Appendix F 

ELBA EXPRESS PIPELINE PROJECT 

WETLAND AND WATERBODY CONSTRUCTION 

AND MITIGATION PROCEDURES 
ELBA EXPRESS PIPELINE PROJECT EEC PROCEDURES 

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ELBA EXPRESS COMPANY’S 

WETLAND AND WATERBODY CONSTRUCTION AND MITIGATION PROCEDURES 

TABLE OF CONTENTS 

I. APPLICABILITY ...............................................................................................................................................1 

II. PRECONSTRUCTION FILING.....................................................................................................................2 

III. ENVIRONMENTAL INSPECTORS..............................................................................................................2 

IV. PRECONSTRUCTION PLANNING..............................................................................................................2 

V. WATERBODY CROSSINGS.........................................................................................................................3 

A. NOTIFICATION PROCEDURES AND PERMITS ..............................................................................3 

B. INSTALLATION ...................................................................................................................................4 

1. Time Window for Construction .......................................................................................................4 

2. Extra Work Areas.............................................................................................................................4 

3. General Crossing Procedures ...........................................................................................................5 

4. Spoil Pile Placement and Control.....................................................................................................5 

5. Equipment Bridges...........................................................................................................................6 

6. Dry-Ditch Crossing Methods ...........................................................................................................6 

7. Crossings of Minor Waterbodies (see figure Proc-8).......................................................................8 

8. Crossings of Intermediate Waterbodies............................................................................................8 

9. Crossings of Major Waterbodies......................................................................................................8 

10. Temporary Erosion and Sediment Control.......................................................................................9 

11. Trench Dewatering...........................................................................................................................9 

C. RESTORATION.....................................................................................................................................9 

D. POST-CONSTRUCTION MAINTENANCE ......................................................................................10 

VI. WETLAND CROSSINGS ............................................................................................................................10 

A. GENERAL............................................................................................................................................10 

B. INSTALLATION .................................................................................................................................11 

1. Extra Work Areas and Access Roads.............................................................................................11 

2. Crossing Procedures.......................................................................................................................12 

3. Temporary Sediment Control.........................................................................................................13 

4. Trench Dewatering.........................................................................................................................14 

C. RESTORATION...................................................................................................................................14 

D. POST-CONSTRUCTION MAINTENANCE ......................................................................................15 

VII. HYDROSTATIC TESTING .........................................................................................................................15 

A. NOTIFICATION PROCEDURES AND PERMITS ............................................................................15 

B. GENERAL............................................................................................................................................15 

C. INTAKE SOURCE AND RATE ..........................................................................................................16 

D. DISCHARGE LOCATION, METHOD, AND RATE..........................................................................16 
ELBA EXPRESS PIPELINE PROJECT EEC PROCEDURES 

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LIST OF FIGURES 

Proc-1 Typical Timber Mat Bridge (w/Culvert) Equipment Crossing 

Proc-2 Typical Timber Mat Bridge (w/o Culvert) Equipment Crossing 

Proc-3 Typical Rock and Flume Equipment Crossing 

Proc-4 Typical Portable Bridge Equipment Crossing 

Proc-5 Dry Waterbody Crossing (Method 2B – Pump-Around) 

Proc-6 Dry Waterbody Crossing (Method 2A – Flumed) 

Proc-7 Typical Workspace Layout Directional Drill Method 

Proc-8 Wet Waterbody Crossing (Method 1 – Open-Cut) 

Proc-9 Standard/Conventional Wetland Construction (Method I or II) 

Proc-10 Wet Waterbody Crossing (Method III – Push/Pull) 

Proc-11 Typical Energy Dissipater 

ATTACHMENT 

Attachment A Additional Temporary Work Space Within 50-feet of Wetlands 

 
ELBA EXPRESS PIPELINE PROJECT EEC PROCEDURES

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ELBA EXPRESS COMPANY’S WETLAND AND WATERBODY 

CONSTRUCTION AND MITIGATION PROCEDURES 

I. APPLICABILITY

A. Elba Express Company, LLC (EEC)’s Wetland and Waterbody Construction and Mitigation 

Procedures (Procedures) for the Elba Express Pipeline Project are based upon the Federal Energy 

Regulatory Commission’s (FERC’s) Wetland and Waterbody Construction and Mitigation 

Procedures published in January 2003 (FERC Procedures). The FERC Procedures state that 

project sponsors should specify in their applications for a FERC Certificate (Certificate) any 

individual measures in the FERC Procedures they consider unnecessary, technically infeasible, or 

unsuitable due to local conditions and to fully describe any alternative measures they would use. 

Applicants also should explain how those alternative measures would achieve a comparable level 

of mitigation. As such, EEC has identified project-specific exceptions for the Elba Express 

Pipeline Project in bold text throughout this document. 

If the Elba Express Pipeline Project is certificated, further changes to EEC’s Procedures may be 

approved by the Director of the Office of Energy Projects (Director), upon EEC’s written request, 

if the Director agrees that an alternative measure: 

1 provides equal or better environmental protection; 

2 is necessary because a portion of these Procedures is infeasible or unworkable based on 

project-specific conditions; or 

3 is specifically required in writing by another Federal, state, or Native American land 

management agency for the portion of the project on its land or under its jurisdiction. 

