Cheryl Lafleur, Chairman Federal Energy Regulatory Commission 888 First Street, NE Washington, D.C

COUNTYOF AUGUSTA,VA. BOARDOF SUPERVISORS MARSHALLW.PAInE LARRYJ.WILLS North River Middle River

TRACYC. PYLES,JR. JEFFREYA. MOORE Pastures DAVIDA. KARAFFA Wayne Beverloy Manor

MICHAELL.SHULL CAROLYNS. BRAGG PATRICKJ. COFFIELD— COUNTYADMINISTRATOR Rivorhoads South River AUGUSTACOUNTYGOVERNMENTCENTER P.O. BOX590, VERONA,VA 24482-0590 March 30, 2015 (540) 245-5610 FAX(540) 245-5521 [email protected] Cheryl LaFleur, Chairman Federal Energy Regulatory Commission 888 First Street, NE Washington, D.C. 20426

Re: Docket No. PF 15-6

Dear Chairman LaFleur:

On behalf of the Augusta County Board of Supervisors, I respectfully submit these comments to the Federal Energy Regulatory Commission (FERC) on the proposed Atlantic Coast Pipeline project (Docket No. PF1 5-6). The Atlantic Coast Pipeline proposed to be installed through Augusta County is obviously a significant issue sparking a number of concerns for citizens and county leaders. The pipeline is concerning to the County both in terms of the short term and long term impacts the proposed pipeline may have on current residents, as well as future generations. This is of the utmost importance to elected officials and the citizens of the County alike and we appreciate the opportunity to provide input into the environmental review process.

The pipeline is proposed to run approximately 43 miles through the County, making Augusta County the jurisdiction most impacted by this route. To better understand the potential impacts of the pipeline, the Augusta County Board of Supervisors embarked on an extensive study process to seek input from staff, citizens, and experts to evaluate potential impacts of the pipeline. As part of the effort, the Board of Supervisors asked the county staff to prepare a staff report on this project, much like they would for a rezoning of land for a development project. Comments were received from the Virginia Department of Health, the Virginia Department of Transportation, the Augusta County Service Authority, and County Departments including Fire/Rescue, Economic Development, Engineering, Planning, and Zoning. The Augusta County Planning Commission also provided comments to the Board on the proposed pipeline route and its potential impacts on land use and development in the county. Attached as part of this submittal is a copy of the Staff Report. In addition, on February 4, 2015, the Board held a public hearing to receive comments, both pro and con, on the pipeline. The public hearing was attended by nearly 300 people and included 36 speakers. In addition to those speaking at the public hearing, the Board also accepted written comments on the proposed project. A Summary of Comments from the public process was prepared by Staff and is included as part of this submittal as well.

1 Cheryl LaFleur, Chairman March 30, 2015 Page 2

From the above described effort, the County has identified concerns that can be grouped into six (6) general areas. For each area, key points are raised, with supplemental information submitted for further study and consideration by the Federal Energy and Regulatory Commission.

Karst: Augusta County is underlain with karst geology. A significant portion of the current routes proposed for the pipeline run through karst areas. The Augusta County Service Authority relies on numerous high-yield karst wells and springs to supply drinking water to over 40,000 customers with over 15,000 connections. The Augusta County Service Authority contracted with Emery & Garrett Groundwater Investigations, LLC (EGGI) to study the potential risks to the Service Authority’s water supply production wells, springs, and infrastructure posed by the construction and operation of a high pressure natural gas pipeline through the county. Their study, a copy of which is submitted with these comments, states “While karst features in carbonate rocks present opportunities for the development of significant groundwater supplies, such features also present challenges with respect to groundwater protection.” Contaminants can quickly enter the groundwater system, sinkhole development can impact water supply infrastructure, and there can be an increase in groundwater turbidity, any of which can put at risk the water supply and distribution system of the Service Authority. The Study recommends ‘the best strategy to protect these critical groundwater resources is to avoid pipeline construction development and operation in designated sensitive water supply areas such as exist in: a) the wellhead protection and groundwater recharge areas, b) close proximity to public supply wells and springs, and c) those areas that have been identified as favorable for the future development of public groundwater supplies.” While the EGGI study focused on public water supplies, the same concerns hold true for the private water supplies of countless county residents, where no public water system exists as a back-up.

Headwaters: Augusta County is uniquely situated as a headwaters zone providing water not only for county residents and businesses, but also for cities and counties downgradient from Augusta County. The impacts on county water supplies from the pipeline, both during construction and in the event of a leak/failure after it becomes operational, are critical concerns. While you will see mention of Augusta County being a headwaters in many of the comments coming from county residents, the question is how much of an impact would a threat to the water leaving the county have on others in the region. Augusta County commissioned a study by Sullivan International Group, Inc. to quantify the annual water volume being contributed from Augusta County to adjoining counties and to conduct an assessment of risks associated with the construction of the proposed Atlantic Coast Pipeline. A copy of the report is submitted to FERC as part of these comments. Based on the results of their study, which estimated volumes under both average and drought precipitation conditions, Sullivan estimates that between 173,612 Mgal/year (million gallons per year) and 273,251 Mgal/year are contributed to

2 Cheryl LaFleur, Chairman March 30, 2015 Page 3 adjoining counties on an annual basis via groundwater flow and streamfiow from Augusta County.

The Sullivan report includes an assessment of risks posed by pipeline construction. The report identifies several potential risk conditions that could potentially impact Augusta County’s groundwater and surface water resources. Those risk conditions include water quality; water yield: dam safety, and occurrence of bedrock outcrops, shallow bedrock, and karst terrain. Again, these risk conditions hold true for both public and private water supplies. Sensitive Area maps were developed by Sullivan which depict sensitive areas in proximity to the proposed pipeline corridor.

According to the Sullivan report, The findings of this study highlight the quantity and value of water resources originating within Augusta County and identify potential risks to the county’s water resources associated with pipeline construction. These findings demonstrate the importance and necessity for groundwater protection planning during any pipeline construction within Augusta County. This planning should include the formulation of a monitoring plan designed to identify impacts to water resources as a result of pipeline construction activities. Mitigation plans should also be formulated to address and remedy any impacts resulting from pipeline construction activities.

Land Use: The impacts to future land use in the county are extensive due to the size of the impacted area from the construction of the Atlantic Coast Pipeline. The proposed pipeline goes through most of the County’s zoning districts and all four of the Planning Policy Areas identified in the County’s Comprehensive Plan. Taxpayers have invested millions of dollars in infrastructure and planning in our growth areas and this investment needs to be taken into consideration and protected when deciding the location, thickness and depth of the pipeline. In our growth areas, future roads, water and sewer, and other utility infrastructure need to be able to cross the pipeline to facilitate the development planned for the County. If built, the County encourages the pipeline to be installed in areas that have the least negative impacts, specifically, the Board asks that the pipeline be installed away from developed areas (both existing and proposed), schools, and future economic development sites. In addition, the County recommends the pipeline be routed to minimize the impacts to individual parcels by using property lines and not going through the center of parcels.

Blasting: Blasting is another concern shared by county residents, the Augusta County Service Authority, and Headwaters Soil and Water Conservation District. The concerns regarding the impact of blasting include the potential to adversely impact water quality in public and private wells, a decrease in yield in wells and springs, and the integrity of the flood control structures. Headwaters Soil and Water Conservation District has requested,

3 Cheryl LaFleur, Chairman March 30, 2015 Page 4 and Augusta County concurs, that blasting be prohibited within ¼ mile of any flood control 34 dam and any blasting between and 1 % mile of a dam be required to have a monitoring plan to ensure that there is no negative impact on the dams. The Emery & Garrett Groundwater Investigations, LLC (EGGI) study included the identification of the potential risks to the Service Authority’s water supply production wells, springs, and infrastructure posed by the construction and operation of a high pressure natural gas pipeline through the county. Their study identifies the concerns with blasting in regards to the County’s groundwater resources. The study echoes the concerns of the Sullivan Report in terms of the potential impact of the pipeline to water quality and diminished well yields. EGGI recommends that a legally binding Construction Management and Blasting Plan be put in place and agreed to by the Augusta County Service Authority, Augusta County, and Dominion Power and their contractors for this project. The Plan should include a Groundwater Monitoring Plan to establish the “existing conditions” prior to the start of construction. These studies as well as Augusta County also recommend the development of an Operation Plan and a Mitigation Plan to protect the investments the Augusta County Service Authority has made in the public water supply.

High Consequence Area: Ifa route through Augusta County is chosen, Augusta County officially requests to be designated a High Consequence Area (HCA) as defined by the U.S. Department of Transportation Pipeline and Hazardous Material Safety Administration for the entire route of the pipeline through the county. It is our understanding that identification of HCAs for hazardous liquid pipelines focus on populated areas, drinking water sources, and unusually sensitive ecological resources. It is our opinion that Augusta County meets these criteria and the county should be declared a High Consequence Area for the entire route of any pipeline proposed to be built in Augusta County. Maps to support the designation of the County as a High Consequence Area are included as part of this submittal.

Extension of public comment period: While we understand that the pipeline route is not yet finalized and you have to start and stop the comment someplace, we would ask that the comment period be extended. There was a fairly major alternate to the route recently announced for the LyndhurstlSherando area of the county. Approximately 90 new county landowners are impacted by this proposed reroute. Many of these property owners are just now receiving their official letters and have not yet had an opportunity to talk to the representatives of Dominion face to face, other than at an open house held last Tuesday in Nelson County. With that in mind, we would ask on their behalf, that FERC extend the public comment period past the current April 28th deadline to allow those citizens the right to be fully informed about the project and its proposed impacts to their properties and provide their comments to you.

Thank you again for giving us the opportunity to participate in the Environmental Review Process for the proposed Atlantic Coast Pipeline. Recognizing the unique issues of the

4 Cheryl LaFleur, Chairman March 30, 2015 Page 5 pipeline to Augusta County, the Board appreciates the opportunity to participate in this process, and as such formally requests to be a cooperating agency, specifically with our expertise in county land use and public safety issues, In addition, the Augusta County Service Authority willalso be requesting to participate as a cooperating agency with their expertise in water resources. We look forward to working with FERC throughout this process.

Sincerely, /

Michael L. ShuIl, Chairman Augusta County Board of Supervisors

5 COUNTY OF AUGUSTA STAFF REPORT ATLANTIC COAST PIPELINE PROJECT FEBRUARY 4, 2015

BACKGROUND: Community Development Department Staff was asked to prepare a report including comments from various federal, state, and local agencies and departments on the potential impact of the proposed Atlantic Coast Pipeline. Staff from various agencies viewed the pipeline route with representatives of Dominion in December of 2014, prior to providing comments. The purpose of this report is to provide additional information to the Board of Supervisors prior to their providing comments to the Federal Energy Regulatory Commission on the proposed pipeline route through the county.

SUMMARY OF REQUEST: The Atlantic Coast Pipeline is a natural gas pipeline proposed to be constructed from West Virginia to North Carolina, traveling through approximately 43 miles of Augusta County. Dominion, along with Duke Energy, Piedmont Natural Gas and AGL Resources, formed a joint venture to build and own the proposed Atlantic Coast Pipeline. Current plans for the proposed project call for a 75’ permanent and 125’ temporary construction easement along the length of the route. The steel pipe will be 42” in diameter and will have a minimum of 3’ of cover in most areas, but 5’ under streams. The capacity of the pipeline is projected to be 1.5 billion cubic feet/day.

COMMENTS FROM ACSA: The Augusta County Service Authority has reviewed the request for comments regarding the proposed Dominion Transmission, Inc. (DTI) pipeline. At this time, the Service Authority understands that the final pipeline route has not been determined. Based on preliminary routing provided, the Authority has the following comments:

1. The proposed route passes through and is very close to some existing groundwater recharge areas and future water exploration areas. (Note that a portion of the recharge area for Staunton’s Gardener Springs is affected by the route and the drainage basin for the Staunton Dam may also be affected. The Service Authority purchases water from the City for customers in certain service areas). These karst areas can be sensitive to construction activities. In a prior meeting DTI agreed to provide a written response to the specific concerns outlined in the report prepared by EGGI regarding construction management and blasting plans, an operation plan, and mitigation plans with bonding (or an escrow account) to address issues that may arise during the pipeline project.

2. The proposed route is located near to and in one small area on the Augusta County Landfill property. Any underground disturbance that causes gas/groundwater violations could cost in excess of $1M to

mitigate. The Service Authority has requested that DTI provide a written response to this in their mitigation and bonding plans.

3. The proposed pipeline would cross existing Service Authority water and sewer pipelines. In a prior meeting, DTI agreed to provide a more specific document regarding impacts and requirements for the Service Authority when working in DTI right-of-way. During the meeting, DTI noted that many of the requirements of the document originally provided (“Guidelines for Construction Activities on Rights-of-Way and in the Vicinity of Dominion Transmission, Inc. Pipelines”) do not apply to the Service Authority. There were several specific items that are expected to be addressed:

a) The portion of the document noting that “despite any agreement” the owner of any other line could be required to remove its line at no cost to DTI. b) The portion of the document that notes DTI will not replace any pavement removed during its construction or maintenance activities. c) Clarification on the process for getting construction and maintenance work approved within the DTI right-of-way and what documents are required. d) Rock removal by chemical breaking allowed in the right-of-way? e) The Service Authority is opposed to signing indemnification clauses. f) A copy of the proposed easement language is requested. g) The Service Authority requested that DTI provide plans for each crossing just as DTI requests of the Service Authority. h) Will the Service Authority be required to name DTI as an additional insured party for the crossings or is proof of insurance all that is needed?

COMMENTS FROM BLUE RIDGE PARKWAY: No Comments Received

COMMENTS FROM ECONOMIC DEVELOPMENT DIRECTOR: If the pipeline is approved as currently planned, it would bisect several key sites that are planned industrial and/or commercial sites, as indicated in the County’s comprehensive plan, thus significantly reducing the development potential of those sites. These key sites include parcels owned by MEG LLC (074-144), Sunrise Investors Inc (ID 084-122-A) and surrounding/adjacent properties as illustrated on the attached exhibits, and collectively Alphonso Boxley (ID 085-61), Orvin Kiser (ID 085-62) James Brenneman (ID 085-63 and 085-63A-E), and Cedar Bluff Inc (ID 085-68 and 085-68F, G, J, K). It would benefit the property owners of these sites as well as all the citizens of Augusta County who benefit from capital investment and new job creation if the development potential of these key sites is preserved. (See attached exhibits for reference.)

If the pipeline is approved, long-term economic benefit to Augusta County is only achieved with taps located at strategic locations in Augusta County.

