Sabal Trail Georgia Section 401 Water Quality Permit

Received today from GA-EPD, although they issued it three weeks ago. Sabal-Trail-WQC-SAS16-Signed-Copy-0001 2013.0000000, 6.0000000 Basically, they believed Sabal Trail, with a few requirements, and issued the permit.

GA-EPD sent three documents, which are inline below with links to the PDF copies that were attached:


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Memo (PDF)

Georgia Department of Natural Resources
Environmental Protection Division
2 Martin Luther King Jr. Dr., Suite 1152 Atlanta, Georgia 30334
Richard E Dunn, Director
(404) 65574713

June 13, 2016


TO: Richard E. Dunn

THROUGH: James A. Capp [initialed]
Bennett Weinstein [initialed]

FROM: Stephen Wiedl [initialed]

SUBJECT: 401 Water Quality Certification
Joint Public Notice SAS-2013-00942
Sabal Trail Pipeline Project
Chattahoochee, Flint, Ochlockonee
and Suwanee River Basin
Stewart, Webster, Terrell, Lee, Dougherty
Mitchell, Colquitt, Brooks 8. Lowndes Counties

Sabal Trail Transmission, LLC is seeking a Section 401 Water Quality Certification for impacts to waters of the US. associated with the construction of a 36-inch diameter natural gas transmission pipeline, which will be approximately 162 miles long and pass through nine southwest Georgia counties. This project connects to associated pipeline projects in adjacent states of Alabama and Florida. Almost all of the pipeline will be installed by “open trench construction method” wherein an approximately seven foot deep trench depth, combined with 36-inch pipeline size, will yield a minimum of three feet of finished backfill cover as required by US. Department of Transportation regulations, Deeper burial may occur in certain areas such as agricultural land, roads, railroads, or under water bodies. Installation of the pipeline will occur in limited instances by means of the horizontal directional drilling (HDD) construction technique. The HDD crossings will occur at four locations in Georgia including the Chattahoochee, Flint, Ochlockonee and Withlacoochee Rivers.

In Georgia, the pipeline project will cross a total of 126 water bodies: 47 perennial streams or rivers, 47 intermittent streams, 25 ephemeral drainageways (which are not regularly considered jurisdictional stream features by the Corps of Engineers, but which are designated for project inclusion for purposes of Federal Energy Regulatory Commission (FERC) project administration), and 7 palustrine open water features (ponds/lakes). Of these 126 waterbody crossings, 83 are identified as “minor” at less than 10 feet wide, 36 are “intermediate” at 10-to-100 foot width, and 7 are “major” crossings greater than 100 feet in size. There will be no permanent wetland impacts by fill placement in Georgia. A total of 122.75 acres of various wetland types will be disturbed by the project’s construction workspaces, including 10.31 acres of emergent wetlands, 6.83 acres of scrub-shrub habitat, and 105.61 acres of forested wetlands. Of this, a total of 41.46 acres of permanent wetland impacts by conversion from forested wetland type to emergent or scrub»shrub wetlands will occur in the state. Another 81.29 acres of wetlands will experience temporary impacts wherein original vegetation conditions will eventually become reestablished by natural regrowth following construction events.

The project applicant has prepared extensive environmental assessment documentation and has undertaken substantial coordination with federal agencies including FERC, the US. Army Corps of Engineers (USACE) and the Environmental Protection Agency (EPA). It is evident that the applicant has made substantial efforts to avoid and minimize wetland and stream impacts. Such efforts include: overall upland-focused route selection, employing generally perpendicular crossings through wetlands, crossings made at narrow portions of unavoidable wetlands, avoidance of longitudinal pipeline routings through riparian corridors and wetland bottomlands, colocation of the pipeline along paths of existing infrastructure such as utility lines, pipelines, and roadways, single-pass construction approach at streams and wetlands, and use of mostly “dry” crossings of streams wherein coffer dams, flumes and pump-around techniques are employed to maintain near normal stream flows during trench excavation and installation of pipeline. Most individual construction events will be relatively brief term comprising a few days at any particular location.

An associated water withdrawal letter of permission is being prepared by EPD’s Surface Water Unit which will temporarily authorize use of water for aforementioned HDD borings and for hydrostatic pressure testing of sections of welded and completed pipeline. Following alignment adjustments and coordination with EPD’s Erosion & Sedimentation Control Unit it has been determined that this project is exempt from stream buffer variance requirements. This certification has been produced following internal coordination with other sections within EPD including the Erosion & Sedimentation Control Unit, the Surface Water Unit, the Watershed Planning & Monitoring Program and the State Geologist.