Project-related impacts on non-wetland areas are addressed in EEC’s Upland Erosion Control, 

Revegetation, and Maintenance Plan (Plan). 

B. DEFINITIONS 

1. "Waterbody" includes any natural or artificial stream, river, or drainage with perceptible 

flow at the time of crossing, and other permanent waterbodies such as ponds and lakes: 

a. "minor waterbody" includes all waterbodies less than or equal to 10 feet wide at 

the water's edge at the time of construction; 

b. "intermediate waterbody" includes all waterbodies greater than 10 feet wide but 

less than or equal to 100 feet wide at the water's edge at the time of construction; 

and 

c. "major waterbody" includes all waterbodies greater than 100 feet wide at the 

water's edge at the time of construction. 

2. "Wetland" includes any area that is not in actively cultivated or rotated cropland and that 

satisfies the requirements of the current Federal methodology for identifying and 

delineating wetlands. 
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II. PRECONSTRUCTION FILING

A. The following information will be filed with the Secretary prior to the beginning of construction: 

1. the hydrostatic testing information specified in Section VII.B.3. and a wetland delineation 

report as described in Section VI.A.1., if applicable; and 

2. a schedule identifying when trenching or blasting would occur within each waterbody 

greater than 10 feet wide, or within any designated coldwater fishery. EEC shall revise 

the schedule as necessary to provide FERC staff at least 14 days advance notice. 

Changes within this last 14-day period must provide for at least 48 hours advance notice. 

B. The following site-specific construction plans required by these Procedures will be filed with the 

Secretary for the review and written approval by the Director: 

1. plans for extra work areas that would be closer than 50 feet from a waterbody or wetland; 

2. plans for major waterbody crossings; 

3. plans for the use of a construction right-of-way greater than 75 feet wide in wetlands; and 

4. plans for horizontal directional drill (HDD) "crossings" of wetlands or waterbodies. 

III. ENVIRONMENTAL INSPECTORS

A. EEC will provide at least one Environmental Inspector (EI) having knowledge of the wetland and 

waterbody conditions in the project area for each construction spread. The number and 

experience of Environmental Inspectors assigned to each construction spread will be appropriate 

for the length of the construction spread and the number/significance of resources affected. 

B. The Environmental Inspector's responsibilities are outlined in the Upland Erosion Control, 

Revegetation, and Maintenance Plan (Plan). 

IV. PRECONSTRUCTION PLANNING

A. A copy of EEC’s Spill Plan will be available in the field on each construction spread. The Spill 

Plan shall contain Spill Prevention and Response Procedures that meet the requirements of state 

and Federal agencies. 

1. EEC and its contractors will structure their operations in a manner that reduces the risk of 

spills or the accidental exposure of fuels or hazardous materials to waterbodies or 

wetlands. EEC and its contractors will ensure that: 

a. all employees handling fuels and other hazardous materials are properly trained; 

b. all equipment is in good operating order and inspected on a regular basis; 

c. fuel trucks transporting fuel to on-site equipment travel only on approved access 

roads; 
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d. fueling equipment is located in an upland additional temporary workspace area at 

the furthest distance away from a waterbody or wetland boundary as is practical. If 

fueling equipment must be located within 100 feet of a wetland or waterbody, Elba 

Express Company, LLC (EEC) proposes to follow provisions in its Spill Plan; 

e. hazardous materials, including chemicals, fuels, and lubricating oils, are not 

stored within 100 feet of a wetland, waterbody, or designated municipal 

watershed area, unless the location is designated for such use by an appropriate 

governmental authority. This applies to storage of these materials and does not 

apply to normal operation or use of equipment in these areas; and 

f. concrete coating activities are not performed within 100 feet of a wetland or 

waterbody boundary, unless the location is an existing industrial site designated 

for such use. 

2. EEC and its contractors will structure their operations in a manner that provides for the 

prompt and effective cleanup of spills of fuel and other hazardous materials. At a 

minimum, EEC and its contractors will: 

a. ensure that each construction crew (including cleanup crews) has on hand 

sufficient supplies of absorbent and barrier materials to allow the rapid 

containment and recovery of spilled materials and knows the procedure for 

reporting spills; 

b. ensure that each construction crew has on hand sufficient tools and material to 

stop leaks; 

c. know the contact names and telephone numbers for all local, state, and Federal 

agencies (including, if necessary, the U. S. Coast Guard and the National 

Response Center) that must be notified of a spill; and 

d. follow the requirements of those agencies in cleaning up the spill, in excavating 

and disposing of soils or other materials contaminated by a spill, and in collecting 

and disposing of waste generated during spill cleanup. 

B. AGENCY COORDINATION 

EEC will coordinate with the appropriate local, state, and Federal agencies as outlined in these 

Procedures and in the Certificate. 

 

V. WATERBODY CROSSINGS

A. NOTIFICATION PROCEDURES AND PERMITS 

1. EEC has applied to the U.S. Army Corps of Engineers (COE) for the appropriate wetland 

and waterbody crossing permits. 

2. EEC will provide written notification to authorities responsible for potable surface water 

supply intakes located within 3 miles downstream of the crossing at least 1 week before 

beginning work in the waterbody, or as otherwise specified by that authority. 
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3. EEC will apply for state-issued waterbody crossing permits and obtain individual or 

generic Section 401 water quality certification or waiver. 

