer impact areas with shading/hatching similar to that shown for wetland
locations and wetland impact areas. Please ensure that buffer impacts are shown in all "line
of sight" clearing areas as well as open cut areas. It will be helpful to show the buffer impact
areas using different colors or hatching for areas which will be permanently maintained
versus areas proposed for buffer re-establishment upon construction completion. Please
note that there may be some streams which are located adjacent to the proposed ROW but
which may have buffers which are within the ROW and these streams should be included
within the buffer impact table and shown on the plan sheets.
Response: The buffer drawings are attached.
4) Comment: In an effort to avoid and minimize impacts to streams and wetlands you have
avoided impacts within the temporary construction corridor in most locations of streams and
wetlands. However, it appears that you have not provided the same avoidance and
minimization measures to buffers. Please provide for avoidance and minimization of buffer
impacts along streams that are subject to the Jordan Lake Buffer Rules or provide
justification for why these areas cannot be avoided. Please show all buffers and temporary
limits of disturbance on plan sheets.
Response: The execution of the open cut stream crossing to install the pipe requires room
for stockpiling ditch spoils, temporary stream crossing pump arounds, filter bags, and
equipment movement in addition to the ditch line itself. As such, the full 60 -foot wide
permanent easement is needed to allow for adequate spacing to safely and properly install
a large pipeline such as this proposed 24 -inch diameter pipeline.
Please let me know if you have any questions or comments on the enclosed revisions. Again,
thank you for your consideration of this application. If you have questions or need additional
information please contact me at [phone] or by email at [e-mail].
Sincerely,
ENERGY LAND & INFRASTRUCTURE, PLLC
Suzan tkHerron, P.E., CPESC
PE 040556
Enclosures
cc: Ms. Alicia DePalma, Environmental Siting and Licensing, Piedmont Natural Gas
Mr. David Bailey, PWS, Regulatory Project Manager, U.S. Army Corps of Engineers (SAW -
2018 -00885)

Piedmont Natural Gas Line 446 Belews Creek Gas Line
Buffer Impacts Table
Zone 1 Mitigation Multiplier = 3
Zone 2 Mitigation Multiplier = 1.5
Wetland areas are removed from buffer impact areas.
Notes
Adjacent wetlands
Adjacent wetlands to east
Crossing by HDD
No adjacent wetlands
Adjacent wetlands
Impact Area:
Impact Area:
Total Buffer
Permanent
Sheet
Perpendicular or
Is Mitigation
Buffer Mitigation
Area
Stream
Permanent
Temporary
Impact Area:
Maintenance
Number
Non -Perpendicular
Required?
Zone 1 Zone 2
Zone 1 Zone 2
Permanent
Corridor Width
Zone 1
Zone 2
Stream 1
84
4986.6 3322.9
5324.8 5554.9
non
8309.5
60'
Yes
14959.8
4984.4
Stream 2/29
82
2791.9 1954.0
2560.9 1704.2
perp
4745.9
60'
Yes
8375.7
2931.0
Stream 3
81
NA NA
NA NA
perp
NA
30'
No
NA
NA
Stream 6
81
5018.5 3694.0
1089.6 806.3
perp
8712.5
60'
Yes
15055.5
5541.0
Stream 7/8
80
5386.3 5611.7
3159.8 2637.9
non
10998.0
60'
Yes
16158.9
8417.6
Zone 1 Mitigation Multiplier = 3
Zone 2 Mitigation Multiplier = 1.5
Wetland areas are removed from buffer impact areas.
Notes
Adjacent wetlands
Adjacent wetlands to east
Crossing by HDD
No adjacent wetlands
Adjacent wetlands