COMMENTS FROM ENGINEER: The project lies within the following watersheds that have identified water quality impairments. The applicant is advised to research the applicable TMDLs and design accordingly. In addition, there may be opportunities to provide voluntary water quality treatment in conjunction with any channel protection or flood protection measures that may be required.

Moffett Creek Portions of the project drain to Moffett Creek which is listed on the Virginia DEQ 2012 and DRAFT 2014 Impaired Waters List. This impaired segment extends from the headwaters downstream to its confluence with Middle River. The impaired uses are recreation and aquatic life, the specific impairments are E. Coli, fecal coliform bacteria and the general benthics standard. The source is wildlife other than waterfowl for the bacterial impairments and unknown for the benthics impairment. TMDLs have been approved for this segment and must be considered by the applicant (Federal TMDL ID # 7679).

Elk Run Portions of the project drain to Elk Run which is listed on the Virginia DEQ 2012 and DRAFT 2014 Impaired Waters List. This impaired segment extends from the headwaters downstream to its confluence with Moffett Creek. The impaired use is recreation, the specific impairments are E. Coli and fecal coliform bacteria. The sources are agriculture, non-point sources and wildlife other than waterfowl. This segment is within the geographical region covered by the TMDL for Moffett Creek which must be considered by the applicant (Federal TMDL ID # 7679).

Middle River (HW to Jennings Branch) Portions of the project drain to Middle River which is listed on the Virginia DEQ 2012 and DRAFT 2014 Impaired Waters List. This impaired segment extends from its headwaters downstream to its confluence with Jennings Branch. The impaired uses are recreation and aquatic life, the specific impairments are violations of the General Benthics standard, Fecal Coliform and E. Coli, the likely sources are unknown for the General Benthics impairment and Agriculture, Non- Point sources, and wildlife other than waterfowl for the bacterial impairments. TMDLs have been approved for this segment and must be considered by the applicant (Federal TMDL ID # 24511).

Eidson Creek Portions of the project drain to Eidson Creek which is listed on the Virginia DEQ 2012 and DRAFT 2014 Impaired Waters List. This impaired segment extends from the headwaters downstream to its confluence with Middle River. The impaired use is recreation, the specific impairments are E. Coli and fecal coliform

3 bacteria. The sources are non-point sources and wildlife other than waterfowl. This segment is within the geographical region covered by the TMDL for Middle River which must be considered by the applicant (Federal TMDL ID # 7683).

Lewis Creek Portions of the project drain to Lewis Creek which is listed on the Virginia DEQ 2012 and DRAFT 2014 Impaired Waters List. This impaired segment extends from south of the Staunton City boundary near the power line crossing downstream to its confluence with Middle River. The impaired uses are recreation, aquatic life and fish consumption, the specific impairments are E. Coli, General Benthics standard, and PCBs in fish tissue. The sources are municipal (Urbanized High Density Area), non-point sources, and wildlife other than waterfowl for the E. Coli impairment, non-point sources for the benthic impairment, and inappropriate waste disposal and municipal (Urbanized High Density Area) for the fish consumption impairment. TMDLs are approved for the bacterial and benthic impairments and must be considered by the applicant (Federal TMDL ID # 7677 and Federal TMDL ID # 7676).

Folly Mills Creek Portions of the project drain to Folly Mills Creek which is listed on the Virginia DEQ 2012 and DRAFT 2014 Impaired Waters List. This impaired segment, including tributary, extends from the headwaters downstream to its confluence with Christians Creek. The impaired use is recreation, the specific impairment is E. Coli and fecal coliform. The sources are non-point sources and wildlife other than waterfowl. This segment is within the geographical region covered by the TMDL for Christians Creek which must be considered by the applicant. (Federal TMDL ID # 17969).

Christians Creek Portions of the project drain to Christians Creek which is listed on the Virginia DEQ 2012 and DRAFT 2014 Impaired Waters List. This impaired segment extends from the headwaters downstream to its confluence with Middle River. The impaired uses are recreation and aquatic life, the specific impairments are E. Coli, fecal coliform and violations of the general benthics standard. The sources are municipal (Urbanized High Density Area), non-point sources and wildlife other than waterfowl. TMDLs are approved for the bacterial and benthic impairments and must be considered by the applicant. This segment is included in the EPA approved Christians Creek benthic TMDL (Federal TMDL ID # 24514) and the EPA approved Christians Creek bacteria TMDL (Federal TMDL ID # 9480).

South River (Stony Run to North River) Portions of the project drain to South River which is listed on the Virginia DEQ 2012 and DRAFT 2014 Impaired Waters List. This impaired segment extends from the confluence with Stony Creek downstream to its confluence with the North River. The impaired use is recreation, the specific impairments are E. Coli

4 and fecal coliform bacteria. The sources are agriculture, non-point sources and wildlife other than waterfowl. This segment is included in the bacterial TMDL for South River which must be considered by the applicant (Federal TMDL ID # 38140).

Back Creek Portions of the project drain to Back Creek which is listed on the Virginia DEQ 2012 and DRAFT 2014 Impaired Waters List. This impaired segment extends from the headwaters downstream to its confluence with South River. The impaired uses are recreation and aquatic life, the specific impairments are E. Coli and violation of the general standard for benthics. The source(s) are Wildlife other than Waterfowl, non-point sources, and Agriculture for the bacterial impairment, and unknown for the benthics impairment.

In addition to being listed on the DEQ Impaired Water lists, the 2007 Augusta County Comprehensive Plan lists the Jennings Branch, Middle River – Bell Creek, Christians Creek – Folly Mills Creek, South River – Canada Run, and Back Creek – Inch Branch watersheds, all of which are crossed by this project, as Priority Watersheds for Groundwater Protection due to the presence of karst features and the location of Source Water Assessment Program zones. Water quality treatment is recommended.

It is our understanding from Virginia DEQ central office that the proposed pipeline project is not subject to Virginia Stormwater Management Program (VSMP) requirements. Regardless of the applicability, the project will have an impact on both impaired and non-impaired streams in Augusta County. Dominion has filed annual standards with DEQ for Erosion Control and will be subject to inspections by Virginia DEQ on this project. With respect to water quantity, all points of discharge must comply with the Adequate Channel provisions of 9VAC25-840-40 subdivision 19.

Drainage calculations for any areas with identified karst features in the watershed should conform to Appendix 6-B, “Stormwater Design Guidelines for Karst Terrain in Virginia”, of the Virginia Stormwater Management Handbook. Installation of certain BMPs is prohibited or discouraged in karst areas depending on the practice.

If the project were subject to the VSMP, with respect to water quality, in Virginia’s Runoff Reduction Method, maintained utility Rights of Way are treated the same as Forested Land in water quality calculations. Therefore, as long as there are no impervious areas and the R/W is bush hogged no more than 4 times per year, there will be little impact from a regulatory water quality perspective. If roadways or other impervious areas are constructed along the route, the project is encouraged to voluntarily follow the VSMP requirements.

Dominion is advised to contact the Virginia Marine Resources Commission, the U.S. Army Corps of Engineers and the Virginia Department of Environmental Quality for any requirements related to proposed work in wetland areas or adjacent to any streams.

Portions of the project are within the boundaries of Area 2 of the Source Water Protection Overlay (SWPO) District. In addition to the requirements of the Source Water Protection Overlay ordinance, for Source Water & Recharge Areas, the Comprehensive Plan recommends restriction of land uses that pose a contaminant threat. Additionally, the Comprehensive Plan recommends that stormwater practices that infiltrate or can contaminate groundwater should be avoided in these areas; water quality treatment and revegetation are recommended.

Portions of this property lie within Zones A and AE on the FEMA FIRM. Any development in these floodplain areas must meet the provisions of the Floodplain Overlay Ordinance. Placement of fill in these areas, even temporary placement of excavated material during construction, is not permitted. At grade access roadways are permitted and should be stabilized with large size stone to limit erosion.

Along the length of the 300 ft. wide study corridor through Augusta County, approximately 11% (168.8 acres) of the potentially impacted soils are considered Prime Farmland and 35% (545 acres) are considered Soils of Statewide Importance. Care should be taken, especially in active farming areas, to ensure that topsoil depth is maintained along the corridor. It is anticipated that considerable spoils areas will be required. If spoils areas are located outside of the corridor, separate Erosion and Sediment Control plans will be required for these disposal or fill sites.

Natural Resources Recommendations from the Comprehensive Plan

Urban Service and Community Development Areas

The 2007 Augusta County Comprehensive Plan recommends performance standards to protect natural resources. For Urban Service and Community Development Areas, a riparian buffer of 35 feet on either side of a stream is encouraged, and where feasible, stormwater should not be piped through in a manner to short-cut the buffer. Additionally, floodplain areas should have no habitable structures, but should instead be utilized for greenways & recreation areas.

In Urban Service and Community Development Areas, the Comprehensive Plan recommends avoidance of slopes >25%, especially associated with stream valleys. For Wetland areas, the Comprehensive Plan recommends provision of a 35 foot buffer from the edge of wetlands.

For unique natural features such as caves, major karst features, critical habitats, etc., the Comprehensive Plan recommends to tie these features in with greenways, active and passive recreation areas and flood plain preservation areas.

Rural Conservation and Agricultural Conservation Areas For Rural Conservation and Agricultural Conservation Areas, a riparian buffer of 100 feet on either side of a stream or the limit of the floodplain (wider of the two) is encouraged, and stormwater should not be piped through in a manner to short- cut the buffer. Additionally, there should be no development or filling in floodplain areas. Small-scale trails (in the Rural Conservation Areas only) and reforestation are encouraged.

In Rural Conservation Areas, the Comprehensive Plan recommends that slopes >25% and ridgelines be set aside through cluster design. In Agricultural Conservation Areas, the Comprehensive Plan recommends no grading, roads or building sites on slopes >25% and ridgelines.

For Wetland areas, the Comprehensive Plan recommends provision of a 100 foot buffer from the edge of wetlands and enhanced water quality treatment for any water discharging to the wetlands.

For unique natural features such as caves, major karst features, critical habitats, etc., the Comprehensive Plan recommends use of cluster design to protect the features to the extent achievable, as well as protecting active agricultural and forestry uses in Rural Conservation Areas and maximizing continued use of active agricultural and forestry areas in Agricultural Conservation Areas.

COMMENTS FROM GEORGE WASHINGTON NATIONAL FOREST: No Comments Received

COMMENTS FROM HEALTH DEPARTMENT: It appears the vast majority of the route will pass through forested and agriculture land. This should avoid most encounters with private water supplies and sewage disposal systems. There does not appear to be many residences in close proximity that could be affected by the pipeline route; however, any actual impact will be determined once the survey and precise location is complete and installation is in progress. Because of the age of some of the residences and lack of records, it is difficult, if not impossible, to determine the actual location of all water supplies, conveyance lines and sewage disposal systems. Any modification, repair, relocation or installation of a private well or sewage disposal system will require a permit from the local health department if encountered.

COMMENTS FROM FIRE-RESCUE: In looking at the impact that the proposed pipeline would have with regard to public safety, the Augusta County Fire-

Rescue Department and Emergency Management Coordinator provides the following:

There are pipelines already in Augusta County and Fire Rescue personnel have been trained in pipeline events and responded to these types of emergencies in the past. There will be a need for updated training, education, and procedure review for agencies in areas that previously did not have these in their first due response areas.

Regarding an Emergency Response concerning a leak or major disaster, we would look to work collectively with Dominion Power through a Unified Command System in mitigating the event and would rely on their having the ability to respond with adequate resources in a timely manner.

COMMENTS FROM SCHOOL BOARD STAFF: The pathway of the proposed pipeline comes relatively close to three (3) different school complexes, which involves a total of six (6) schools having a student population of approximately 3,310 students. The table below is an indication of this situation.

SCHOOLS # OF STUDENTS # OF EMPLOYEES

Beverley Manor 370 50 Elementary Churchville Elementary 730 90 Beverley Manor Middle 300 50 Stuarts Draft Elementary 680 90 Stuarts Draft Middle 530 80 Stuarts Draft High 700 90 TOTAL 3310 450

The proposed pipeline will run approximately (.8) of a mile east of Churchville Elementary; (.8) of a mile west of the Beverley Manor Middle and Beverley Manor Elementary School complex; and (.5) of a mile west of Stuarts Draft High, (.5) of a mile south of Stuarts Draft Middle, and (.6) of a mile west and south of Stuarts Draft Elementary.

Naturally, school division personnel are concerned with the safety of all our students, parents, and our employees. The close proximity of the project is certainly a safety concern for each of these school facilities.

Should this project come to fruition, planning with Emergency Service personnel would be a high priority. Specific safety procedures will need to be established and put into operation. Such plans and procedures should be mutually developed, examined, and approved with all stakeholders and have the confidence that a potential safety hazard will be avoided.

Finally, another concern deals with the construction phase for the proposed project. Although specific construction information has not been shared, transporting students from their home to school destinations could possibly be cumbersome. The school division would request the ability to provide input into this phase to assure arrival and departure times to and from schools would be closely monitored. The objective of the request is to avoid and possibly eliminate anticipated delays due to the increased construction. It would be essential and advantageous to all stakeholders that the school division’s administrative and transportation departments would be involved during the initial planning stages.

Please realize the Augusta County Public Schools are committed to fully cooperate in this project. Feel free to contact my office should additional input or information be needed.

COMMENTS FROM SHENANDOAH NATIONAL PARK: No Comments Received

COMMENTS FROM VDOT: Based off of the proposed Dominion Pipeline tour on December 15, 2014, VDOT is providing the following comments and/or concerns regarding the project: 1. VDOT understands that the proposed 42” pipeline will be transversely crossing a large number of state maintained roadways having varying functional classifications from local gravel roads to Interstate highway. No longitudinal installations within VDOT right-of-way are proposed. All crossings are expected to be bored under the roadway. Open-cuts will be considered on a case-by-case basis on local gravel roads. 2. VDOT expects the construction traffic to be similar to the recent Dominion transmission line projects. As we learned during those projects, a large amount of heavy construction traffic will be required on low-volume roadways that are not intended for heavy traffic. VDOT will encourage construction traffic during the better construction seasons to hopefully prevent unnecessary damage to the existing state maintained roadways. VDOT will also inventory the condition of the roads before and after the project. Dominion has voluntarily worked with VDOT in the past to help with the maintenance of certain roadways affected by their project. 3. Work on VDOT right-of-way requires a VDOT land use permit from our office. Such work includes, but may not be limited to, construction entrances, permanent entrances, pipeline crossings, and maintenance of traffic operations. 4. Some construction entrances that are built for the pipeline installation may be negotiated to remain in place as a field or private entrance for the property owner (most will simply be removed). If this is planned, VDOT needs to be made aware at the time of reviewing the construction entrance locations. Also, the entrance will need to be re-permitted in the Owner’s name at the conclusion of construction.