4. EEC will notify appropriate state authorities at least 48 hours before beginning trenching 

or blasting within the waterbody, or as specified in state permits. 

B. INSTALLATION 

1. Time Window for Construction 

Unless expressly permitted or further restricted by the appropriate state agency in writing 

on a site-specific basis, instream work, except that required to install or remove 

equipment bridges, must occur during the following time windows: 

a. coldwater fisheries - June 1 through September 30; and 

b. coolwater and warmwater fisheries - EEC will conduct all in-stream work in 

consultation with federal and state regulatory agencies. Unless specific issues are 

identified for a particular stream crossing, EEC will use its discretion to utilize 

the most appropriate crossing method for that location during a time period 

within its construction schedule. In all events, EEC will attempt to minimize instream impacts by expediting the crossing time and adhering to best management 

practices for waterbody crossings. 

 

2. Extra Work Areas 

a. EEC will locate all extra work areas (such as staging areas and additional spoil 

storage areas) at least 50 feet away from water’s edge, except where the adjacent 

upland consists of actively cultivated or rotated cropland or other disturbed land. 

EEC has identified areas where it will be necessary to utilize extra work spaces 

within 50 feet of wetland and waterbodies and within wetlands. These extra 

workspaces are necessary for certain construction techniques for HDD and 

conventional bore pits at road crossings and the crossings of sensitive 

environmental features. The Extra Work Space areas within 50 feet of wetlands 

and waterbodies are detailed in Attachment A. 

b. EEC shall file with the Secretary for review and written approval by the Director, 

a site-specific construction plan for each extra work area with a less than 50-foot 

setback from the water's edge, (except where the adjacent upland consists of 

actively cultivated or rotated cropland or other disturbed land) and a site-specific 

explanation of the conditions that will not permit a 50-foot setback. 

FERC Staff Comment – This approach is acceptable only if the GDNR, 

SCDNR, FWS, and COE are amenable to this construction schedule. 

FERC Staff Comment – We have determined that EEC’s extra work spaces 

(presented as Attachment A to these Procedures) are reasonable and adequately 

justified. EEC would need to be consistent with its permits from the other 

jurisdictional agencies (e.g., the COE, the GDNR, and the SCDNR). 
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c. EEC will limit clearing of vegetation between extra work areas and the edge of 

the waterbody to the certificated construction right-of-way. 

d. EEC will limit the size of extra work areas to the minimum needed to construct 

the waterbody crossing. 

3. General Crossing Procedures 

a. EEC will comply with the COE, or its delegated agency, permit terms and 

conditions. 

b. EEC will construct crossings as close to perpendicular to the axis of the 

waterbody channel as engineering and routing conditions permit. 

c. If the pipeline parallels a waterbody, EEC will attempt to maintain at least 15 feet 

of undisturbed vegetation between the waterbody (and any adjacent wetland) and 

the construction right-of-way. 

d. Where waterbodies meander or have multiple channels, EEC will route the 

pipeline to minimize the number of waterbody crossings. 

e. EEC will maintain adequate flow rates to protect aquatic life, and prevent the 

interruption of existing downstream uses. 

f. Waterbody buffers (extra work area setbacks, refueling restrictions, etc.) must be 

clearly marked in the field with signs and/or highly visible flagging until 

construction-related ground disturbing activities are complete. 

f. The Chief Inspector (CI), EI, Environmental Contractor (EC), appropriate 

agency(s), and other EEC inspectors will identify or approve the appropriate 

waterbody crossing method from Section V.B.6-9 or Section VI.B of the Procedures 

for each location, based on site-specific conditions at the time of construction. In all 

instances, the crossing method utilized will be in accordance with all federal, state 

and local permit requirements including specific measures listed within this plan for 

the selected method. 

4. Spoil Pile Placement and Control 

a. All spoil from minor and intermediate waterbody crossings, and upland spoil 

from major waterbody crossings, will be placed in the construction right-of-way 

at least 10 feet from the water's edge or in additional extra work areas as 

described in Section V.B.2. 

FERC Staff Comment – Implementation of this method of the EI determining 

crossing methods at the stream location in consultation with appropriate agencies 

would offer the same level of protection or greater than identifying crossing 

methods prior to construction. 
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b. EEC will use sediment barriers to prevent the flow of spoil or heavily silt-laden 

water into any waterbody. 

5. Equipment Bridges 

a. Only clearing equipment and equipment necessary for installation of equipment 

bridges may cross waterbodies prior to bridge installation. The number of such 

crossings of each waterbody will be limited to one per piece of clearing 

equipment. 

b. EEC will construct equipment bridges to maintain unrestricted flow and to 

prevent soil from entering the waterbody. Examples of such bridges include: 

(1) equipment pads and culvert(s) (see figure Proc-1); 

(2) equipment pads or railroad car bridges without culverts (see figure Proc-2); 

(3) clean rock fill and culvert(s) (see figure Proc-3); and 

(4) flexi-float or portable bridges (see figure Proc-4). 