The applicant will offset the project’s wetland impacts through the purchase of a total of 581.05 freshwater wetland mitigation credits obtained from four different Corps of Engineers approved mitigation banks within Primary Service Areas, or within Secondary Service Areas as allowed by the Corps of Engineers for watersheds lacking any available banks with relevant Primary Service Areas. The applicant has, to date. purchased all of the required wetland mitigation credits.

Memo per Public Comments (PDF)

Georgia Department of Natural Resources
Environmental Protection Division
2 Martin Luther King Jr. Dr., Suite 1152 Atlanta, Georgia 30334
Richard E Dunn, Director
(404) 65574713

June 13, 2016


TO: Richard E. Dunn

THROUGH: James A. Capp [initialed]

FROM: Bennett Weinstein [initialed]

SUBJECT: Public Comments
401 Water Quality Certification — Sabal Trail Pipeline Project

As discussed in the accompanying memo, Watershed Branch staff has completed the review of the Sabal Trail Pipeline Project application package, including all comments received.

As noted on the routing form, this project was subject to an Army Corps of Engineers (Corps) Joint Public Notice (JPN) When comments are received under a JPN, the Corps takes the lead and requests that the applicant prepare responses.

The small handful of comments that were addressed specifically to Georgia’s 401 process were either so general as to not be actionable or they were used as the basis for further inquiry with the applicant and subsequently informed specific conditions. The remainder of the vast majority of the comments were addressed to and responded . by Florida and the Federal Energy Regulatory Commission The issues raised in the various comments have been satisfactorily addressed.

Water Quality Certification (PDF)

Georgia Department of Natural Resources
Environmental Protection Division
2 Martin Luther King Jr. Dr., Suite 1152 Atlanta, Georgia 30334
Richard E Dunn, Director
(404) 65574713

June 28, 2016

Mr. George McLachlan
Sabal Trail Transmission, LLC
400 Colonial Center Parkway, Suite 300
Lake Mary, FL 32746

Re: Water Quality Certification
Joint Public Notice SAS-2013-00942
Sabal Trail Pipeline Project
Chattahoochee, Flint, Ochlockonee
and Suwanee River Basins
Stewart, Webster, Terrell, Lee, Dougherty
Mitchell, Colquitt, Brooks & Lowndes Counties

Dear Mr. McLachlan:

Pursuant to Section 401 of the Federal Clean Water Act, the State of Georgia issues this certification to Sabal Trail Transmission, LLC, an applicant for a federal permit or license to conduct an activity in, on or adjacent to the waters of the State of Georgia.

The State of Georgia certifies that there is no applicable provision of Section 301; no limitation under Section 302; no standard under Section 306; and no standard under Section 307, for the applicant’s activity. The State of Georgia certifies that the applicant’s activity will comply with all applicable provisions of Section 303,

This certification is contingent upon the following conditions:

  1. All work performed during construction will be done in a manner so as not to violate applicable water quality standards
  2. No oils, grease, materials or other pollutants will be discharged from the construction activities which reach public waters.
  3. The applicant must comply with the terms of the NPDES General Permit for Infrastructure Construction Projects (GAR100002).
  4. The following conditions apply if the Georgia Environmental Protection Division (Georgia EPD) issues a letter of concurrence for transient uses of surface water from the Chattahoochee and Withlacoochee Rivers associated with horizontal directional drilling (HDD) and hydrostatic pipeline integrity testing.
    1. Pumpage rates, whether from a single or multiple withdrawal points on either the Chattahoochee or Withloacoochee Rivers, must not exceed 1,500 gallons per minute (gpm).
    2. The operational pumpage rate from the Chattahoochee River of 1,500 gpm is less than 1 percent of the historical low flow records for any given month at the Chattahoochee River.
    3. To ensure sufficient river flow will be maintained at all times in the Withlacoochee River, the applicant will monitor the daily flow records at USGS Stream Gage 02318500 (Withlacoochee River at U.S. 84 near Quitman, GA). If the flows in the Withlacoochee River, as measured at the USGS gage, are 8,000 gpm or less, the applicant will postpone water withdrawals.
  5. Only benign, non-contaminating drilling additives rated as suitable for potable water well use will be used during HDD processes.
  6. The applicant plans to maintain daily, weekly, monthly and non-compliance reports on-site and submit them annually to the EPD Non-point Source Program, as cited in Section 2.1, Items 13 and 20 of the Sabal Trail Erosion and Sedimentation Control Plan (E&SCP) dated May 22, 2016. in addition, the applicant shall immediately notify Georgia EPD about any events that are reasonably expected to result in an exceedance of instream water quality standards during construction. Such notice will be made to:

    Georgia EPD Southwest District Office
    Albany, GA
    Attn: Tom Fowler
    Phone: 229-430-4144

  7. For all “minor waterbody” stream crossings (less than 10 feet wide) and for all “intermediate waterbody” stream crossings less than 30 feet wide, regardless of their State vs. Non-State Designated status (as cited on pages 5-4 and 5-5 of the Sabal Trail E&SCP, revised May 22, 2016), “dry” flumed or dam and pump crossing methods will be used. Any exception to this stipulation (i.e. using a “wet” stream crossing due to localized stream channel/drainageway conditions which would not allow for the successful application of “dry“ crossing methods) will occur only with the documented approval of the Sabal Trail Environmental lnspector and the FERC 3rd Party Compliance Monitor.
  8. The applicant plans to utilize temporary equipment bridges to cross streams. In order to minimize placement of crushed stone fill into stream beds, it is preferred that the applicant utilize equipment mats/pads and culverts (Figure #38 of E&SCP), Flexi-float or portable bridges (Figure #40 of E&SCP), free span equipment pads or railroad car bridges without culverts, as opposed to crushed stone and culverts (Figure #39 of E&SCP). Use of the crushed stone and culvert method for temporary bridging at specific stream crossings will occur only with the documented approval of the Sabal Trail Environmental Inspector and the FERC 3rd Party Compliance Monitor. Any crushed stone used in such allowed situations will be clean without excessive fine materials which would lead to erosion and sedimentation compromise to stream beds.
  9. The applicant may not use synthetic monofilament mesh/netted erosion control materials.
  10. Passage of construction equipment through wetlands or across streams/waterbodies for mainline clearing, trenching, pipe laying and backfilling must occur as a one-time event. This one-time event would be either over and back once or would occur as a single crossing with equipment proceeding down the project alignment without a return crossing. Any other passage of equipment across a stream/waterbody along the pipeline corridor must occur along temporary equipment bridges. General equipment or construction access roads will not be routed through wetlands; passage through wetlands will only occur as a one-time event for trenching and pipe laying. Temporary bridges are to be removed as soon as possible following pipeline construction, and shall not remain in place post-construction.
  11. In addition to the NPDES general stormwater permit requirements for turbidity sampling, the Sabal Trail Environmental Inspector shall also conduct visual inspections during stream crossing activities. Any observation of a substantial visual contrast between the appearance of the stream immediately upstream of the activities and the appearance of the stream downstream from the activities must be addressed immediately through proper erosion and sedimentation control practices and consultation with the Environmental inspector.
  12. The applicant will comply with the measures and protocols outlined in the Karst Mitigation Plan, Appendix F of the Final EIS for the Sabal Trail project.
  13. The applicant must notify the Wetlands Unit of any modifications to the proposed activity. Where modifications are identified through an NOI modification, the applicant will provide a copy of the NOI modification to the Wetlands Unit, Attn: Stephen Wiedl by email (,gov) or by mail to Georgia EPD, Watershed Protection Branch, Wetlands Unit, 7 Martin Luther King, Jr. Drive, Suite 450, Atlanta, GA 30334).

This certification does not relieve the applicant of any obligation or responsibility for complying with the provisions of any other laws or regulations of other federal, state or local authorities.

It is your responsibility to submit this certification to the appropriate federal agency.

Richard E. Dunn

cc: Mr. Brad Floyd, TRC
Mr, Terry Kobs. USACE
Mr. Eric Somerville, USEPA
Ms. Sandy Abbott, USFWS

One thought on “Sabal Trail Georgia Section 401 Water Quality Permit

  1. Harriet Heywood

    Once again, global investors takes precedence over our precious water resources, with rubber-stamp agencies enabling destruction of life for private profit.
    The organizations given the authority to protect are simply the gateway to BIG OIL and GAS, where eminent domain has nothing to do the public good, and where those who represent us are paid to fast-track their approval.
    Florida has 5 LNG fracked gas export terminals, one in my own Citrus County, where the majority of this “public good” will be shipped overseas to free / non free trade partners. Once this gas is shipped globally, the argument of cheap / energy-independent reasoning will fly out of the window. Never mind that the LNG comes from the Marcellus Shale where people’s wells, rivers, and wells are catching fire and are too toxic to drink.
    We the people are not being represented, and our public lands and waters are simply considered barriers to profit.
    A yearly test will not prevent disaster to waters and climate

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