5. The pipeline does not appear to encroach on any planned major road project limits. However, this will be evaluated in more detail at time of plan review and permit application.

COMMENTS FROM ZONING ADMINISTRATOR: The proposed Dominion - Atlantic Coast natural gas pipeline that would be constructed through Augusta County is a public utility distribution line which is permitted in all districts by Section 25-20 of the Augusta County Zoning Ordinance. The natural terrain of Augusta County may present some challenges to an underground pipeline considering its many elevation changes and occasional rock formations that may require drilling, chipping, and blasting in order to obtain the required depth of the pipeline. Property owners along the route may be impacted during the excavation and construction process by traffic congestion, noise, lights, dust, odor, fumes and vibration. The majority of the proposed route appears to be through farm and crop land, however, zoning would recommend the following conditions in order to mitigate potential impacts: (1) that best management practices be followed at all times, (2) the pipeline be located as far from homes, schools and businesses as possible, and (3) that there be “daytime only” operations and limited hours of drilling, chipping, and blasting when construction is in close proximity to homes.

COMMENTS FROM PLANNING COMMISSION: The proposed pipeline goes through most of the County’s zoning districts. Development associated with the zoning of the properties, other than General Agriculture, should be expected and accommodated during construction. However, approximately 95% of the County remains zoned General Agriculture, so in order to determine the expected land uses on property zoned General Agriculture, you must look to the Comprehensive Plan Planning Policy Area and Future Land Use Maps for guidance. The proposed pipeline goes through all four Planning Policy Areas of the County’s Comprehensive Plan. Specifically, the goals of the Planning Policy Areas and expected land uses can be summarized as follows:

Agriculture Conservation Areas: The goal is to keep agriculture the primary use in this Policy Area. Accommodations to ensure that the land remains viable farmland are encouraged.

Rural Conservation Areas: The goal is to keep agriculture the primary use in the Policy Area, but to accommodate small amounts of future rural residential development. Where the pipeline goes through Rural Conservation Areas and is adjacent to existing residential development (whether zoned Rural Residential or developed through the provisions of the County’s Zoning Ordinance governing General Agriculture zoning), accommodations should be made to support rural residential development along the pipeline route, while at the same time ensuring the farmland remains productive.

Community Development Areas: These areas are areas currently served by public water or expected to have public water extended to them as part of the development process over the next 20 years. In most cases, the future land use expected in these areas is low density residential development with a minimum lot size of 1 acre and an overall density of one dwelling per 2 acres. Development of these areas is anticipated and should be planned for.

Urban Service Areas: Urban Service Areas are the County’s primary growth areas and the areas where the County wants to see most of its future commercial and industrial development and at least 80% of its future residential development. The proposed pipeline route goes through several of the County’s Urban Service Areas and include areas that are planned for medium density (3-4 units per acre) and attached residential development (4-8 units per acre), business and industrial development, and mixed use development. Development of these areas is anticipated and should be planned for. The infrastructure has been put in place to support higher density residential development and commercial and industrial uses. If the pipeline is constructed through the County’s development areas, the pipe should be sized and buried as if these areas were already developed rather than assuming they will stay in agriculture and low density residential use. In addition, the pipeline route should accommodate existing development plans, if already approved by the County, or follow property lines as much as possible to minimize the impact on development. The County’s Comprehensive Plan also calls for numerous road improvements to accommodate the expected development. Road projects recommended by the Planning Commission as part of the County’s Comprehensive Plan Update in November 2014 should be taken into consideration during the planning, and any building of the pipeline. The County has invested in the road, water, sewer, and school infrastructure to support development in these areas and that public investment needs to be protected if at all possible, even if the private property owners are compensated.

Ninety-five percent (95%) of Augusta County is zoned General Agriculture. General Agriculture is a legitimate land use and needs to be protected, but there are other plans for much of this property as outlined in the County Comprehensive Plan for the next 20 years and beyond. Taxpayers have invested large amounts in infrastructure and planning and this needs to be taken into consideration and protected when deciding the location, thickness and depth of the pipeline. The Comprehensive Plan needs to be followed and roads, water and sewer need to be able to cross the pipeline. Site the pipeline to make minimum impacts to individual parcels by using property lines and not going through the center of parcels. Further, as a Planning Commission and County government we can address the planning of our community with things we have control over, but we don’t include things like pipelines. We expect agencies that have in their mandate to manage how the pipeline will impact our community to do their jobs. We recommend to the Board of Supervisors that they insist that the agencies do their jobs.

WEBSITE REFERENCES: Additional Information can be obtained from the following resources: https://www.dom.com/corporate/what-we-do/natural-gas/atlantic-coast-pipeline http://augustacountyalliance.org/

SUMMARY OF PIPELINE COMMENTS

Concern about the impact of the pipeline is both short-term (during construction) and long-term (the life of the project). Staff would recommend submitting the entire staff report, along with accompanying maps, to FERC as part of any comments that are officially submitted. Key areas of concern, along with specific points raised during the hearing and in subsequent written comments, are listed below and may be helpful to the Board as they consider additional comments they wish to transmit to FERC.

Environmental-

Tree removal in the National Forests- destruction and fragmentation, as well as visual impacts; tree removal in areas where trees were planted to stabilize stream banks and steep slopes

Impact on historic structures in pipeline path

Pristine habitat and scenery

Impact on threatened and endangered species

Protect the bald eagles and their habitat

Cutting the swath to put the pipeline in will open area up for invasive plant species

Ensure it doesn’t impact conservation easements or areas designated by the Virginia Outdoors Foundation as “special project areas”

Hire an environmental consultant

Request a full environmental impact review from FERC- develop a comprehensive scoping list with a paid consultant to submit to FERC, more time to review than normal

Request that pipeline decision be delayed to fully study the consequences.

Impact of slope failures; how can they be avoided?

Erosion and Sediment Control-

Ask for Dominion to agree not to seek waivers and variances on this project in terms of compliance with the state’s Erosion and Sediment Control laws. Ask for specific plans to be submitted to County staff for the work they are doing in county.

Headwaters concerned about the impact erosion and sediment could have on dams if not properly controlled.

Karst-

Karst and sinkholes are prevalent in the County

Virginia Hazard Mitigation Plan identifies County as being of highest risk

32 known sinkholes along Dominion’s current proposed route

Dominion has provided no real details in how they will deal with karst during construction; how they will deal with existing sinkholes and new ones that develop during construction

Water Resources-

Ask for a legally binding pipeline construction management and blasting plan (including groundwater monitoring plan), operation plan, and mitigation plan along with funds and an independent board to oversee mitigation compensation.

Headwaters watersheds; flows to the Chesapeake Bay; impact on water resources is more extensive than just on the county.

Ask for pre-construction testing of all public and private water sources within a 1 mile radius of the pipeline corridor.

Headwaters’ dams need to be protected.

Headwaters Soil and Water Conservation Board requests for blasting prohibitions within ¾ of a mile of the dams and monitoring plan for impacts further away.

Scenic-

Impact on the Scenic Route 250 Corridors; Confederate Breastworks on Shenandoah Mountain, Braley Pond Recreation Area, and Humpback Rocks, Appalachian Trail, Great Eastern Trail.

Protect the scenery of the entire county

Economic-

Property values- Concern that property owners will have no use of the land under the easement; will destroy marketability with easement cutting land in two or just the presence of such a large easement on their land. Concerned about the overall value of properties with the pipeline running through them and the impact on county tax revenues.

Several county economic development sites are impacted by the current pipeline route that cuts through these sites

No economic benefit to county, no new jobs.

Negative economic impact due to loss of tourism based on degradation

Safety-

School safety- Stuarts Draft complex, Stump, Churchville

Nursing home safety

General pipeline safety- across the county

National safety concerns if this pipeline carries 2% of the entire national supply of gas? Wouldn’t having more lines with less gas per line be better strategy?

High consequence (death and destruction) is the 1100 feet radius figure; safe evacuation distance of 3650’. Another study- Area of strong impact/high lethality- 1680-3480’; Area of irreversible damage- 2,180-6800’; area of reversible damage- 2590-12,500’. Need to better define the areas of impact due to the location of population, schools, etc.

Too close to population centers- Staunton

Too close to flood control dams

National Transportation Safety Board has adopted more than 2 dozen recommendations for pipeline oversight this year due to significant accidents that have occurred.

Where there are road crossings, what will be the weight limits for vehicles? No clear answer yet, but a concern for normal traffic and also for fire apparatus.

Dominion says they can’t co-locate along the rail lines due to the vibrations, however, the pipeline goes underneath the tracks in several places. Isn’t that a safety concern?

Existing Development and Comprehensive Plan-

Impact on lands designated for economic development in Comp Plan

Impact on planned development of Stone Valley- specifically on rec area

Abide by the Comprehensive Plan

Agriculture-

Farming over pipeline- will it be as productive, can it still be called “organic”

Impact on the hay, etc. for the livestock

Dominion Track Record-

Dominion’s past record in terms of environmental violations during construction; concern about subcontractors who will be doing the work one step removed from Dominion’s promises. Another concern is their creation of subsidiaries to absolve themselves of responsibility if things go wrong.

No experience by Dominion in building a 42” pipeline

Liability for Issues Created During Construction-

Establish a mitigation fund to protect natural resources that may be disturbed and to clean-up and assist with damages from construction mishaps and pipeline failures

If wells are impacted, will property owners outside of the easement area be compensated?

Alternatives-

No attempt to find better route- one that is less destructive or less controversial

Lack of due diligence to attempt to use existing right-of-ways

Co-locate where possible- VDOT, USDOT, etc.

Demonstrated Public Need for the Project-

No evidence of need for this pipeline

Use solar and wind to meet energy needs

Others-

Pipeline is a means to “enable” fracking and its environmental dangers

County should have a full environmental assessment done for the project

If pipeline is approved, need to prepare/revise our hazard mitigation plan to include the pipeline impacts- both short-term (construction) and long-term; such a plan would need to include disaster training

In Favor:

Economic impact to the county and the State of Virginia, as well as neighboring states.

It can be safely installed and not harm the environment. You can build in karst areas and in areas with sinkholes. (VDOT has for years) Trust the engineering professionals and the reviewing federal agencies to protect the county.

Creation of additional jobs- both temporary during construction and more manufacturing businesses attracted to area.

The 100’ wide easement will not harm the vast areas of farmland and wilderness the county has.

Forest Service already has oil and gas leases

Pipeline is needed; Energy independence; eliminate coal as an energy source

Safer than trucking oil and gas through the county.

Address our deteriorating infrastructure

Dominion Response: At the hearing, Dominion indicated they would be submitting a formal response on comments made at the hearing. We contact Dominion 2/11/15 to see the status of that response. They have indicated they are working on a response to the Service Authority questions/report, as well as a response to comments at the public hearing, but the response is not available. Couldn’t give a definitive time when it would be sent to the Board.

Emeiy & Garrett Groundwater In vestigations, LLC 56 Main Street ‘RO. Box 1578 Meredith, New Hampshire 03253 (603) 279-4425 www.eggi.conj FAX (603) 279-8717

October31, 2014

Mr. Ken Fanfoni Augusta County Service Authority 18 Government Center Lane P.O. Box 859 Verona, VA 24482-0859

Dear Ken,

This letter presents Emery & Garrett Groundwater Investigations, LLC’s (EGGI’s) professional opinions and recommendations regarding potential risks to the Augusta County Water Supply Production Wells, Springs, and infrastructure posed by the construction and operation of a high pressure natural gas pipeline by Dominion Power Resources, Inc. (Figure 1). As you know, Augusta County Service Authority (ACSA) (combined with the City of Staunton) provides potable drinking water and wastewater treatment to over 40,000 customers in Augusta County, Virginia. ACSA has invested hundreds of millions of dollars in water supply and wastewater infrastructure to serve the residents of the County. Most of the 1.2 billion gallons of water produced annually by the ACSA comes from high-yield wells and springs located in carbonate karst geologic settings.

The proposed routes for the Dominion Power natural gas pipeline that will go through Augusta County have raised numerous public concerns regarding the security of existing water resources and the potential for adversely impairing the opportunities for developing future groundwater resources that are critical to so many Augusta County residents (Figure 1). It is a recognized responsibility of the County to protect the substantial financial investments made to date by the ACSA as they relate to these potable groundwater supplies and the construction of both water and wastewater infrastructure.

A brief overview of the hydrogeologic setting and the risks associated with the construction and operation of the gas pipeline is provided herein. Recommendations are also provided to the ACSA and Augusta County that would serve to help prevent adverse impacts from occurring as they relate to the installation and operation of this high pressure gas pipeline. ______) _____

Mr. Ken Fanfoni October 31, 2014 Page 2

A. HYDROGEOLOGIC SETTING

The ACSA obtains most of its potable water supplies from wells and springs located in karst settings (Figures 1 and 2). This Photo Inset 1. Open reflects the fact that a significant portion of Augusta County is karst conduit beneath a underlain by carbonate bedrock (i.e., limestone, dolomite, etc.). solution sinkhole.

Dissolution of the carbonate portion of such bedrock (Photo Inset 1) leads to the development of a karst landscape and subsurface karst aquifers. Karst environments are characterized by the presence of sinkholes, internally drained regions, sinking -r and losing streams, large springs, and caves (Figure 2).

While karst features in carbonate rocks present opportunities for the development of significant groundwater supplies, such features also present challenges with respect to groundwater protection. In a karst setting, changes to land use ‘-;E associated with construction and blasting can allow surface water to quickly enter the ground through solution enhanced fractures, conduits, or caves (Photo Inset 1, Figure 2). Such rapid infiltration can occur without the benefit of slow filtering that takes place in non-karst settings where relatively thick soil and complex fracture systems reduce the influx of potential contaminants, including potential pathogens such as bacteria, giardia, and other microparticulates. Other contaminants, such as those related to fuel spills, pesticides, fertilizers, and contaminated stormwater runoff, can also quickly enter the groundwater Photo Inset 2. system when ground conditions Dropout Sinkhole in Augusta County. are altered. As a result, contaminants that enter the groundwater system can -a adversely impact nearby 7t’” Production Wells and Springs rendering them unfit for use.

Another concern associated with impacting karst aquifer systems is that sinkhole development can pose a particular challenge to water supply infrastructure. Some sinkholes in Augusta County develop slowly over the course of thousands of years, but others have formed suddenly in a matter of minutes or days (Photo Inset 2). The latter

Emery & Garrett Groundwater Investigations, LLC _____—

Mr. Ken Fanfoni October 31, 2014 Page 3

type of sinkhole can pose a very substantial hazard to the ACSA’s infrastmcwre and potable groundwater resources.