Additional options for equipment bridges may be utilized that achieve the 

performance objectives noted above. Do not use soil to construct or stabilize 

equipment bridges. 

c. EEC will design and maintain each equipment bridge to withstand and pass the 

highest flow expected to occur while the bridge is in place. Align culverts to 

prevent bank erosion or streambed scour. If necessary, install energy dissipating 

devices downstream of the culverts. 

d. EEC will design and maintain equipment bridges to prevent soil from entering 

the waterbody. 

e. EEC will remove equipment bridges as soon as possible after permanent seeding 

unless the COE, or its delegated agency, authorizes it as a permanent bridge. 

f. If there will be more than 1 month between final cleanup and the beginning of 

permanent seeding and reasonable alternative access to the right-of-way is 

available, EEC will remove equipment bridges as soon as possible after final 

cleanup. 

6. Dry-Ditch Crossing Methods 

a. Unless approved otherwise by the appropriate state agency, EEC will install the 

pipeline using one of the dry-ditch methods outlined below for crossings of 

waterbodies up to 30 feet wide (at the water's edge at the time of construction) that 

are state-designated as either coldwater or significant coolwater or warmwater 

fisheries. 
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b. Dam and Pump (see figure Proc-5) 

(1) The dam-and-pump method may be used without prior approval for 

crossings of waterbodies where pumps can adequately transfer 

streamflow volumes around the work area, and there are no concerns 

about sensitive species passage. 

(2) Implementation of the dam-and-pump crossing method must meet the 

following performance criteria: 

(i) use sufficient pumps, including on-site backup pumps, to 

maintain downstream flows; 

(ii) construct dams with materials that prevent sediment and other 

pollutants from entering the waterbody (e.g., sandbags or clean 

gravel with plastic liner); 

(iii) screen pump intakes; 

(iv) prevent streambed scour at pump discharge; and 

(v) monitor the dam and pumps to ensure proper operation 

throughout the waterbody crossing. 

c. Flume Crossing (see figure Proc-6) 

The flume crossing method requires implementation of the following steps: 

(1) install flume pipe after blasting (if necessary), but before any trenching; 

(2) use sand bag or sand bag and plastic sheeting diversion structure or 

equivalent to develop an effective seal and to divert stream flow through 

the flume pipe (some modifications to the stream bottom may be 

required in to achieve an effective seal); 

(3) properly align flume pipe(s) to prevent bank erosion and streambed 

scour; 

(4) do not remove flume pipe during trenching, pipelaying, or backfilling 

activities, or initial streambed restoration efforts; and 

(5) remove all flume pipes and dams that are not also part of the equipment 

bridge as soon as final cleanup of the stream bed and bank is complete. 

d. Horizontal Directional Drill (HDD) (see figure Proc-7) 

To the extent they were not provided as part of the pre-certification process, for 

each waterbody or wetland that would be crossed using the HDD method, EEC 

will provide a plan that includes: 

(1) site-specific construction diagrams that show the location of mud pits, 

pipe assembly areas, and all areas to be disturbed or cleared for 

construction; 
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(2) a description of how an inadvertent release of drilling mud would be 

contained and cleaned up; and 

(3) a contingency plan for crossing the waterbody or wetland in the event the 

directional drill is unsuccessful and how the abandoned drill hole would 

be sealed, if necessary. 

7. Crossings of Minor Waterbodies (see figure Proc-8) 

Where a dry-ditch crossing is not required, minor waterbodies will be crossed using the 

open-cut crossing method, with the following restrictions: 

 a. except for blasting and other rock breaking measures, complete instream 

construction activities (including trenching, pipe installation, backfill, and 

restoration of the streambed contours) within 24 hours. Streambanks and 

unconsolidated streambeds may require additional restoration after this period; 

 b. limit use of equipment operating in the waterbody to that needed to construct the 

crossing; and 

 c. equipment bridges are not required at minor waterbodies that do not have a statedesignated fishery classification (e.g., agricultural or intermittent drainage 

ditches). However, if an equipment bridge is used it must be constructed as 

described in Section V.B.5. 

8. Crossings of Intermediate Waterbodies 

Where a dry-ditch crossing is not required, intermediate waterbodies will be crossed 

using the open-cut crossing method, with the following restrictions: 

a. complete instream construction activities (not including blasting and other rock 

breaking measures) within 48 hours, unless site-specific conditions make 

completion within 48 hours infeasible; 

b. limit use of equipment operating in the waterbody to that needed to construct the 

crossing; and 

c. all other construction equipment must cross on an equipment bridge as specified 

in Section V.B.5. 

9. Crossings of Major Waterbodies 

Before construction, EEC shall file with the Secretary for the review and written approval 

by the Director a detailed, site-specific construction plan and scaled drawings identifying 

all areas to be disturbed by construction for each major waterbody crossing (the scaled 

drawings are not required for any offshore portions of pipeline projects). This plan will 

be developed in consultation with the appropriate state and Federal agencies and will 

include extra work areas, spoil storage areas, sediment control structures, etc., as well as 

mitigation for navigational issues. 
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The Environmental Inspector may adjust the final placement of the erosion and sediment 

control structures in the field to maximize effectiveness. 