GRAPHIC SCALE (IN FEET)
100 0 50 100 200
1 inch= 100 ft.
LEGEND: STREAM BUFFERS
.............
LINE 446 BELEWS CREEK PIPELINE
STREAM BUFFER MAP
DATE 11/19/18SEE TABLE FOR BUFFER AREAS
WETLAND AREAS EXCLUDED
SHEET 4 OF 4 CORRESPONDS TO SHEET 84
STREAM 1
(PERENNIAL)
OPEN -CUT FOR GAS
LINE, DEWATERING
STRUCTURE,
EQUIPMENT
CROSSING/MAT
PLACEMENT
IMPACT SITE 19:
STREAM 1
WETLAND 1A
WETLAND WXA
WETLAND WXB
r
I -
EXISTING
CULVERT
WETLAND 2
NO IMPACT
Piedmont PREPARED BY
ENERGY LAND & INFRASTRUCTURE, PLLC
Natural Gas
1015 PASSPORT WAY- NORTH CAROLINA # P-1
919-234-1974 WWW.ELI-LLC.COM•LICENSE # P-1289
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STREAM BUFFERS TO
BE PROVIDED PER
JORDON LAKE
BUFFER RULE (SEE
DETAIL 9, SHEET 87
40' TEMP
EASEMENT
SFCD
141
SFJ
STREAM 2/29
(INTERMITTENT)
OPEN CUT FOR GAS
LINE, DEWATERING
STRUCTURE,
EQUIPMENT
CROSSING/MAT
PLACEMENT
LINE 446 BELEWS CREEK PIPELINE
STREAM BUFFER MAP
DATE 11/19/18 SEE TABLE FOR BUFFER AREAS
WETLAND AREAS EXCLUDED
SHEET 3 OF 4 CORRESPONDS TO SHEET 82
LEGEND: STREAM BUFFERS
ZONE 1: PERM. IMPACT
ZONE 2: PERM. IMPACT
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GRAPHIC SCALE (IN FEET)
100 0 50 100 200
1 inch = 100 ft.
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IMPACT SITE 18:
STREAM 2/29
WETLAND 5A FLOW
WETLAND 5B
WETLAND 5A PERMANENT
EASEMENT TEMPORARY
IMPACT: OPEN CUT FOR GAS
LINE, DEWATERING
EXISTING STRUCTURE, EQUIPMENT
CULVERT CROSSING/MAT PLACEMENT.
WETLAND 5B PER
Piedmont
PREPARED BY
ENERGY LAND b INFRASTRUCTURE, PLLC
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Natural
Gas
1 3 PASSPORT WAY- NORTH CAROLINA # P-1
919-234-1974 WWW.ELI-LLC.COM•LICENSE # P-1289
ENGINEERS • SURVEYORS • INFRASTRUCTURE • ENVIRONMENTAL

LEGEND: STREAM BUFFERS
ZONE 1: PERM. IMPACT
ZONE 2: PERM. IMPACT
6� ZONE 1: TEMP. IMPACT
ZONE 2: TEMP. IMPACT
65' TEMP
EASEMENT
SIFSIFc SF SFF
SF
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GRAPHIC
00 0 50 100 200
1
40' TEMP
EASEMENT
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STREAM BUFFERS TO BE
IMPACT SITE 16: PROVIDED PER JORDON
STREAM 6 LAKE BUFFER RULE (SEE D
DETAIL 9, SHEET 87
LINE 446 BELEWS CREEK PIPELINE
STREAM BUFFER MAP Piedmont PREPARED BY:
SEE TABLE FOR BUFFER AREAS ENERGY LAND & INFRASTRUCTURE, PLLC
DATE 11/19/18 Natural Gas 1015 PASSPORT WAY- NORTH CAROLINA # P-1
WETLAND AREAS EXCLUDED 919-234-1974 WWW.ELI-LIC.COM•LICENSE # P-1289
SHEET 2 OF 4 CORRESPONDS TO SHEET 81 ENGINEERS •SURVEYORS •INFRASTRUCTURE •ENVIRONMENTAL

IMPACT SITE 15:
STREAM 7/8
WETLAND9A
WETLAND 9B
WETLAND 10/11
WETLAND 12A
WETLAND 12B
WETLAND WY
I GRAPHIC SCALE\(IN FEET)
100 0 50 100
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LEGEND: STREAM BUFFERS
ZONE 1: PERM. IMPACT
ZONE 2: PERM. IMPACT
ZONE 1: TEMP. IMPACT
ZONE 2: TEMP. IMPACT
SF
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WETLAND 8/13
N O 1 M PACT
STREAM 7/8
OPEN CUT FOR GAS LINE,
DEWATERING STRUCTURE,
EQUIPMENT CROSSING/MAT
PLACEMENT. STREAM
BUFFERS TO BE PROVIDED
PER JORDON LAKE BUFFER
RULE (SEE DETAIL 91
SHEET 87
LINE 446 BELEWS CREEK PIPELINE
STREAM BUFFER MAP Piedmont PREPARED BY:
SEE TABLE FOR BUFFER AREAS ENERGY LAND & INFRASTRUCTURE, PLLC
DATE 11/09/18 Natural Gas 1015 PASSPORT WAY- NORTH CAROLINA # P-1
WETLAND AREAS EXCLUDED 919-234-1974 WWW.ELI-LIC.COM•LICENSE # P-1289
SHEET 1 OF 4 CORRESPONDS TO SHEET 80 ENGINEERS •SURVEYORS •INFRASTRUCTURE •ENVIRONMENTAL