Wells and springs located within karst aquifers are also susceptible to increases in turbidity that results from the suspension of insoluble residuum of carbonate rock formations (mainly inorganic clays, quartz, and other minerals). Although turbidity is not typically a problem during the normal operation of ACSA Production Wells, land use changes that impact groundwater levels, groundwater flow, or cause changes in hydrostatic pressure within the groundwater system can result in the suspension of the residuum and cause an increase in groundwater turbidity (Figure 2, Photograph 3). Increased turbidity levels in the local groundwater system can impair the potability of public water supply sources.

B. SPECIFIC CONCERNS RELATED TO THE INSTALLATION AND OPERATION OF A NEW HIGH PRESSURE GAS LINE

1) Blasting

The installation of a gas pipeline across Augusta County will necessitate substantial blasting of bedrock where shallow exposures are encountered. Blasting projects generate two primary concerns with respect to groundwater resources: I) they can cause adverse water quality impacts, and 2) they can cause a decrease in yield of nearby wells and springs.

a) Water Quality

Groundwater quality concerns with any blasting project are associated with the introduction of blasting chemicals (or their combustion by-products) into the environment where they can enter the groundwater system and ultimately adversely affect the underlying bedrock aquifer, wells, and springs. Examples of blasting agents (and their byproducts) that are of concern include: nitrate, volatile organic compounds (VOCs), perchlorate, and petroleum hydrocarbons. Blasting can also adversely impact water quality in other ways, such as causing turbidity (suspended particles) to be generated in the groundwater and by modifying rfl% natural groundwater flow paths in ways that change the occurrence of dissolved - - material that is naturally present in the groundwater. Furthermore, blasting in Inset Diagram 1. Example profile of a dropout karst environments can open up fractures sinkhole formed near an excavation site. or other karst conduits allowing the introduction of surface water directly

Emery & Garrett Groundwater Investigations, LLC Mr. Ken Fanfoni October 31, 2014 Page 4 into the aquifer without the benefit of adequate treatment to eliminate pathogens such as E.coli, giardia, and other microparticulates.

Blasting vibrations can also damage the grout and sanitary seals constructed around each Production Well. Compromised sanitary seals can allow surface water and other contaminants to quickly enter the well and underlying aquifer. Presently, the ACSA Production Wells produce water from karst aquifers that are of very high quality. Any adverse impacts to this high quality water could result in very costly treatment remedies.

b) Diminished Well Yields

Blasting induces vibrations into the ground and groundwater system and can result in diminished well yields due to: 1) the collapse of a fracture or well bore (e.g., the infilling by sediment of the water-bearing fracture in a well); 2) permanently lowering water tables; 3) forming sinkholes, particularly where unstable soil arches are present (Photograph 3 on Figure 2). All changes caused by blasting vibrations in the karst system can alter the hydrology of the bedrock aquifer and reduce the yield of wells and springs.

2) Gas Pipeline Construction

Installation of a high pressure gas pipeline involves significant construction activity including land clearing, major trenching and excavating, and activities associated with the assembly of the pipeline and associated infrastructure.

Construction activities pose numerous potential threats to the utilization of the ACSA Production Wells and Springs. These include the following:

• Frequent handling and storage of petroleum products can lead to uncontrolled releases to the environment that result in contamination of underlying groundwater supplies (Field, 1990); • Construction induced vibrations can cause Inset Photo 3 — Pipeline corridor turbidity to occur within the groundwater passes through an area of intense system and within productive wells and sinkhole development proximal to the springs (Langer, 2001); ACSA Lyndhurst Production Well. • Earth disturbance and excavations can change (or concentrate) stormwater flow in new ways that can adversely affect groundwater quality; • Ponding of stormwater in new areas (as a result of construction activities) is a common trigger of sudden sinkhole formation and ground collapse, leading to rapid infiltration of untreated stormwater into the underlying aquifer (Newton, 1987);

Emery & Garrett Groundwater Investigations, LLC Mr. Ken Fanfoni October 31, 2014 Page 5

• Excavation can expose and enhance existing bedrock fractures and or karst conduits that exist at or near the ground surface leading to surface water intrusion into the underlying groundwater system; and • Construction activities can damage existing water utilities, as the proposed natural gas pipeline is expected to cross existing ACSA water mains (and sewer lines) at numerous locations.

3) Operation of High Pressure Gas Pipeline

Although the normal operation of a natural gas pipeline typically presents limited risk to groundwater quality, there are certain events or occurrences that can pose a threat to groundwater resources. Slow, long-term leaks of natural gas that go undetected for long periods of time can result in natural gas entering the karst aquifer system and potentially traveling to springs and wells used for domestic, industrial, or public use. In such a case, indoor degassing of concentrated natural gas from groundwater can result in explosive atmospheres (Crawford, N.C., 1984, and Pennsylvania Department of Environmental Protection, 2009).

Catastrophic pipeline failures are low frequency, high-impact events that have devastating consequences in terms of structural damage and personal injury. Over the past 20 years (1994-20 13), significant gas transmission pipeline accidents in the United States have resulted in over4l fatalities, 195 injuries, and caused $1.6 billion dollars ofproperty damage (Figure 3, Appendix A). A catastrophic leak, explosion or fire can lead to groundwater contamination (and water utility service disruption) due to runoff from fire suppression efforts (Photograph 5, Figure 3) and/or the mass injection of natural gas to the subsurface. In karst terrains, there is an increased risk of a pipeline failure due to the formation of a sinkhole or subsidence that occurs in proximity to the pipeline, wells, and/or springs.

Furthermore, if this proposed pipeline is licensed to carry liquid hydrocarbons (gasoline, crude oil, diesel, or other liquid hydrocarbons) other than natural gas, there is serious concern that a release of one (or more) of these products could result in a significant impact to groundwater quality that renders the groundwater unfit for potable purposes (Figure 3, Photographs 3 and 6). Property losses due to hazardous liquid pipeline incidents are more extensive nationwide than incidents involving gas transmission pipelines even though there are fewer miles of hazardous liquid pipeline (192,396 miles of liquid hydrocarbon pipeline in 2013) compared to gas transmission lines (302,825 miles as of 2013) (PHMSA Website accessed 2014). Over the past 20 years (1994-2013), significant hazardous liquid transmission pipeline accidents have resulted in over 40 fatalities within the United States, 132 injuries, and caused $3.2 billion dollars of property damage (Appendix B). A total of 2.3 million barrels’ of product have been spilled over that 20 year span, with an excess of 119 thousand barrels (nearly S million gallons) spilled as a result of 401 significant incidents just in 2013. Whether the leak is a slow, long-term occurrence, or a sudden catastrophic release, there are numerous cases of groundwater contamination that are often difficult, expensive, and, sometimes, not even feasible to clean up (Delin and Others, 1998). If such an event were to

One barrel of oil is equivalent to 42 gallons.

Emery & Garrett GromnidwaterInvestigations, LLC Mr. Ken Fanfoni October 31, 2014 Page 6 occur within one of the ACSA’s designated groundwater recharge areas (Welihead Protection Area [WHPAI) or proximal to a Production Well (Figure 1), it would be highly disruptive to the ACSA’s water supply.

Another major concern posed by the normal operation of the gas pipeline is that the right- of-way and line crossing requirements could restrict or hamper expansion of the water utility system and potentially restrict development of additional well sites that are necessary to meet hiture water supply demands (Figure 1). Augusta County has seen rapid growth over the past two decades; the population has increased from 54,677 in 1990 to 73,912 people in 2013 (US Census Bureau). The availability’of reliable water resources has been critical to support this growth, and it is vital for ffiture expansion, as well as serving current residents and businesses. Any restrictions to developing a new source of groundwater supply or building additional water or wastewater infrastructure will cause significant detrimental impacts to the County as a whole.

C. CONCLUSIONS

I) The Augusta County Service Authority and Augusta County should Avoid all High Pressure Gas Pipeline Construction Operations within Sensitive Groundwater Recharge and Protection Areas

The Augusta County Service Authority (ACSA) relies on numerous high-yield karst wells and springs to supply drinking water to over 40,000 customers at over 15,000 connections (Figure 1). In many cases, individual/independent water sources have been developed to meet the entire demand of key portions of the ACSA Service Districts (e.g., Middlebrook). In other words, if a critical well or spring were rendered unusable, a portion of the ACSA water users would be left without a public water supply2. Additionally, many homes in rural Augusta County rely on domestic wells for their only source of potable water, and loss of the use of their well would be catastrophic to many owners.

Once groundwater becomes contaminated, it can be very costly, time consuming, and potentially impossible to clean up. Therefore, the best strategy to protect these critical groundwater resources is to avoid pipeline construction development and operation in designated sensitive water supply areas such as exist in: a) the wellhead protection and groundwater recharge areas, b) close proximity to public supply wells and springs3, and c) those areas that have been identified as favorable for the future development of public groundwater supplies.

2) The ACSA and Augusta County should Avoid the Use of any High Pressure Gas Pipeline for Transporting “Other” Hazardous Liquids

ACSA should work diligently to prohibit any potential for using the gas pipeline for transporting other hazardous materials including the transport (or potential transport) of

The ACSA Middlebrook Well is the sole source of public water in Middlebrook, Virginia. Although Source Water Protection Areas have been identified for many of the ACSA Production Wells and Springs, not all water supplies have had their source areas delineated.

Finery & Garrett Groundwater Investigations, LLC Mr. Ken Fanfoni October 31, 2014 Page 7 hazardous liquids, such as petroleum products, diesel fuel, gasoline, or other liquid hydrocarbons. It is EGGI’s professional opinion that a catastrophic release of liquid petroleum products could contaminate karst aquifers rendering groundwater (pumped from nearby wells and springs) unfit for human consumption for a period of months, decades, or much longer. Therefore, the ACSA and the County should ensure that the license issued by the FERC for the Dominion Pipeline explicitly excludes the transport of liquid-phase products and allows only the transport of dry (free of condensate) natural gas.

3) The ACSA and Augusta County should confirm that the Pipeline Design is Sufficient to be Protected from Natural Environmental Hazards

A high priority for groundwater protection is to ensure that the pipeline is designed to be suitable to withstand environmental hazards that will be encountered along the final route(s). It is imperative that the pipeline be built to withstand stresses caused by ground subsidence, irregular (pinnacled) bedrock, potential rapid sinkhole development, earthquakes, and chemical and physical corrosion.

D. RECOMMENDATIONS - MINIMUM REQUIREMENTS TO BE MANDATED BY ACSA AND AUGUSTA COUNTY IF PIPELINE IS APPROVED TO BE LNSTALLED

1) Development of Legally Binding Pipeline Construction Management and Blasting Plan (including a Groundwater Monitoring Plan)

It is imperative that, if thepipeline is approved, its construction and installation be contingent upon the development qf a legally binding Construction Management anti Blasting Plan that is agreed tipoti by the AcSA, Augusta County, and Dominion Power (and its contractors) that addresses specific Best Management Practices to limit the potential for contaminating groundwater during site work activities. Aspects of the Plan must include (as a minimum): a) pre- / post-construction water quality sampling program, b) groundwater level monitoring, c) selection, handling and use of blasting agents, d) dewatering of blast-holes, e) control of stormwater, 1)mitigation of karst features encounteredlcreated during excavationlblasting, g) fuel storage and refueling, h) procedures and practices related to crossing existing utilities, i) stormwater management, andj) construction I blasting monitoring to ensure compliance with groundwater protection measures. It is imperative that the ACSA and Augusta County retain the authority to have Dominion Power immediately stop work on the pipeline if conditions develop that threaten public water supply sources. The specific metrics and criteria for establishing this ‘stop work” event will need to be thoroughly presented in the Piwi.

Prior to the initiation of any blasting, a Groundwater Monitoring Plan must be designed, agreed upon, and implemented to quantify existing baseline hydrogeologic conditions and provide a means for identifying adverse impacts (should they occur) during and after the pipeline blasting/construction activities. The collected groundwater monitoring data will be used to establish any mitigation plan that is subsequently required.

Emery & Garrett Groundwater In vestigations, LLC Mr. Ken Fanfoni October 31, 2014 Page 8

The Plan(s) shall include a provision for the ffinding of an escrow account to cover expenses incurred by the ACSA and County for testing, construction/blasting monitoring / inspections, and professional or legal consultation to address adverse impacts/issues that may arise during construction of the pipeline.

2) Development of Operation Plan

It is hnperative that, if the pipeline is approved, its construction and installation be contingent upon developing a,? Operational Plan for thepipeline 1/ia!is approved by the ACSA Augusta County, and Donthuon Power. The Operation Plan shall mandate specific provisions for regular inspections, leak monitoring and detection, ongoing training of emergency response personnel, and to establish the right, in perpetuity, for new ACSA water and wastewater utility crossings of the pipeline. An escrow account shall be established and maintained during the operational period of the pipeline to address all issues that may arise and to cover additional costs4 incurred by the ACSA when crossing the pipeline right-of-way with new or existing utilities.

3) Development of a Mitigation Plan

It is imperative that, if thepipeline is approved, its construction and installation be contingent upon developing a Mitigation Plan that is developed and approved by the ACSA, Augusta County, and Dominion Power to address a nunther of contingencies shou ld all efforts targeted toward preventing adverse impacts fail . These contingencies would apply to the following: a) groundwater contamination occurs, b) the usability of a public supply well or residential well is compromised or diminished, c) a sinkhole develops near the pipeline, d) damage occurs to an ACSA facility or pipeline, e) a leak or release of transported product occurs, or a major catastrophic pipeline failure occurs. The Plan shall establish Dominion Power’s financial liability (or other owner, operator, partner, successor, etc.) to repair, replace, remediate, any wells, aquifers, recharge areas to aquifers, or infrastructure that is harmed by the installation or operation of the pipeline. Dominion Power shall be financially responsible for providing alternative water supplies during a water “outage”, whether this includes hauling water, paying for water purchased from adjoining utilities, or providing temporary emergency treatment systems. A keypart of this Plan shall describe appropriate financial assurances (such as surety bonds, escrow accounts, insurance instruments, etc.) to insure that any remediation can be completed even if the company is no longer solvent.

E. FINAL STATEMENT

The ACSA and Augusta County have invested hundreds of millions of dollars developing public water supplies and infrastructure to meet the growing water supply demands in Augusta County. Most of the water supplies in the County are obtained from sensitive karst aquifers that warrant the highest level of groundwater protection efforts to ensure a safe, reliable, and sustainable source of water for ftiwre generations. It is our professional opinion that all critical

These costs are defined as anything above and beyond the normal installation costs associated with water or wastewater lines due to the presence of the gas pipeline.