10. Temporary Erosion and Sediment Control 

EEC will install sediment barriers (as defined in Section IV.F.2.a. of the Plan) 

immediately after initial disturbance of the waterbody or adjacent upland. Sediment 

barriers will be properly maintained throughout construction and reinstalled as necessary 

(such as after backfilling of the trench) until replaced by permanent erosion controls or 

restoration of adjacent upland areas is complete. Temporary erosion and sediment 

control measures are addressed in more detail in the Plan; however, the following specific 

measures must be implemented at stream crossings: 

a. install sediment barriers across the entire construction right-of-way at all 

waterbody crossings, where necessary to prevent the flow of sediments into the 

waterbody. Removable sediment barriers (or driveable berms) must be installed 

across the travel lane. These removable sediment barriers can be removed during 

the construction day, but must be re-installed after construction has stopped for 

the day and/or when heavy precipitation is imminent; 

b. where waterbodies are adjacent to the construction right-of-way, install sediment 

barriers along the edge of the construction right-of-way as necessary to contain 

spoil and sediment within the construction right-of-way; and 

c. use trench plugs at all waterbody crossings, as necessary, to prevent diversion of 

water into upland portions of the pipeline trench and to keep any accumulated 

trench water out of the waterbody. 

11. Trench Dewatering 

EEC will dewater the trench (either on or off the construction right-of-way) in a manner 

that does not cause erosion and does not result in heavily silt-laden water flowing into 

any waterbody. Removal of the dewatering structures will take place as soon as possible 

after the completion of dewatering activities. 

C. RESTORATION 

1. EEC will use clean gravel or native cobbles for the upper 1 foot of trench backfill in all 

waterbodies that contain coldwater fisheries. 

2. For open-cut crossings, EEC will stabilize waterbody banks and install temporary 

sediment barriers within 24 hours of completing instream construction activities. For 

dry-ditch crossings, complete streambed and bank stabilization before returning flow to 

the waterbody channel. 

 

3. EEC will return all waterbody banks to preconstruction contours or to a stable angle of 

repose as approved by the Environmental Inspector. 

4. Application of riprap for bank stabilization will comply with COE, or its delegated 

agency, permit terms and conditions. 
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5. Unless otherwise specified by state permit, EEC will limit the use of riprap to areas 

where flow conditions preclude effective vegetative stabilization techniques such as 

seeding and erosion control fabric. 

6. EEC will revegetate disturbed riparian areas with conservation grasses and legumes or 

native plant species, preferably woody species. 

7. EEC will install a permanent slope breaker across the construction right-of-way at the 

base of slopes greater than 5 percent that are less than 50 feet from the waterbody, or as 

needed to prevent sediment transport into the waterbody. In addition, EEC will install 

sediment barriers as outlined in the Plan. 

In some areas, with the approval of the Environmental Inspector, an earthen berm may be 

suitable as a sediment barrier adjacent to the waterbody. 

8. Sections V.C.3. through V.C.6. above also apply to those perennial or intermittent 

streams not flowing at the time of construction. 

D. POST-CONSTRUCTION MAINTENANCE 

1. EEC will limit vegetation maintenance adjacent to waterbodies to allow a riparian strip at 

least 25 feet wide, as measured from the waterbody's mean high water mark, to 

permanently revegetate with native plant species across the entire construction right-ofway. However, to facilitate periodic pipeline corrosion/leak surveys, a corridor centered 

on the pipeline and up to 10 feet wide may be maintained in a herbaceous state. In 

addition, trees that are located within 15 feet of the pipeline that are greater than 15 feet 

in height may be cut and removed from the permanent right-of-way. 

2. EEC will not use herbicides or pesticides in or within 100 feet of a waterbody except as 

allowed by the appropriate land management or state agency. 

VI. WETLAND CROSSINGS

A. GENERAL 

1. EEC shall conduct a wetland delineation using the current Federal methodology and file a 

wetland delineation report with the Secretary before construction. This report shall 

identify: 

a. by milepost all wetlands that would be affected; 

b. the National Wetlands Inventory (NWI) classification for each wetland; 

c. the crossing length of each wetland in feet; and 

d. the area of permanent and temporary disturbance that would occur in each 

wetland by NWI classification type. 
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The requirements outlined in this section do not apply to wetlands in actively cultivated 

or rotated cropland. Standard upland protective measures, including workspace and 

topsoiling requirements, apply to these agricultural wetlands. 

2. EEC will route the pipeline to avoid wetland areas to the maximum extent possible. If a 

wetland cannot be avoided or crossed by following an existing right-of-way, EEC will 

route the new pipeline in a manner that minimizes disturbance to wetlands. Where 

looping an existing pipeline, EEC will overlap the existing pipeline right-of-way with the 

new construction right-of-way. In addition, EEC will locate the loop line no more than 

25 feet away from the existing pipeline unless site-specific constraints would adversely 

affect the stability of the existing pipeline. 

3. EEC will limit the width of the construction right-of-way to 75 feet or less. Prior written 

approval of the Director is required where topographic conditions or soil limitations 

require that the construction right-of-way width within the boundaries of a federally 

delineated wetland expand beyond 75 feet. Early in the planning process EEC identified 

site-specific areas where existing soils lack adequate unconfined compressive strength 

that would result in excessively wide ditches and/or difficult to contain spoil piles. 

4. Wetland boundaries and buffers will be clearly marked in the field with signs and/or 

highly visible flagging until construction-related ground disturbing activities are 

complete. 

5. EEC will implement the measures of Sections V. and VI. in the event a waterbody 

crossing is located within or adjacent to a wetland crossing. If all measures of Sections 

V. and VI. cannot be met, EEC will file with the Secretary a site-specific crossing plan 

for review and written approval by the Director before construction. This crossing plan 

shall address at a minimum: 

a. spoil control; 

b. equipment bridges; 

c. restoration of waterbody banks and wetland hydrology; 

d. timing of the waterbody crossing; 

e. method of crossing; and 

f. size and location of all extra work areas. 

