TDEC Filing

What is a “Permission to Cross” application?

In the case of Piedmont Natural Gas’ application, the “Permission to Cross” is a request for approval from the Tennessee Department of Environment and Conservation (TDEC) to allow Piedmont (The Company) to cross a portion of state-owned land with a new natural gas pipeline.  Because the property involved (Radnor Lake) is designated as a state natural area, the application is being filed with TDEC, which has responsibility for all such areas within the state of Tennessee.

Why has Piedmont filed this application?

Piedmont’s South Nashville Pipeline project, which will allow the Company to remain compliant with U.S. D.O.T. natural gas pipeline safety and integrity regulations, is following an existing Tennessee Valley Authority (TVA) easement for several miles of the pipeline’s proposed route.  A portion of that existing easement crosses Radnor Lake State Natural Area (RLSNA) and so a “Permission to Cross” application must be filed with TDEC for their review and approval.

What is included in Piedmont’s application?

Piedmont’s application includes:

  1. An overview and general description of the pipeline project as well as Piedmont’s goals for the project;
  2. The proposed location of the pipeline right-of-way (ROW) on Radnor Lake property as well as how Piedmont proposes to access, clear, restore, and maintain the ROW;
  3. Construction timing;
  4. A description of construction practices, procedures, and techniques to be employed by Piedmont to minimize or mitigate any issues related to spill prevention and cleanup, erosion protection and sediment control, stream and wetland crossings, threatened and endangered species;
  5. A description of how and by whom water quality within the RLSNA will be monitored throughout the construction period;
  6. A listing of governmental and agency permits necessary to the construction of the pipeline on the RLSNA;
  7. Detailed maps; graphical representations of various construction techniques, stream and wetland crossings; ROW restoration; soil erosion and sediment control plans.

Where is Piedmont proposing to cross Radnor Lake property with its new pipeline?

Within the RLSNA, Piedmont is proposing that the new pipeline be located entirely inside the existing TVA power line easement in order to minimize its impact on the property.  The proposed route enters RLSNA on its eastern boundary and lies in and along the northern edge of TVA’s easement for approximately 2,400 feet before shifting to the southern edge of TVA’s easement.  The pipeline, still within the TVA easement, will then continue in a westerly manner for another 3,400 feet before exiting the RLSNA.

How did Piedmont develop the proposed construction practices, procedures, and techniques contained in the application?

Piedmont Natural Gas follows best practices when designing, constructing, and installing its natural gas pipeline system.  Our goal is to leave the property in which we place our pipelines in as good or better condition than we found them.  With that in mind and as is typical in a project of this kind, Piedmont has reached out to a number of outside resources to complement its own extensive experience and expertise in such projects.  These outside resources include environmental consultants, biologists, cultural archaeologists, and geotechnical specialists to assist the Company in crafting its proposed practices and procedures.

What are the areas of environmental impact addressed in Piedmont’s request?

Piedmont’s request contains information regarding how the Company would propose to address environmental impacts in four broad areas:

  • Erosion protection and sediment control;
  • Jurisdictional waters;
  • Threatened and endangered species and,
  • Archaeological considerations.

Included within that information are topics ranging from the clearing and restoration of both temporary and permanent right-of-ways to water quality monitoring to construction techniques and timing.  It should be noted, too, that Piedmont’s efforts in a number of areas – like erosion prevention and sediment control, and storm water pollution and prevention – will be captured in a formal, detailed plan to be submitted to TDEC and appropriate local agencies for review and approval.

How will Piedmont address the environmental impacts identified in its request?

Information concerning Piedmont’s approach for addressing the environmental impacts can be found in significant detail in the request itself and in the exhibits attached to the request.  That document can be accessed here.  Various aspects of Piedmont’s proposed approach include:

  • A limited number of temporary construction access points along the route with all such access points being restored to their current condition following construction;
  • All temporary access points and equipment travel paths will have erosion protection and sediment controls installed and maintained;
  • Movement and travel of all construction equipment along the route will be confined to the permanent and temporary easement secured prior to beginning construction;
  • Any permanent or temporary clearing proposed by Piedmont within the RLSNA will occur within the existing TVA easement where much of the land has already been cleared by TVA;
  • Absolutely no herbicides will be used in conjunction with any clearing within the right-of-way (TVA easement);
  • No burning is proposed or will be permitted;
  • Disturbed areas will be restored to original grades as found prior to construction;
  • Use of a qualified third party to monitor water quality and conduct analyses associated with the pipeline installation through RLSNA;
  • Enlistment of arborists and landscape architects to inspect and report on the health of plantings and guide caretakers in order to maximize the survivability of restorative plantings.

How else is Piedmont addressing the environmental impacts of the proposed pipeline route through RLSNA?

Piedmont has engaged biologists to survey and examine the proposed pipeline route through RLSNA with respect to streams, wet weather conveyances, seeps, springs, sinks, wetlands, glades, rate species, and associated habitats.  Information on rare species known to occur in the general project area was also obtained from TDEC’s Division of Natural Areas and from the Tennessee Wildlife Resources Commission.  The U.S. Fish and Wildlife Service (USFWS) was also contacted regarding the project.  Radnor Lake State Natural Area management was consulted regarding sensitive environmental areas and rare species known to be present in the area. Through TRC Environmental Corporation (TRC), Piedmont has also had preliminary background research conducted with respect to previously recorded significant cultural resources (archaeological, architectural, and historic sites) which might pose challenges in developing the project area.  Further detail about these efforts may be found in Piedmont’s formal filing with TDEC.

How long would construction of the pipeline on Radnor Lake property take and would it impact visitors to the property?

While an exact schedule concerning the construction of the pipeline has not yet been determined, construction and stabilization activities are not expected to exceed six months.  We would work closely with TDEC and Radnor Lake staff to find a start date that meets the unique requirements of RLSNA and addresses Piedmont’s needs for the pipeline’s “in-service” date toward the end of 2013.

How will Piedmont’s application be reviewed and when will a decision be made?

Piedmont’s application will be reviewed by the Tennessee Department of Environment and Conservation (TDEC).  The state, as owner of the Radnor Lake State Natural Area, will make the final decision as to whether Piedmont’s application will be accepted.  The precise timeline for that decision has not been determined at this time.

Formal TDEC Filing (pdf)

TDEC Exhibits (pdf)

A copy of the full submittal document is available for inspection at the Radnor Lake Visitor Center during business hours.

About Piedmont Natural Gas
Piedmont Natural Gas is an energy services company primarily engaged in the distribution of natural gas to more than one million residential, commercial, industrial and power generation utility customers in portions of North Carolina, South Carolina and Tennessee, including 52,400 customers served by municipalities who are wholesale customers. Our subsidiaries are invested in joint venture, energy-related businesses, including unregulated retail natural gas marketing, and regulated interstate natural gas transportation and storage and intrastate natural gas transportation businesses. More information about Piedmont Natural Gas is available on the Internet at