Emery & Garrett Groundwater Investigations, LLC Mr. Ken Fanfoni October 31, 2014 Page 9 water resource areas serving the County, such as areas near ACSA Production Wells and Springs, designated groundwater recharge areas, wellhead protection areas, and thture groundwater development zones, should be avoided when siting proposed gas transmission lines. Furthermore, the transport of hazardous hydrocarbon liquids (other than natural gas) should be strictly prohibited in this proposed high pressure gas pipeline where a leak could have devastating consequences. EGGI has provided herein our conclusions and recommendations as they relate to these issues.

Respectfully submitted,

Jeffrey M. Marts, P.G. James M. Emery, PG. Geologist/Project Manager Senior Hydrogeologist President

F. REFERENCES

Crawford, N.C., 1984, Toxic and explosive himes rising from carbonate aquifers—A Hazard for Residents of Sinkhole Plains: in Beck, B.F., ed., Sinkholes: Their Geology, Engineering and Environmental Impact, Proceedings of the First Multidisciplinary Conference on Sinkholes, Orlando, Florida.

Delin, G.N., Essaid, HI., Cozzarelli, I.M., Lahvis, M.H., Bekins, B. A., 1998, Groundwater Contamination by Crude Oil Near Bemidji, Minnesota, USGS Fact Sheet 084-98.

Field, M.S., 1990,Transport of Chemical Contaminants in Karst Teranes — Outline and Summary: in Selected Papers on Hydrogeology, 2t International Geologic Congress, v. 1, 1989.

Langer, W.H., 2001, Potential Environmental Impacts of Quarrying Stone in Karst—A Literature Review, USGS Open-File Report OF-01-0484.

Newton, J.G., 1987, Development of Sinkholes Resulting from Man’s Activities in the Eastern United States, USGS Circular 968.

Pennsylvania Department of Environmental Protection, 2009, Stray Natural Gas Migration Associated with Oil and Gas Wells, Draft Report downloaded from DEP website on 10/31/14.

Emery & Garrett Groundwater Investigations, LLC FIGURES

Enie;y & Garrett Groundwater Iiivestigations, LLC FIGURE 1

Proposed Gas Pipeline Study Corridors and Augusta County

Groundwater Resources - Sensitive Groundwater Recharge Areas Augusta County, Virginia

Public Water Supplies

Existing ACSA Production Wll - Potable Supply

ACSA Source Waler Pro4ecl,on Area - Daignated Senuitive Groundwater Recharge Areas

Proposed Pipeline Study

Alternate Route

Sole-source Production \‘ell for b Initial Route the Iiddlebrook Service District (Recharge asra not yet defined) Bedrock Geology

4La

scale is I 190080

Groundwater Recharge Area for the ACSA liurdis. Hershey. and Emery & Garrett Groundwater Ridgeview Acres Productton Vellu Investigations, LLC FIGURE 1 Pholograph 2 FIGURE 2 Photograph I Karst Geology and Geologic Hazards Augusta County, Virginia Photograph 3

Pholograph 4

Photograph of a soil-filled vertical kant cotsdoii in lie Conococh eactie Formation Blasting-induced vihmlt 005 can cause l)iagram I dossnsvard movement of sail in similar geologic seltines, leading to the l’holograph 6 Photsograpls of a casem in the Newassasket cover sinkhole development of a collapoc I,smeslone thai once wasapa thway for significant Contaminants in at itse ground surface groundss alec flow The lower portion of ibis cave is the groundwater filled ssilh groundsssler dissolution features Photograph 5 tr - -

Agrtcullsretsscommoit land tue sit Attgttsla Costoly Blasting induced vibrations or changes in storm‘vale, low paths can on up - limestone Example of a rave in Augusla Counw where soil-filled conduits groin dwater flows In the ground ssstface lists ochematic diagram illustrates smponant features ofa karst aqum fersystem and how activities at the ground fonstogamajoc k arstspssng surface cant mpact Ihe groondwaler system

S S Emery & Garrett Groundwater Investigations, LLC FIGURE 2 Photograph I FIGURE 3 Examples of Pipeline Accidents Augusta County, Virginia

Photograph 3

Aflennaili ala gas pipe’’ lie explosion in Apponiallox. Virginia Example ala fire due lox gas pipeline nplure in Virginia. Oil discharging from he njpiure ni an abuse-ground high- pressure pipeline in Alberta. Canada Asiinilar release fran, a buried pipeline wnuld polenliall yresull inasig nifirani amounl nf peimoleum piudurl enieringinlo ihe karsi aquifer l’hotograph 4 Photograph 5 Photograph 6

Numerou, hunse, ‘xre deornyed hy the explosion and subsequeni fire fulloring Firefighiers applying hundreds of gallons nf waier per minuie io ilie mplureo Is gas lransminsiun line In California conirol he fire asxociaied wiih ihe gas line mpiure shnxws in Eon oil spill in flab from a mpiured pipeline Iluslrales Ihe poieniial magmlusk Phoiograph 3 RunnIf cnniaining chemical residues front Fireliishling ala hazardous liquid pipeline failure 3 nperaiions can cnnlamiiuie gruundwaierresuurc es, particularly in Lamsi ierrazn

Emery & Garrett Groundwater Investigations, LLC FIGURE 3 APPENDIX A

US DOT PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION (PHMSA) DATA

• PHMSA Gas Transmission Pipeline Incidents 1994-2013 • PHMSA Gas Transmission Pipeline Mileage

Emery & Garrett Groundwater In vestigations, LLC Pipeline Incidents by System Type: Gale rum 10120i2014

Porlal - Gels as of 1012712014 Data Source: US DOT Prpol’ne and Hazardous Malorrals Safety Administ,aton PHMSA Plp.IIn. IncIdents: (1004-2013) Incident Type: AllRopollsd System Typ.: GAS TRANSMISSION Stat.: (AllColumn Values) OFohot. Flag fAllColumi Valusa)

CoIeadarYe., Number FalalsI.. label.. Prsp.rty D.msa. As RipeR.4 1914 74 0 22 43878.900 1095 54 2 7 0.715.250 1090 70 I 5 13.076,474 1097 60 I 5 11.659,117 lOla 80 I Ii 41.024124 1099 40 2 0 15.656.!34

2220 70 15 ‘16 16.966.291 2201 75 2 5 13,731.347

2202 73 1 4 25.369.331

2223 03 1 0 40.515,121

2204 123 0 ‘2 35.759.127 2223 100 0 5 290 274.502 2220 130 3’ 3 41.110.273 2227 111 2 7 62229,166 2208 122 II 5 206011,440 2005 105 5’ 11 55,911,801

— 2010 107 10 01 411,031,023

2011 110 0 1 80.034641 2012 103 0’ 7 45,223 014 2013 100 0. 2 42275574 Grand Total 1.091 41 190 I 001,055,550

PHMSA P1peOn. incld.nls: MultI-far Av.rag.e (1004-2013) IncIdent Type: All Rel96lod System Type: GAS TRANSMISSICN Stat.: fAllColumn Values) Offohor. Flag (AllColumn Value,) IncIdent Count FstalltIn Injarln Prap.rly Dance. 2514 To-Gal. 3Y..r Av.r.e. 10011.2013) 100 20.., An.,.g. 0 JYe.rAv.rsg. 3 30.ar Av.rso. 061.543.512 IncIdent 00 1 Y.0 Averse. - 12000.20031 100 Sloan Averse. J 2 5 Year Amr.e. 10 0 Ye., Anersse 5133.454.070 F.UIIIl.s l0Ye.r Av.n.ee- 2004-2053) Ii? 100.., *8.1.0.1 2 loVes, Av.rss. IS loThar Averse. $134048012 InjurIes 35 Y.sr Aven.ge- (1904-2003) 05 20 Year Averse. 2 20 Year Averse. 10 20 ‘roar Averse. 579.210.2v0 Prop.90y Damee $31444702 PHMSA P)p.IIne IncIdents: Coons (1094-2013) Incident Type: All Roporod System Type: GAS TRANSMISSION 50.0.: fAllColumn Values) Offshore Flag (AllColumn Values)

100

150

120 ‘E:iiIIIiIiiIIIIIIIIIII 1994 1900 1016 9907 1996 1559 2000 2001 2002 2003 2004 2305 2000 2007 2009 2009 20(0 2011 2092 2013

PHMSA Piplin Incidents: Fatalitlee (1094-2013) IncIdent Type: All R.po4.d System Type: GAS TRANSMISSION State: fAllColumn Values) Offshore Flag (AllColumv Values)

(994 0005 1900 1957 1990 1099 2000 In2001 2002 2003 2004 2505 I2396 2307 2050 2009 2310 2011 2012 23(3 ______

PToperly Oom.age *rws S S S S S S S 1’ 0 0

I I •

I H § II • hi H 5 “ S flu p a

a Gas Transmission Pipeline Miles Time run: 10128/2014 10:02:04 AM

Data Source: US DOT Pipeline and Hazardous Materials Safety Administration Portal Data as of 10127/2014 9:57:31 PM

State: (All Column Values) INTERSTATE INTRASTATE Onshore Offshore Total Operator Calendar Onshore Offshore Total Operator Onshore Offshore Total Operator Miles Miles Miles Count Year Miles Miles Miles Count Miles Miles Miles Count 2013 192,781.8 4,397.7 197179.6 159 105,5232 122.4 105,645,6 865 298,305.0 4,520.2 302,825.2 990 2012 192.514,9 4,620.4 197,135,3 154 106,047.5 148.8 106,196.3 836 298,562.3 4,769.2 303331.5, 960 2011 191,956.8 S208.2jl97,154.9 152 107,7659 105.3 107,671.1 817 299,722.6 5,313.5 305,036.11 937 2010 191,572.0 5,336,5T 196908.5 146 107,770.7 95.9 107,866.6 766 299,342.7t 5,432.4 304775.1 874

GT Total Miles

350.0K 1400

300 OK 1200

250 .0K 1000 0 t 0 0 200.0K 800 2 0 C, C 150.0K 600 I-

100.0K 400 —

500K 200

0.0K 0 2010 2011 2012 2013 Calendar Year • Total Miles — Operator Count APPENDIX B

US DOT PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION (PHfvISA) DATA

• PHMSA Hazardous Liquid Pipeline Incidents 1994-2013 • PHMSA Hazardous Liquid Pipeline Mileage

Enze;y & Garrett Groundwater Investigations, LLC ______

Plp.(ln. Incld.nt. by Sy.0.m Typ.: be? ‘531.0514 960.0 Data.. 01161370314 0.14 Lou’s.: US 001 PpII,,e pAl H*z.Alou. 44.0,441. LaIely Mnslol.9.tbn P54995*P.a,. b.,,6.: (13644610) InoId.nI Typ.: AllRapon.d Iy.4.m lb.: HA1OUS LIQUID 166’.. (Al Cbonsn Valoet) 006,4w,. Fbg:aI Can Vas.) C.noodl6y: (Al Cdupw, V.Iun( 0.Iwd.. To.’ ww.thn P 6.p..a014.d 6,16.6.11 I.44 604 345 I 7 943.194 063 64 297 114.942 ‘994 III 0 II 602.613.630 10237 53.653 393 04 5 II $60,134 396 503 354 900049 1397171 0 5 130.169 643 533543 103,503 ‘993 23 2 3 193.336 623 046394 60705 I 10.11 30 309.156 560 567330 104467 I 4 6130.555.745 106.912 56 093 1 530 0 335.344.761 96.343 77.494 404 0 351.643647 67,394 77.053 (36J_ 434 —— 0 3 997459.145 05.340 03910 3004 _i__’_f_ II 3994 009 004 99.311 69343 3009 340 3 3 3304 454 691 536 001 46 244 3000 304 0 3 373.120.324 137.403 63915 2007 332 4 0 340 443 450 05940 46 942 2006 371 3 3 3140.377 320 102.077 60 650 2000 342 4 4 374.160 677 55314 33340

3090 300 I 4 35003 774604 5:0.510 40453

2011 346 1 2 1213002146 59555 57474 301200434 1544273316 40 650 23 377 2093405 1 5 3267300337 559235 67700 G’aedTflhI.a97 40933 91 994.930.457 3105.464 1.563,700 P4143* Plp.lls. (s14.st.: 14*01-V..’ ((60410039 All (AS Column (neld.nl Typ.: 5,700,4 3y.l.m Typ.: HAZASDOU0 LIQUID 36.6.: value, C 0461k.’. P144 (41 Couu,eso 0.13,6 C..,w.d167: (All CuI*mo VaIues( C “1010” 00000 F.u6611. 14.4*’ P,’,.Oy 04mpg. 1.6.1. 6p6.d 63’ 0.n.b L99l — 2614709-76331. 435641*6336991 35.945031.63 420993113( 170 3 Y.6lA.’04 30.634.99463 0225 970330 35..,*o.,.p. 647 05 00254 9144a006 _J, 054 63.a,Ao.,.6..(20003113( III IT..,Ao.,.o. 65501*0.1.99 4 6 54.l*.4l.p. 5151714005 1 7.a,*..,.p. 61575 57..,Aon 01.375 ‘.6.646.. 0 007.9,4501.4.300430135 309 937..,4s.e.4. 137..,*o.,.g. 963136lAllfl9 3251459001 107.a,*l.,.4. 07253 9476354931943 (62031154,1’. 9 20 73944031.43 4161433135 255 20 76314o.l.4. 20566140.9463 7 035..,A..,n. 0959 72(0.7 305..,4o.,.9. 115275 3009994061.49 39.963 9,164.19 56564. 353752025 39359663p4•4 27.794 609 6*so11 1.4.1 F 13.001

P4913* P (p.IIs. 54014.566: 064,6 11134.33031 6,014.66 Typ.: Al 5.po,Ied 3y.6.m Typ.: HAZARDOUS LIQUID 314111(Al Column V.6*,.) Ofiihorp Fin (ACDoom, Valoet) C.6,m.dlty: (Al Colom, VaIl’s

600

400 3394 Ii I

IIIUii,iiiior.IIIIII.sIII:5H

P6143*91 y.llo. 1504 . P.1.1111.. (6 664-20039 546(4.53 Typo Al RepusS,4 3y.l.m Typ.: HAZARDOUSLIQUID5146.: (Al Cdo,e,s V.60’.) 00696,. 914. (All Column V.Sue,( CommAlIly: (ACColumn V.Su,.l

lii0694 1690 604 5647 ii.644 600 300 009 .3342 3003 II2944 3000 3004 II.1i12947 006 9406 2253 2011 2313 3013 96913* PIp.61.. 660140546: 609046.6 56144043) 6,614.66 lyp.: Al 6po0e0 64664,. Typ.: HAZARDOUS UOUI3 69*6.: (465Cd.s,w V.6u.6( 010.56,. 6 (Al ColumnVi...) Coo..o.dOy: (00 Coo,., V.6*..)