6. EEC will not locate aboveground facilities in any wetland, except where the location of 

such facilities outside of wetlands would prohibit compliance with U.S. Department of 

Transportation regulations. 

B. INSTALLATION 

1. Extra Work Areas and Access Roads 

a. EEC will locate all extra work areas (such as staging areas and additional spoil 

storage areas) at least 50 feet away from wetland boundaries, except where the 
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adjacent upland consists of actively cultivated or rotated cropland or other 

disturbed land. Areas where it will be necessary to utilize extra work spaces 

within 50 feet of wetlands and waterbodies are identified in Attachment A. 

b. EEC shall file with the Secretary for review and written approval by the Director, 

a site-specific construction plan for each extra work area with a less than 50-foot 

setback from wetland boundaries (except where adjacent upland consists of 

actively cultivated or rotated cropland or other disturbed land) and a site-specific 

explanation of the conditions that will not permit a 50-foot setback. 

c. EEC will limit clearing of vegetation between extra work areas and the edge of 

the wetland to the certificated construction right-of-way. 

d. The construction right-of-way may be used for access when the wetland soil is 

firm enough to avoid rutting or the construction right-of-way has been 

appropriately stabilized to avoid rutting (e.g., with timber riprap, prefabricated 

equipment mats, or terra mats). 

In wetlands that cannot be appropriately stabilized, all construction equipment 

other than that needed to install the wetland crossing shall use access roads 

located in upland areas. Where access roads in upland areas do not provide 

reasonable access, limit all other construction equipment to one pass through the 

wetland using the construction right-of-way. 

e. The only access roads, other than the construction right-of-way, which will be 

used in wetlands without Director approval, are those existing roads that can be 

used with no modification and no impact on the wetland. 

 

2. Crossing Procedures 

a. EEC will comply with COE, or its delegated agency, permit terms and conditions 

(see figures Proc-9 and Proc-10). 

b. EEC will assemble the pipeline in an upland area unless the wetland is dry 

enough to adequately support skids and pipe. 

c. EEC will use "push-pull" or "float" techniques to place the pipe in the trench 

where water and other site conditions allow. 

d. EEC will minimize the length of time that topsoil is segregated and the trench is 

open. 

e. EEC will limit construction equipment operating in wetland areas to that needed 

to clear the construction right-of-way, dig the trench, fabricate and install the 

pipeline, backfill the trench, and restore the construction right-of-way. 

f. EEC will cut vegetation just aboveground level, leaving existing root systems in 

place, and remove it from the wetland for disposal. 

g. EEC will limit pulling of tree stumps and grading activities to directly over the 

trenchline. Do not grade or remove stumps or root systems from the rest of the 
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construction right-of-way in wetlands unless the Chief Inspector and 

Environmental Inspector determine that safety-related construction constraints 

require grading or the removal of tree stumps from under the working side of the 

construction right-of-way. 

h. EEC will segregate the top 1 foot of topsoil from the area disturbed by trenching, 

except in areas where standing water is present or soils are saturated or frozen. 

Immediately after backfilling is complete, restore the segregated topsoil to its 

original location. 

i. EEC will not use rock, soil imported from outside the wetland, tree stumps, or 

brush riprap to support equipment on the construction right-of-way. 

j. If standing water or saturated soils are present, or if construction equipment 

causes ruts or mixing of the topsoil and subsoil in wetlands, EEC will use lowground-weight construction equipment, or operate normal equipment on timber 

riprap, prefabricated equipment mats, or terra mats. 

k. EEC will not cut trees outside of the approved construction work area to obtain 

timber for riprap or equipment mats. 

l. EEC will attempt to use no more than two layers of timber riprap to support 

equipment on the construction right-of-way. 

m. EEC will remove all project-related material used to support equipment on the 

construction right-of-way upon completion of construction. 

3. Temporary Sediment Control 

EEC will install sediment barriers (as defined in Section IV.F.2.a. of the Plan) 

immediately after initial disturbance of the wetland or adjacent upland. Sediment barriers 

will be properly maintained throughout construction and reinstalled as necessary (such as 

after backfilling of the trench). Except as noted below in Section VI.B.3.c, sediment 

barriers will be maintained until replaced by permanent erosion controls or restoration of 

adjacent upland areas is complete. Temporary erosion and sediment control measures are 

addressed in more detail in the Plan. 

a. EEC will install sediment barriers across the entire construction right-of-way 

immediately upslope of the wetland boundary at all wetland crossings where 

necessary to prevent sediment flow into the wetland. 

b. Where wetlands are adjacent to the construction right-of-way and the right-ofway slopes toward the wetland, EEC will install sediment barriers along the edge 

of the construction right-of-way as necessary to prevent sediment flow into the 

wetland. 

c. EEC will install sediment barriers along the edge of the construction right-of-way 

as necessary to contain spoil and sediment within the construction right-of-way 

through wetlands. EEC will remove these sediment barriers during right-of-way 

cleanup. 
ELBA EXPRESS PIPELINE PROJECT EEC PROCEDURES

F-14 

4. Trench Dewatering 

EEC will dewater the trench (either on or off the construction right-of-way) in a manner 

that does not cause erosion and does not result in heavily silt-laden water flowing into 

any wetland. EEC will remove the dewatering structures as soon as possible after the 

completion of dewatering activities. 

