20181393 Ver 1_More Info Requested_20181126

Strickland, Bev
From: Homewood, Sue
Sent: Monday, November 26, 2018 4:26 PM
To: '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
Suzanne,
Thank you for your very detailed response and extremely clear buffer impact drawings. Unfortunately my letter wasn't
clear about what to do when there are wetlands within the buffer areas. I apologize for that, buffer rules can be difficult
to explain and I should have taken more time to make sure I was clear enough.
When wetlands overlap buffer areas, we still consider the area to be subject to the buffer rules and we still need to
account for the impact. So we still need them calculated as part of the buffer impact area (whether temporary or
permanent) in your table, and to show as shaded on the drawings. But before you apply the mitigation ratios (when
required) you would subtract the wetlands out of the total impact area. So you'll need to revise your buffer impact
table and drawings (for some areas with wetlands present)
What works for most projects is to add 2 more columns to your table:
Wetlands within buffer area (Zone 1 and Zone 2 should be in separate columns)
Buffer mitigation area required (this should be total buffer impact area minus the wetlands within that buffer area).
The multiplier (3 or 1.5) should be applied to this column the buffer mitigation area required.
We will also need an acceptance letter from a private buffer mitigation bank (information about banks can be found
here) if there is one with credits available and if not then you can submit an acceptance letter from DMS for buffer
mitigation.
Again, I apologize that this was not clear from my earlier correspondence. If you have any questions or comments about
it please feel free to contact me at your convenience.
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 9, 2018 4:28 PM
To: Homewood, Sue <[e-mail]>; David. [e-mail]
Cc: 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 @duke-energy.com>; Lemons, Elizabeth Pressley ([e-mail])
<[e-mail]>; Keith Gualtieri <[e-mail]>
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:sue.homewoodCa)ncdenr.Qov]
Sent: Monday, November 05, 2018 4:34 PM
To: Suzanne Herron; David. E. Bailey2ausace.army.mil
Cc: Roden Reynolds, Bryan K CIV (US); Alicia DePalma - Piedmont Natural Gas (alicia.depalma(a)duke-energy.com);
Dietrich, Ned (Ned.Dietrich (d)duke-energy.com); Lemons, Elizabeth Pressley (Elizabeth. Lemons(a)duke-energy.com); 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-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 @duke-
energy.com>; Lemons, Elizabeth Pressley (Elizabeth. [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.BaileyNausace.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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