111116604 1645 1066 6047 1049 (660 II2309 3005 1303 II..III..II2342 2096 3345 3294 2347 3346 3004 2060 1056 3052 2901 PHMSA PIp.IIn. IncId.nb: 1109dy D.ni.g. 115531131 IMld.N Typ: AS R.pannd Sy.l.m typ.: HAZARDOUS1.00USD Slat.: (All Cdomn Voes(

015s6tis F1 - (All 0*4005 VIHInI Cnnnl.dby: (All C4o,,o, V.11..)

II 20051

1l.00

573000

500051

- 040000

123000 11h11 165 ((05 1(5611(7 70(01007 2000 2005 2002 30305 3004 2005 2006 2007 2200 2005 30(0 2011 2012 2073

PHMSA PIp.IIn. .1440755: 5mb SpIlI.d 1151441131 Istld.lot Typ.; All R,p0rl.d Syil.m Typa: HAZARDOUS LIQUID 11.6.1 (Al 0114501 V.101.1 DAli),.,. FIfl (All C.k1l.IIIVSIIAII( C.mnwdly: (AS CdUIIWIV00I,I(

306

2166

1000 121111 IIiiuiii11111.I: PHMSA Plp.lls. 1001dm10.-. I•l Btr.la La’S 1564-3113) J los(d.,l Oyp.: AS R1pllll,d Sy.l.n Syp.; HAZARDOUS LIQUID 51.1.; (AS 041,n’ V.Iu,.( 00.50,. Flag (All Coluso V.luo.( CammodIly: (All Colusm Valuni)

1200

1000

- lilhhudno1n1l1001 IllS 1110 Ill; 11071016 22 2001 3002 2005 3004 2005 32 2(507 2000 2000 2010 0011 20(3 20(5 Hazardous Liquid Pipeline Miles and Tanks Time run: 10/2812014 10:02:04 AM Data Source: US DOT Pipeline and Hazardous Materials Safety Administration Portal Data as of 10127/2014 9:57:31 PM

State: (All Column Values) INTERSTATE INTRASTATE Total Total Miles of Operator Calendar Total Milesof Total Operator Total Milesof Total Operator Breakout MIles GatherIng Count Year Miles Gathering Breakout Count Miles Gathering Breakout Count Tanks Tanks Tanks 2013 135,483.4 890.4 4,818 169 56,912.8 2,785.8 2,152 360 192,396.2 3,676.1 6,970 441 2012 130,164.6 985.4 4,754 162 56,044.5 2,101.3 2,045 333 186,209.0 3,086.7 6,799 413 2011 128,426.9 1,069.6 4,635 153 55,140.9 1,847.5 1,860 312 183,567.8 2,917.1 6,495 393 2010 127,532.4 1,089.3 4,394 151 54,441.5 2,673.4 1.865 294 181,974.0 3,762.6 6,259 379

HL Total Miles

240.0K 600

200 OK 500

0 160.0K 400 C

0 120.0K 300 0 CD I- C 80.0K 200

40.0K 100

0.0K 0 2010 2011 2012 2013 Calendar Year • Total M:les — Operator Counl SULLIVAN

Assessment of Augusta County as a Headwaters Zone and Associated Risk Posed by Pipeline Construction

Augusta County, Virginia

Prepared for:

Mr. William Monroe. P.E. Augusta County Service Authority

18 Government Center Lane Verona, Virginia 24482

Prepared by:

Sullivan International Group, Incorporated 402 N. West Street Culpeper, Virginia 22701

Sullivan Project No. 3386-002 February 23, 2015 Assessment of Augusta County as a Headwaters Zone and Associated Risk Posed by Pipeline Construction

Augusta County, Virginia

Prepared for:

Mr. William Monroe. P.E. Augusta County Service Authority 18 Government Center Lane Verona. Virginia 24482

Prepared by:

Sullivan International Group. Incorporated 402 N. West Street Culpeper, Virginia 22701

Michael L. Maloy, CPG Senior Geologist, Vice President

Thomas P. Nelson, CPG Hydrogeologist, Project Manager Table of Contents

1.0 INTRODUCTION I

2.0 ESTIMATE OF WATER OUTFLOW TO ADJOINING COUNTIES I

2.1 Water Outflow Assessment Methodology 1 2.2 Results 2 3.0 ASSESSMENT OF RISKS POSED BY PIPELINE CONSTRUCTION 4 3.1 Occurrence of Bedrock Outcrops, Shallow Bedrock, and Karst Terrain 4 3.2 Water Quality 4 3.3 Water Yield 5 3.4 Dam Safety 6 4.0 SENSITIVE AREA MAPPING 6 4.1 Discussion of Mapping Methodology 6 4.2 Geologic Faults 8 4.3 Sinkholes 8 4.4 Non-Municipal Springs 9 4.5 Public Supply Source Water Protection Areas 9 4.6 Future Groundwater Development Areas 9 4.7 Streams 9 4.8 Dams 10 5.0 CONCLUSIONS AND RECOMMENDATIONS 10 6.0 LIMITATIONS 11 7.0 REFERENCES 11

Figu res

Figure 1 Proposed Pipeline Corridor Figure 2 Regional Hydrography Figure 3a Countywide Map of Sensitive Areas Figure 3b Sensitive Area Map Subset Boundaries Figure 3c Sensitive Area Map, Subset A Figure 3d Sensitive Area Map, Subset B Figure 3e Sensitive Area Map, Subset C Figure 3f Sensitive Area Map, Subset D Figure 3g Sensitive Area Map, Subset E

Tables

Table 1 Summary of Augusta County’s mass-balance hydrologic budget calculations Table 2 Summary of sensitive features in proximity to the proposed Dominion Pipeline Appendices

Appendix A Augusta County Hydrologic Budget Description and Calculations Appendix B Excerpted Figure from the Virginia Hazard Mitigation Plan (2013), Depicting Karst Regions and Historical Subsidence in Virginia Appendix C Headwaters Soil and Water Conservation District’s Letter Addressing Dam Safety in Regard to Pipeline Construction Assessment of Augusta County as a ileadwaters Zone Sullivan Project No. 3386-002 and Associated Risk Posed by Pipeline Construction February 23, 2015

1.0 INTRODUCTION

Sullivan International Group, Inc. (Sullivan) is pleased to provide the following report to Augusta County Service Authority (ACSA), which documents our methodologies and findings related to the following: (I) an estimation of the annual water volume being contributed from Augusta County to adjoining counties and (2) an assessment of risks associated with the construction of the proposed Dominion Pipeline. The proposed path of the Dominion Pipeline can be observed in Figure I. It was important to assess the risks associated with construction of the proposed Dominion Pipeline because Augusta County is uniquely situated as a geographic headwaters zone. As such, water in the county, including both surface water and groundwater, is supplied by precipitation that falls within the county. This water is not only an essential and valuable resource for Augusta County, but is also an important resource to counties downgradient from Augusta County. Figure 2 shows the regional hydrography of Augusta County, including named streams and subbasin boundaries, and depicts the county’s position as a geographic headwaters zone.

Sullivan estimated the annual water volume being contributed from Augusta County to adjoining counties by utilizing a mass-balance approach to estimate the county’s annual hydrologic budget. This allowed Sullivan to assess individual inflows and outflows to/from Augusta County. Findings from this assessment are documented in Section 2.0, below. Sullivan also performed an assessment of potential risks to the county’s water resources that should be considered prior to construction of the Dominion Pipeline. This risk assessment included the development of Sensitive Area Maps (Figures 3a—3g),which depict identified sensitive areas that are in proximity to the proposed pipeline corridor. General descriptions of potential risks associated with pipeline construction, both within identified sensitive areas and throughout the path of the pipeline, have also been included. Findings from the risk assessment portion of this study are documented in Sections 3.0 and 4.0, below.

The findings of this study highlight the quantity and value of water resources originating within Augusta County and identify potential risks to the county’s water resources associated with pipeline construction. These findings demonstrate the importance and necessity for groundwater protection planning during any pipeline construction within Augusta County. This planning should include the formulation of a monitoring plan designed to identify impacts to water resources as a result of pipeline construction activities. Mitigation plans should also be formulated to address and remedy any impacts resulting from pipeline construction activities.

2.0 ESTIMATE OF WATER OUTFLOW TO ADJOINING COUNTIES

2.1 Water Outflow Assessment Methodology To better understand the annual volume of water that originates in Augusta County and flows to downgradient regions beyond its borders, Sullivan has calculated Augusta County’s annual hydrologic inflows and outflows using a mass-balance approach. A U.S. Geological Survey (USGS) Scientific Investigations Report by Sanford et al. (2012), Assessmentof AugustaCountyas a HeadwatersZone SullivanProjectNo.3386-002 and AssociatedRiskPosedby PipelineConstruction February23.2015 wherein components of the hydrologic cycle were quantified throughout Virginia, was an essential resource that was used as part of this study. Sullivan personnel spoke with David Nelms, a hydrologist with the USGS and second author of the Sanford et al. (2012) publication, to discuss the applicability of data within their publication to the Augusta County study. Mr. Nelms concurred that these data could appropriately be used for planning purposes to provide an estimate of average annual groundwater and surface water outflows from Augusta County.

The inflows and outflows comprising Augusta County’s hydrologic budget are as follows: (1) inflow from direct precipitation, (2) outflow from subsurface groundwater flow and the component of streamfiow contributed from groundwater discharge (i.e. baseflow), (3) outflow from groundwater and surface water withdrawn for consumptive use (i.e. human, agricultural, industrial. etc.). (4) outflow from the stormwater runoff component of streamfiow, and (5) outflow from evapotranspiration. All of these hydrologic budget components were accounted for within Sullivan’s hydrologic budget calculations.

Sullivan performed two iterations of the mass-balance calculations; average hydrologic conditions were used for the first iteration and drought conditions were used for the second iteration to provide an estimated range of hydrologic inflows and outflows under variable climactic conditions. Sullivan utilized an annual direct precipitation value of 65 percent of normal precipitation conditions to represent drought conditions. A 35 percent reduction to normal precipitation conditions was utilized to assess drought conditions because the Virginia Drought Response Technical Advisory Committee states that an indicator of extreme drought is the occurrence of a 12-month period where normal precipitation is reduced by 35 percent or more (Virginia Technical Advisory Committee 2003). Detailed descriptions of the assessed hydrologic components and calculation methodology has been provided in Appendix A.

2.2 Results The utilization of a mass-balance approach to estimate Augusta County’s annual hydrologic inflows and outflows yielded the volumes included in Table 1. This table includes estimated volumes under both average and drought precipitation conditions. Under normal precipitation conditions, the calculated groundwater outflow volume via subsurface flow and baseflow was approximately 190,403 million gallons (Mgal) per year and the calculated storm water runoff component of streamflow was 82,848 Mgal/year, for a combined outflow volume totaling 273,251 Mgal/year. Under drought conditions, the calculated groundwater outflow component via subsurface flow and baseflow was 120,214 Mgal/year and the storm water runoff component of streamfiow was 53,598 Mgal/year, for a combined outflow volume totaling 173,812 Mgal/year. Based on these results, Sullivan estimates that between 173,812 Mgal/year and 273,251 Mgal/year are contributed to adjoining counties on an annual basis via groundwater flow and streamfiow.

-2- Assessment of Augusta County as a Headwaters Zone Sullivan Project No. 3386-002 and Associated Risk Posed by Pipeline Construction February 23. 2015

Table 1. Summary of Augusta County’s mass-balance hydrologic budget calculations

. . . . . Drought Precipitation Average Precipitation Conditions Conditlonsa Hydrologic Hydrologic Parameter Augusta County Annual Augusta County Annual Component Parameter Component Value Volume Value Volume (inches/year) (MgaUyeart) (inches/year) (MgaWyear’) Inflow Precipitation Total Precipitation 43.2 730,416 28.08 474,770 Total Evapotranspiration . 26.6 449,747 17.27 291,997 Evapotranspiration Storm Streamfiow Runoff to streams 4.9 82,848 3.17 53,598 Subsurface flow Groundwater Outflow and stream 11.24 190,043 7.11 120,214 Outflow baseflow Groundwater and Surface Water Consumptive use 0.56” 9,468 0.56” 9,468 Withdrawal

Not Applicable Not Applicable -0.1 -1,690 -0.03 -507 Difference alt is assumed that drought conditions are represented by 65 percent of normal precipitation conditions hparameier values obtained from Sanford et al. (2012) cMgal/year million gallons per year dparameier value from Sanford et al. (2012) that has been modified to account for drought conditions eparameter value from Sanford et al. (2012) that has been modified to account for returns to the hydrologic system

-3- Assessment of Augusta County as a Headwaten Zone Sullivan Project No. 3386-002 and Associated Risk Posed by Pipeline Construction February 23,2015

3.0 ASSESSMENT OF RISKS POSED BY PIPELINE CONSTRUCTION

Sullivan has identified several potential risk conditions posed by pipeline construction activities that should be considered. These risk conditions could potentially impact Augusta County’s groundwater and surface water resources. While these risks have the potential to affect the sensitive areas identified within Figures 3a—3g,they may also affect, on a broader scale, any surface water and groundwater resources encountered during construction of the proposed pipeline, including resources servicing individual property owners (i.e. wells and springs).

3.1 Occurrence of Bedrock Outcrops. Shallow Bedrock. and Karst Terrain Bedrock geology in Augusta County varies in depth and in physical character. Generally, the western portion of the county is underlain by clastic shale, siltstone and sandstone, the central “valley” portion is underlain by carbonates (limestone and dolostone) and shale, and the eastern portion is underlain by sandstone and metamorphic crystalline rock (Figure I). Geologic mapping, including detailed formation descriptions, of Augusta County can be found online at the Virginia Department of Mines, Minerals, and Energy’s website (http://www.dmme.virginia.gov/dgmr/augusta.shtml).

Approximately 61 percent of the Augusta County-portion of the planned Dominion Pipeline path extends across carbonate bedrock. Dissolution of the carbonate bedrock leads to the development of karst features and subsurface karst aquifers. Karst aquifers are characterized as having complex flow pathways that can transmit groundwater at significantly higher flow rates than that of typical clastic or crystalline aquifers. As a result of their typically high hydraulic conductivities, karst aquifers have the ability to rapidly transmit contamination through the aquifer. According to the Virginia Department of Conservation and Recreation (VDCR), the most important current and future environmental issue with respect to karst is the sensitivity of karst aquifers to groundwater contamination, since water can travel rapidly through solution conduits with relatively little time for natural filtering (VDCR 2015).