C. RESTORATION 

1. Where the pipeline trench may drain a wetland, EEC will construct trench breakers 

and/or seal the trench bottom as necessary to maintain the original wetland hydrology. 

2. For each wetland crossed, EEC will install a trench breaker at the base of slopes near the 

boundary between the wetland and adjacent upland areas. EEC will install a permanent 

slope breaker across the construction right-of-way at the base of a slope(s) greater than 5 

percent where the base of the slope is less than 50 feet from the wetland, or as needed to 

prevent sediment transport into the wetland. In addition, EEC will install sediment 

barriers as outlined in the Plan. In some areas, with the approval of the Environmental 

Inspector, an earthen berm may be suitable as a sediment barrier adjacent to the wetland. 

3. EEC will not use fertilizer, lime, or mulch unless required in writing by the appropriate 

land management or state agency. 

EEC does not intend to revegetate wetlands by planting native species. Studies have shown that 

natural revegetation of wetlands in the southeast have a higher success rate than planted wetlands due 

to inherent, regenerative capacities of seedbank and vegetative reproduction. Natural species 

selection will occur across the environmental gradient and microsites where they are best adapted 

versus seeded or installed plantings. 

4. EEC has outlined its wetland restoration methods in its Wetland Mitigation Plan. A Draft 

Wetland Mitigation Plan has been submitted to the USACE with EEC’s application to the 

USACE to construct the pipeline within waters of the U.S. (in compliance with 

Section 404 of the Clean Water Act and Section 10 of the Rivers and Harbors Act of 

1899). EEC’s wetland restoration measures as approved by the USACE will become part 

of the USACE’s permit authorizing construction of the proposed project within waters of 

the U.S. EEC will comply with federal and state permit conditions regarding wetland 

restoration and mitigation. 

5. EEC will ensure that all disturbed areas successfully revegetate with wetland herbaceous 

and/or woody plant species. 

6. EEC will remove temporary sediment barriers located at the boundary between wetland 

and adjacent upland areas after upland revegetation and stabilization of adjacent upland 

areas are judged to be successful as specified in Section VII.A.5. of the Plan. 

FERC Staff Comment – This approach is acceptable only if the COE agrees. Complete analysis of 

this approach can be found in section 4.4.
ELBA EXPRESS PIPELINE PROJECT EEC PROCEDURES

F-15 

D. POST-CONSTRUCTION MAINTENANCE 

1. EEC will not conduct vegetation maintenance over the full width of the permanent rightof-way in wetlands. However, to facilitate periodic pipeline corrosion/leak surveys, a 

corridor centered on the pipeline and up to 10 feet wide may be maintained in a 

herbaceous state. In addition, trees within 15 feet of the pipeline greater than 15 feet in 

height may be selectively cut and removed from the permanent right-of-way. 

2. EEC will not use herbicides or pesticides in or within 100 feet of a wetland, except as 

allowed by the appropriate land management agency or state agency. 

3. EEC will continue revegetation efforts until wetland revegetation is successful. Upon 

EEC’s determination that revegetation is successful, it will terminate monitoring. An 

annual report will be filed with the Secretary identifying the status of the wetland 

revegetation efforts. The percent cover achieved and problem areas (weed invasion 

issues, poor revegetation, etc.) will be included in the report. EEC will file a report 

annually until wetland revegetation is successful. 

4. Wetland revegetation shall be considered successful if the cover of herbaceous and/or 

woody species is at least 80 percent of the type, density, and distribution of the vegetation 

in adjacent wetland areas that were not disturbed by construction. If revegetation is not 

successful at the end of 3 years, EEC will develop and implement (in consultation with a 

professional wetland ecologist) a remedial revegetation plan to actively revegetate the 

wetland. EEC will continue revegetation efforts until wetland revegetation is successful. 

VII. HYDROSTATIC TESTING

A. NOTIFICATION PROCEDURES AND PERMITS 

1. EEC will apply for state-issued water withdrawal permits, as required. 

2. EEC will apply for National Pollutant Discharge Elimination System (NPDES) or stateissued discharge permits, as required. 

3. EEC will notify appropriate state agencies of intent to use specific sources at least 48 

hours before testing activities unless they waive this requirement in writing. 

B. GENERAL 

1. EEC will perform 100 percent radiographic inspection of all pipeline section welds or 

hydrotest the pipeline sections, before installation under waterbodies or wetlands. 

2. If pumps used for hydrostatic testing are within 100 feet of any waterbody or wetland, 

EEC will address the operation and refueling of these pumps in the project’s Spill 

Prevention and Response Procedures. 

3. EEC shall file with the Secretary before construction a list identifying the location of all 

waterbodies proposed for use as a hydrostatic test water source or discharge location. 
ELBA EXPRESS PIPELINE PROJECT EEC PROCEDURES

F-16 

C. INTAKE SOURCE AND RATE 

1. EEC will screen the intake hose to prevent entrainment of fish. 

2. EEC will not use state-designated exceptional value waters, waterbodies which provide 

habitat for federally listed threatened or endangered species, or waterbodies designated as 

public water supplies, unless appropriate Federal, state, and/or local permitting agencies 

grant written permission. 