Localized areas of bedrock outcrops, as well as areas with shallow depths to bedrock, are widespread throughout Augusta County in areas underlain by both carbonate and non- carbonate bedrock. The presence of exposed or shallow bedrock is often associated with drainage incisions in the landscape where overlying soils have been transported away by erosional forces, but it can also be associated with higher topographic settings where the physical properties of the bedrock result in greater resistance to weathering. Based on the variety of both landscape positions and bedrock types throughout Augusta County, shallow depths to bedrock would be expected to be encountered frequently during construction of the Dominion Pipeline, which is expected to be buried to depths of 30—60 inches below the land surface. Such occurrences may require blasting to accommodate pipeline construction.

3.2 Water Quality Groundwater wells and springs can be susceptible to impacts from blasting activities. Contamination of groundwater can occur from exposure to, or from a release of,

-4- Assessmentof Augusta County as a Headwaters Zone Sullivan Project No. 3386-002 andAssociatedRisk Posedby Pipeline Construction February 23.201Z chemicals used in bedrock blasting. Increased turbidity of groundwater can also be caused by agitation of the subsurface as a result of blasting. Blasting vibrations can shake loose silt, rock particles and chemical precipitates that line fracture surfaces in the subsurface, which can increase groundwater turbidity (Kernen 2010). Blasting vibrations in proximity to a well may also have the potential to compromise a well’s sanitary seal by creating cracks within the grout seal. The introduction of turbidity or contaminants to groundwater can impair its quality (Emery & Garrett Groundwater Investigations, LLC [EGGI] 2014).

The potential for increased turbidity and susceptibility to chemicals associated with blasting represents a risk to groundwater throughout Augusta County. However, areas underlain by carbonate bedrock possessing karst characteristics are considered more vulnerable to such risks. Active sinkholes, which are typical of karst conditions, can provide a direct conduit from the surface to the underlying bedrock aquifer. The use of chemicals that are frequently used at construction sites, such as diesel fuel, gasoline, antifreeze, etc.. represents an additional risk to groundwater quality within the karst aquifer due to the potential for rapid contaminant migration and the resulting long-lasting effects to water quality.

Sinkholes can develop in a variety of ways. Dissolution sinkholes form naturally by the slow downward dissolution of carbonate rock, whereas collapse sinkholes form suddenly when overlying rock collapses into a dissolution cavern. According to the Virginia Department of Emergency Management’s (VDEM’s) Hazard Mitigation Plan (VDEM 2013), sinkhole development can also be human-induced by alterations to local hydrology, as inadequate drainage and increased runoff can lead to sinkhole development. Proper stormwater management is an essential component of protecting groundwater and surface quality. According to Figure 3.14-I in VDEM’s Hazard Mitigation Plan, titled Karst Regions and Historical Subsidence, the entire portion of Augusta County that is underlain by carbonate rock is recognized as an area that has experienced historical subsidence, which is further defined as having extensive sinkhole development. This figure also identifies the type of karst in Augusta County as being of the “long” variety, which is characterized by fissures, tubes, and caves over 1,000 feet in length with vertical extents of 50 feet to greater than 250 feet. Figure 3.14-1 in the Hazard Mitigation Plan has been included as Appendix B in this report. Finally, the Hazard Mitigation Plan recognizes karst terrain as a risk to energy pipelines, stating that “pipeline infrastructure, underlain by karst terrain, can be damaged by collapse in the supporting soil” (VDEM 2013).

3.3 Water Yield Blasting-induced vibrations have the potential to affect fragile bedrock fracture systems within the bedrock aquifer underlying Augusta County, which could result in diminished well yields. Diminished well yields can occur as a result of the collapse of a water bearing feature, or by increased sedimentation effectively clogging a water-bearing feature contributing water to a well or spring (EGGI 2014). Substantial changes within a fragile karst aquifer system also have the potential to lower the water table, which can result in reduced yields to wells and springs (EGGI 2014).

-5- Assessment of Augusta County as a Headwaters Zone Sullivan Project No. 3386-002 and Associated Risk Posed by Pineline Construction February 23. 2015

3.4 Dam Safety The potential for blasting vibrations to threaten the integrity of dams within the county has created concerns from the Headwaters Soil and Water Conservation District (HSWCD). The HSWCD outlined their concerns for dam safety in a correspondence to the Federal Energy Regulatory Commission (FERC) dated December 17, 2014. A copy of this correspondence has been included as Appendix C. In this correspondence, the HSWCD requested that blasting be prohibited within 0.75 mile of any dams to avoid potential damage to the dam embankments. The HSWCD further requested that a monitoring plan be prepared for any blasting occurring between 0.75—1.25mile of any dams to monitor for potential damage.

4.0 SENSITIVE AREA MAPPING

Sullivan has prepared a series of Sensitive Area Maps that show identified sensitive areas in proximity to the planned route of the Dominion Pipeline (Figures 3a—3g). Figure 3a depicts identified sensitive areas throughout Augusta County on a countywide-scale, Figure 3b depicts the boundaries of map “subsets” that show large-scale mapping of identified sensitive areas along the path of the pipeline, and Figures 3c—3gshow these large-scale subset maps. The Sensitive Area Maps depict the route of the pipeline, mapped geologic faults, carbonate and non-carbonate bedrock areas, sinkholes, ACSA well heads, potable water supply production springs, source water protection zones associated with ACSA wells and water supply production springs, areas planned for future groundwater development, mapped non-municipal springs, and dams. Available published resources and mapping data provided by Augusta County, ACSA, HSWCD, Virginia Department of Environmental Quality (VDEQ), and USGS were used to develop these maps. While the intent of the Sensitive Area Maps is not to relieve Dominion Power of their own obligation to perform due diligence regarding risk assessment associated with pipeline construction, the mapping does provide a screening-level assessment that identifies sensitive areas that could be susceptible to impact during pipeline construction. Any such impact could result in impairment to Augusta County’s water resources.

There will undoubtedly be numerous domestic wells located in proximity to the planned path of the pipeline. With the exception of public water supply wells utilized by ACSA, the Sensitive Area Maps do not identify groundwater wells. Any domestic well. community supply well, or other public water supply well that lies in proximity to the planned path of the pipeline would be deemed as sensitive. An additional site-specific inventory would be required to determine the locations of any wells that may lie in proximity to the planned pipeline.

4.1 Discussion of Mapping Methodology Sullivan utilized Geographic Information Systems (GIS) mapping and shapefile data to identify sensitive areas located in proximity to the path of the proposed pipeline. A 500- foot buffer distance from both sides of the pipeline was utilized to select the mapped sinkholes and non-municipal supply springs. A larger 2.640-foot (0.5-mile) buffer

-6- Assessment of Augusta County as a Headwaters Zone Sullivan Project No. 3386-002 and Associated Risk Posed LivPineline Construction Februaiw 23.2015

Table 2: Summary of sensitive features in proximity to the proposed Dominion Pipeline. Buffer . Number of . . Distance Sensitive Feature Features Within Notes from . . Buffer Distance Pipeline Pipeline directly crosses over 4 500 fton Mapped Sinkholes 27 of the 27 sinkholes located each side . within 500 ft of the pipeline ACSA Wells and 0.5 mile on 0 Production Springs each side City of Staunton 0.5 mile on 0 Production Springs each side Non-Municipal 500 ft on 4 springs are located within 0 Springs each side 1,000ft of the pipeline

Geologic Faults Crossings 7 crossings Inch Branch Dam, Robinson Hollow Dam, Happy Hollow 1.25 mile Dam, and Waynesboro Dams on each 4 Nurseries Dam. All of these side dams except Inch Branch Dam are located within 0.75-mile of the pipeline From west to east: Barn Lick Branch, Braley Branch, Calfpasture River, Stoutameyer

. . Branch, Jennings Branch, Streams (named) Crossings 12 crossings Middle River, Lewis Creek, Folly Mills Creek, Christians Creek, Barterbrook Branch, South_River,_Back_Creek Pipeline directly crosses through the Lyndhurst Well and Wellhead 0.5 mile on Gardner Spring Wellhead Protection Areas each side Protection Areas, and is within 0.5 mile of the HHR Wells Wellhead_Protection_Area

Potential Future . . Pipeline directly crosses Groundwater 0.5 mile on . 2 through both of these future Development each side groundwater development areas Areas

-7- Assessment of Augusta County as a Headwaten Zone Sullivan Project No. 3386-002 and Associated Risk Posed by Pipeline Construction February 23,2015 distance from both sides of the pipeline was utilized to assess public water supply sources used by ACSA or the City of Staunton, Wellhead Protection Areas associated with these wells and springs, and potential future groundwater development areas. This buffer distance was selected based on criteria utilized by the state code of Massachusetts (Massachusetts State Code 2009) for interim wellhead protection area delineation. A buffer distance of 1.25 mile was utilized to select dams in proximity to the pipeline. This distance was chosen to correspond with the aforementioned HSWCD concerns related to the threat of blasting vibrations on dam stability. Table 2 shows a summary of assessed sensitive features, buffer distances from the pipeline. and the number of features located within the buffer distance. Analysis of the sensitive area mapping results is provided below.

4.2 Geologic Faults The proposed pipeline crosses seven (7) mapped geologic faults. The majority of geologic faults in Augusta County have a general northeast-southwest orientation. As such, the generally east-west trend of the proposed pipeline leads to a propensity for fault crossings. Preferential weathering of bedrock often occurs along geologic faults, which can provide enhanced means for subsurface groundwater movement (De Simone and Gale 2009). Springs are also often found along geologic faults, particularly in karst regions of Augusta County. The most prominent mapped fault in the region is the Staunton Fault, which the proposed Dominion Pipeline would cross at a location approximately two miles southwest of the City of Staunton (Figure 3d). Although they are not located within the 0.5-mile buffer zone, it is of interest that three (3) significant springs (Gardner Spring, Berry Farm Spring, and Dices Spring) are located along or are likely supplied water from the Staunton Fault. Each of these springs are used for public water supply by either the ACSA or the City of Staunton.

4.3 Sinkholes As much of Augusta County is underlain by carbonate geology, it is not unexpected that 27 sinkholes were identified within the 500-foot pipeline buffer zone. These sinkholes are outlined in red in Figures 3c—3g. Four (4) of the 27 sinkholes actually underlie the planned path of the pipeline, all of which are located within the extent of Figure 3e. It is important to note that mapped sinkhole data obtained during this assessment are representative of work performed by Hubbard (1984), who identified sinkholes using stereoscopic analysis. Certainly other sinkholes that may not have been clearly visible are absent from this mapping. Likewise, any new sinkhole development that has occurred from the date of this mapping (1984) would not be shown.

The locations of sinkholes within 500 feet of the planned pipeline are deemed important because sinkhole development often occurs in clusters, as evidenced by sinkhole mapping in Figures 3a—3g.Also, active sinkholes possess the ability to rapidly transmit water and potential contaminants from the surface to the underlying bedrock aquifer. The potential for disturbance to soil arches and/or fragile weathered solution channels that are typically associated with sinkholes should be carefully considered during any pipeline construction activity, since damage to these systems can affect the flow pathways, yield, and quality of groundwater in karst aquifers. The potential risk of damage to the proposed pipeline

-8- Assessment of Augusta County as a Headwaters Zone Sullivan Project No. 3386-002 and Associated Risk Posed by Pipeline Construction February 23.2015 must also be considered within karst portions of Augusta County, since pipeline infrastructure underlain by karst terrain can be damaged by collapse in the supporting soil (VDEM 2013).

4.4 Non-Municipal Springs The locations of mapped springs within Augusta County were obtained from the VDEQ. There were no mapped springs identified within the defined buffer zone, however, it should be noted that four (4) springs were identified within 1.000 feet of the planned pipeline. Other unmapped springs could exist in proximity to the pipeline that are not included within the VDEQ database.

4.5 Public Supply Source Water Protection Areas Review of the sensitive area mapping indicated that two (2) source water protection areas that have previously been delineated for existing public water supplies used by the ACSA or City of Staunton lie within the path of the planned pipeline and an additional source water protection area is within 0.5 mile of the proposed pipeline. The source water protection areas that would be crossed by the proposed pipeline are the Lyndhurst Well and the Gardner Spring areas. The HHR Wells wellhead protection area is within 0.5 mile of the proposed pipeline. A source water protection area can be defined as the landscape area which is deemed to supply groundwater to the well or spring. Their delineation typically involves hydrogeologic mapping, which considers underlying geology, fracture orientation, and landscape position. Construction activity within a source water protection area must consider the sensitive nature of these areas, as the potential for impact to both water quality and yield associated with public water supplies could exist.

4.6 Future Groundwater Development Areas Areas that are deemed important for potential future development of groundwater have been previously delineated in Augusta County. Just as it is important to protect existing public water supplies, it is likewise prudent to protect areas that may provide future water supply. Sensitive area mapping indicated that two (2) such areas are located within the 0.5 mile buffer zone from the pipeline, both of which are crossed by the proposed pipeline.

4.7 Streams The locations of named streams throughout the county have been depicted in Figure 2. Review of this figure shows that the planned path of the pipeline crosses 12 of these streams. From west to east, these streams are as follows: Barn Lick Branch, Braley Branch, Calfpasture River, Stoutameyer Branch, Jennings Branch, Middle River, Lewis Creek, Folly Mills Creek, Christians Creek, Bartbrook Branch, South River, and Back Creek. It should be noted that crossing of other unnamed streams will likely occur. During any stream crossing, the risk of impact to surface water and potentially groundwater quality exists.

-9- AssessmentofAugustaCountyas a HeadwatersZone SullivanProjectNo.3386-002 and AssociatedRiskPosed by PipelineConstruction February23,2015

4.8 Dams A review of dams proximal to the planned path of the pipeline was also conducted. Dams located within 1.25 mile of the proposed pipeline were identified to be consistent with requests previously made by the HSWCD (Appendix C). Four (4) dams (Inch Branch Dam, Robinson Hollow Dam, Happy Hollow Dam, and Waynesboro Nurseries Dam) were identified as being located within 1.25 mile of the proposed pipeline. With the exception of Inch Branch Dam, all of these dams are located within 0.75 mile of the planned pipeline. As previously discussed, concerns related to blasting vibrations and the potential effects of such vibrations on the integrity of the dams have been raised by the HSWCD. Their concerns were highlighted within correspondence to the Federal Energy Regulatory Commission, where a request was made to prohibit blasting within 0.75 mile of any dams. They also requested that a monitoring plan be prepared for any blasting occurring between 0.75—1.25mile of any dams to monitor for potential damage.

5.0 CONCLUSIONS AND RECOMMENDATIONS

The findings of this report demonstrate the value of Augusta County’s groundwater and surface water resources, as demonstrated by the large annual volume of water outflow being contributed to adjoining counties (Table 1). A discussion of general risks posed by pipeline construction, along with the creation of Sensitive Area Maps (Figures 3a—3g) and analysis of these maps, has provided a screening-level assessment of risks specific to Augusta County that could be encountered during pipeline construction. Numerous sensitive areas lying within or near the path of the planned pipeline have been identified. Impacts to the county’s water resources could potentially occur during any pipeline construction activities in these areas.