3. EEC will maintain adequate flow rates to protect aquatic life, provide for all waterbody 

uses, and provide for downstream withdrawals of water by existing users. 

4. EEC will locate hydrostatic test manifolds outside wetlands and riparian areas to the 

maximum extent practicable. 

D. DISCHARGE LOCATION, METHOD, AND RATE 

1. EEC will regulate discharge rate, use energy dissipation device(s), and install sediment 

barriers, as necessary, to prevent erosion, streambed scour, suspension of sediments, or 

excessive streamflow (see figure Proc-11). 

2. EEC will not discharge into state-designated exceptional value waters, waterbodies which 

provide habitat for federally listed threatened or endangered species, or waterbodies 

designated as public water supplies, unless appropriate federal, state, and local permitting 

agencies grant written permission. 











Attachment A 

AREAS ALONG THE ELBA EXPRESS PIPELINE PROJECT WHERE EEC PROPOSES EXTRA WORK 

SPACES AND FACILITIES WITHIN 50 FEET OF WETLANDS AND WATERBODIES
ELBA EXPRESS PIPELINE PROJECT EEC PROCEDURES

AREAS WHERE EEC PROPOSES EXTRA WORK SPACES/ATWS AND FACILITIES 

WITHIN 50 FEET OF WETLANDS AND WATERBODIES 

Landuse Acreage 

MP Work Space 

ID County/ State Approximate Dimension Wetland/ Waterbody ID Drawing Reference Description 

PFO 

PSS 

PEM 

OTHER 

Extra Work Spaces/ATWS and Facilities within 50 feet of a WETLAND 

Southern Segment 

16.4 EF-20 Effingham/GA 100x150 W1BEF017 SN-GA- ELBA-1-007 State Highway 119 0.17 -- -- 0.17 19.4 EF-32 Effingham/GA 50x245 + 45x50 (Triangle) W1BEF029 SN-GA- ELBA-1-008 Boaen Road 0.15 -- -- 0.16 19.4 N/A (TWS) Effingham/GA 50X257 + 48X50 (Triangle) WiBEF029 SN-GA- ELBA-1-008 Boaen Road 0.25 -- -- 0.05 19.4 EF-33 Effingham/GA 50x135 + 35x50 (Triangle) W1BEF030 SN-GA- ELBA-1-008 Boaen Road 0.17 -- -- 0.00 19.4 N/A (TWS) Effingham/GA 50x242 + 43x50 (Triangle) W1BEF030 SN-GA- ELBA-1-008 Boaen Road 0.11 -- -- 0.22 20.6 EF-37 Effingham/GA 50x270 + 45x50 (Triangle) W1BEF033 SN-GA- ELBA-1-009 MT. Hope Road -- -- -- 0.34 27.3 EF-56 Effingham/GA 50x410 + 15x50 (Triangle) W1BEF038 SN-GA- ELBA-1-011 Egypt Ardmore Road 0.35 -- -- 0.13 27.3 EF-57 Effingham/GA 105x330 + 25x105 (Triangle) W1BEF038 SN-GA- ELBA-1-011 Egypt Ardmore Road -- -- -- 0.83 30.1 EF-70 Effingham/GA 100x290 + 90x100(Triangle) W1BEF064 SN-GA- ELBA-1-012 Norfolk Southern Railroad 0.54 -- -- 0.23 
ELBA EXPRESS PIPELINE PROJECT EEC PROCEDURES

AREAS WHERE EEC PROPOSES EXTRA WORK SPACES/ATWS AND FACILITIES 

WITHIN 50 FEET OF WETLANDS AND WATERBODIES 

Landuse Acreage 

MP Work Space 

ID County/ State Approximate Dimension Wetland/ Waterbody ID Drawing Reference Description 

PFO 

PSS 

PEM 

OTHER 

Northern Segment 

161.0 EL-01a Elbert/GA 15x140 W2AEL001 SN-GA- ELBA-1-064 Wetland/ Stream -- -- -- 0.05 

Aboveground Facilities 

No ATWS/Aboveground facilities located within 50ft. of wetlands. Extra Work Spaces/ATWS and Facilities within 50 feet of a WATE

Southern Segment 

28.5 EF-60 Effingham/GA 50x90 + 55x50 (Triangle) S1BEF031 SN-GA- ELBA-1-011 Stream -- -- -- 0.13 

Northern Segment 

No ATWS/Aboveground facilities located within 50ft. of waterbodies. 

Aboveground Facilities 

No ATWS/Aboveground facilities located within 50ft. of waterbodies. Extra Work Spaces/ATWS and Facilities within 50 feet of WETLANDS an

Southern Segment 

No ATWS/Aboveground facilities located within 50ft. of wetland and waterbodies. 

Northern Segment 

No ATWS/Aboveground facilities located within 50ft. of wetlands and waterbodies. 

Aboveground Facilities 

9.7 EF-113 Effingham/GA No change SF2CEF001- 001 SN-GA- ELBA-1-004 McIntosh Meter Station No change No change No change No change 

NOTE: ITEMS IN BOLD REPRESENT CHANGES TO ATTACHMENT A OF EEC’S PROCEDURES SUBMITTED WITH THE SEPTEMBER ER.