In an effort to protect the water resources of Augusta County, it will be imperative to have proper groundwater protection planning in place during any pipeline construction activities. This planning should include site-specific monitoring plans designed to identify impacts to groundwater and surface water resources resulting from pipeline construction activities. Adequate storm water management would also be necessary to avoid sinkhole development. In the event that impacts to water resources are identified, adequate mitigation planning should be available to clearly address and remedy any such impact conditions.

Sensitive area mapping provided within this report has utilized readily-available mapping resources to aid in identifying areas deemed to potentially be at risk from impacts resulting from pipeline construction. Analysis of mapping results was conducted on a countywide scale and was focused along the path of the proposed pipeline. Locations of mapped sensitive features should be considered approximate. This assessment is not intended to replace a site-specific inventory of sensitive conditions that may exist along the planned path of the pipeline. Site-specific sensitive area inventory and site specific monitoring and mitigation planning is recommended.

-10- Assessment of Augusta County as a Headwaters Zone Sullivan Project No. 3386-002 and Associated Risk Posed by Pipeline Construction February 23, 2015

6.0 LIMITATIONS

The work performed in conjunction with this study, and the data developed, are intended as a description of available information. This report does not warrant against future operations or conditions, nor does it warrant against operations or conditions present of a type or at a specific location not investigated. Generally accepted industry standards were used in the preparation of this report. Stated opinions and conclusions are not intended as a guarantee.

7.0 REFERENCES

De Simone, Di. and Gale, M. 2009. The surficial geology and hydrogeology of Dorset, Vermont. Publication of the Vermont Geological Survey. June 2009. [EGGI] Emery & Garrett Groundwater Investigations, LLC 2014. Letter report to Augusta County related to potential risks to water resources resulting from pipeline construction. Report dated 10/31/2014.

Hubbard, D.A. 1984. Sinkhole distribution in the central and northern Valley and Ridge province. In: Beck, B.F., ed., Sinkholes: Their geology, engineering, and environmental impact. Proceedings of the first multidisciplinary conference on sinkholes, Orlando, Florida, pp. 28 1—284.

Kernen, B. 2010. Rock blasting and water quality measures that can be taken to protect water quality and mitigate impacts. New Hampshire Department of Environmental Services Document WD-10-12.

Massachusetts State Code 2009. State Code 310 CMR 22.00: Massachusetts Drinking Water Regulations. Amended December 2009.

Sanford, W.E., Nelms, D.L., Pope, J.P., and Selnick, D.L. 2012. Quantifying components of the hydrologic cycle in Virginia using chemical hydrograph separation and multiple regression analysis. U.S. Geological Survey Scientific Investigations Report 201 1-5198, 152 p. [VDCRj Virginia Department of Conservation and Recreation 2015. Living with Sinkholes. Accessed online at < http://www.dcr.virginia.gov/natural_heritage/ vcbsinkholes.shtml> on 2/18/2015.

[VDEM] Virginia Department of Emergency Management 2013. Commonwealth of Virginia Hazard Mitigation Plan. Section 3.14—Karst Topography. March 2013.

Virginia Technical Advisory Committee 2003. Virginia Drought Assessment and Response Plan. Submitted 3/28/2003.

- II - Figures ______

Figure 1: Proposed Pipeline Corridor Legend AugustaCounty ServiceAuthority AugustaCounty,Virginia Augusta County

Virginia-West Virginia Border Proposed Pipeline

Carbonate Rock N I I Non-Carbonate Rock

0 4 8 16 Sullivan Miles Project Number:3386-002 Figure 2: Regional Hydrography Legend Augusta County Service Authority Augusta County, Virginia I IAugusta County Virginia-West Virginia Border Proposed Pipeline

Stream N Reservoir Subbasin Boundary LUVAN

0 4 8 16 •MiIes Sullivan Project Number: 3386-002 ______

Figure 3a: Countywide Map of Sensitive Areas Legend Augusta County Service Authority Augusta County, Virginia Map Notes: ii) Sensitive areas located within IAugusta County Carbonate Rock assigned bufferdistances of the prnposed pipeline an’ outibiedin Orange.t2) Atapped Proposed Pipeline Non-Carbonate Rock I I sinkholesgenera/h’appear as small clots ACSAWeII Mapped Sinkhole due to the ‘;iaps countnride scale. ® I I ACSAPotable Spring Dammed Reservoir .4 Cityof Staunton Potable Spring .j Wellhead ProtectionArea

— Non-MunicipalSpring Potential Future Groundwater Development Area Geologic Fault LLIVAN o 4 8 16 •MiIes Sullivan Project Number: 3386-002 Figure 3b: Sensitive Area Map Subset Boundaries Augusta County Service Authority Augusta County, Virginia Legend

I IAugusta County Proposed Pipeline

Carbonate Rock N I _J Non-CarbonateRock L3 [J Subset Boundary

0 4 8 16 Miles Sullivan Project Number: 3386-002 ______

Figure 3c: Sensitive Area Map, Subset A Legend Augusta County Service Authority Augusta County, Virginia Augusta County Carbonate Rock Map Note: Sensitiveareas located ,i’ithin assigned bzLfferdistances of the prnposed Proposed Pipeline Non-Carbonate Rock I I pipeline ore outlinedin orange ® ACSAWell Mapped Sinkhole $- ACSAPotable Spring Dammed Reservoir $- Cityof Staunton Potable Spring Wellhead Protection Area • Non-MunicipalSpring j Potential Future Groundwater Development Area Geologic Fault

0 1 2 0.5 Sullivan Miles Project Number: 3386-002 ______

Figure 3d: Sensitive Area Map, Subset B Legend Augusta County Service Authority Augusta County, Virginia Augusla County Carbonate Rock I I Map Note: Sensitiveareas located within Proposed Pipeline Non-Carbonate Rock assigned bufferdistances oft/ic proposed I I pipeline are outlinedIn orange ACSAWell Mapped Sinkhole ACSAPotable Spring [;Jj Dammed Reservoir Cityof Staunton Potable Spring Wellhead Protection Area N . Non-MunicipalSpring Potential Future Groundwater Development Area Geologic Fault LLVAN

0 1 2 0.5 Sullivan Project Number: Miles 3386-002 ______

Figure 3e: Sensitive Area Map, Subset C Augusta County Service Authority Legend Augusta County, Virginia Rock I IAugusta County I ICarbonate Map Note: Sensitiveareas located ii’itlsin assigned bufferdistances theproposed Proposed Pipeline Non-Carbonate Rock of I I pipelineare outlinedin orange ACSAWell Mapped Sinkhole I I ACSAPotable Spring Dammed Reservoir

Cityof Staunton Polabte Spring Wellhead Protection Area I I N C, Non-MunicipalSpring j

1 2 0 0.5 Sullivan Project Number: 3386-002 Miles Figure 3f: Sensitive Area Map, Subset D Augusta County Service Authority Legend Augusta County, Virginia Augusta County Carbonate Rock Map Note: Sensitivearvas located within I I I I assigned bufferdistances oft/ic proposed Proposed Pipeline Non-Carbonate Rock I I pipeline are outlinedin orange ACSAWeII Mapped Sinkhole ® I I ACSAPotable Spring r J Dammed Reservoir • Cityof Staunton Potable Spring r i Wellhead ProtectionArea • Non-MunicipalSpring I>;1 Potential Future Groundwater DevelopmentArea Geologic Fault LUVAN

0.5 1 2 0 Sullivan Project Number: 3386-002 Miles ______

Figure 3g: Sensitive Area Map, Subset E Augusta County Service Authority Legend Augusta County, Virginia

I IAugusta County Carbonate Rock Map Note: Sensith’eareas located within assigned buffer distances of/he proposed Proposed Pipeline Non-Carbonate Rock pipeline are outlined in orange 0 ACSAWell Mapped Sinkhole 43- ACSAPotable Spring Dammed Reservoir Cityof Staunton Potable Spring Welihead ProtectionArea $ I I N • Non-MunicipalSpring I’’/1 Potential Future Groundwater Development Area Geologic Fault LLIVAN

0 0.5 1 2 Sullivan 3386-002 Miles Project Number: Appendix A

Augusta County Hydrologic Budget Description and Calculations Detailed Description of Hydrologic Budget Assessment

Hydrologic Budget Calculation Methodology Sullivan utilized a mass-balance approach to calculate annual hydrologic inflows and outflows to/from Augusta County. The following equation was used to perform the calculations: Total Inflow = Total Outflow + Change in Storage. The annual change in water storage within the county, which is primarily a function of fluctuations in groundwater storage, was assumed to be negligible. As such, the aforementioned mass- balance equation was reduced to the following: Total Inflow = Total Outflow.

A U.S. Geological Survey (USGS) Scientific Investigations Report by Sanford et al. (2012), wherein components of the hydrologic cycle were quantified throughout Virginia, was an essential resource that was used as part of this study. Sullivan personnel spoke with David Nelms, a hydrologist with the USGS and second author of the Sanford et al. (2012) publication, to discuss the applicability of data within their publication to the Augusta County study. Mr. Nelms concurred that these data could appropriately be used for planning purposes to provide estimates of average annual groundwater and surface water outflows from Augusta County.

Sullivan performed two iterations of the mass-balance calculations, where average hydrologic conditions were used for the first iteration and drought conditions were used for the second iteration, to provide an estimated range of hydrologic inflows and outflows under variable climactic conditions. Sullivan utilized an annual direct precipitation value of 65 percent of normal precipitation conditions to represent drought conditions. A 35 percent reduction to normal precipitation conditions was utilized to assess drought conditions because the Virginia Drought Response Technical Advisory Committee states that an indicator of extreme drought is the occurrence of a 12-monthperiod where normal precipitation is reduced by 35 percent or more (Virginia Technical Advisory Committee 2003).

All of the Hydrologic inflow to Augusta County is assumed to be from direct precipitation, as a result of it being a geographic headwaters zone. To conduct the first iteration of mass-balance calculations, Sullivan utilized the average annual direct precipitation value for Augusta County (43.2 inches/year). as presented in the Sanford et al. (2012) publication, to calculate the total annual volume of direct precipitation that falls within Augusta County under normal conditions. To conduct the second iteration of calculations that represent drought conditions, Sullivan utilized an annual direct precipitation value of 65 percent of normal precipitation conditions (28.08 inches/year). Calculations of total inflow volumes to Augusta County under normal and drought conditions are included in Appendix A.

Hydrologic outflow components from Augusta County include evapotranspiration. streamfiow contributed from stormwater runoff, subsurface groundwater flow, streamflow contributed from baseflow, and groundwater and surface water withdrawn for consumptive use. Calculations of total outflow volumes from Augusta County under normal and drought conditions are included in Appendix A, and are discussed further below.

The average total evapotranspiration rate of Augusta County (26.6 inches/year), as provided in Sanford et al. (2012), was utilized to assess the total annual volume of evaporative outflow. Sanford et al. (2012) state that Augusta County’s annual total evapotranspiration is approximately 61.5 percent of the total direct precipitation annual rate. As such, a value of 17.27 inches/year was used to simulate evapotranspiration outflow under drought conditions.

The Sanford et al. (2012) publication states that a total of 0.91 inch/year is withdrawn from groundwater and surface water in Augusta County annually. Although this value only comprises a very minor segment of Augusta County’s annual hydrologic budget, Sullivan has estimated the portion of this water that would return to the hydrologic system via septic systems, direct discharges, injection, etc. Sullivan has assumed that a portion of this withdrawn water would leave the hydrologic system via evaporation and the remaining portion would be input back into the hydrologic system via groundwater recharge. To account for the portion of water removed from the hydrologic system via evaporation, Sullivan multiplied the 0.91 inch/year consumptive use rate by the ratio of total annual evapotranspiration to total annual direct precipitation (26.6 inches/year ÷ 43.2 inches/year), which yielded a consumptive use evaporative removal rate of 0.56 inch/year. The remaining 0.35 inch/year was assumed to recharge back into the groundwater system. These values were utilized to simulate outflow under both average and drought precipitation conditions. The aforementioned consumptive use groundwater recharge rate provides a conservative estimate of the volume of water returned to the groundwater system, since much of the consumptive use water would not be subjected to evaporative processes (i.e. water returned to the hydrogeologic system via septic systems or injection).

The average component of streamfiow contributed from stormwater runoff in Augusta County (4.9 inches/year), as provided in Sanford et al. (2012), was utilized to assess the total annual outflow volume of this streamfiow component. Sanford et al. (2012) state that Augusta County’s annual runoff component of streamfiow is approximately 11.3 percent of the total direct precipitation annual rate. As such, a value of 3.17 inches/year was used to simulate outflow from the stormwater runoff component of streamfiow under drought conditions.

The average outflow of groundwater from Augusta County via subsurface flow and the baseflow component of streamfiow (11.8 inches/year), as provided in Sanford et al. (2012), was modified to account for consumptive-use withdrawals to assess the total annual volume of groundwater outflow from the county. As previously discussed, Sullivan has estimated that 0.91 inch/year is removed from groundwater and surface water annually in Augusta County. Of this 0.91 inch/year, 0.56 inch/year was estimated to be lost from the system via evaporative processes and the remaining 0.35 inch/year was assumed to recharge back into the groundwater system. As such, the total annual groundwater outflow via subsurface flow and baseflow was assumed to be equal to the average groundwater outflow value (11.8 inches/year) less consumptive-use losses to evaporation (0.56 inch/year). This resulted in a total annual groundwater outflow via subsurface flow and baseflow of 11.24 inches/year under average precipitation conditions. To simulate groundwater outflow under drought conditions, the average groundwater outflow value (11.8 inches/year) was reduced by a factor of 35 percent, yielding a value of 7.67 inches/year. This value was then reduced by 0.56 inch/year to account for consumptive-use losses, since consumptive-use losses during drought conditions were assumed to be the same as losses under normal precipitation conditions, yielding a drought-conditions total annual groundwater outflow via subsurface flow and baseflow of 7.11 inches/year.

Results from Hydrologic Buduet Calculations The utilization of a mass-balance approach to estimate Augusta County’s annual hydrologic inflows and outflows yielded the volumes included in Table 1, within the main body of this report. This table includes estimated volumes under both average and drought precipitation conditions. Under normal precipitation conditions, the calculated groundwater outflow volume via subsurface flow and baseflow was approximately 190,403 million gallons (Mgal) per year and the calculated storm water runoff component of streamflow was 82,848 Mgal/year, for a combined outflow volume totaling 273,251 Mgal/year. Under drought conditions, the calculated groundwater outflow component via subsurface flow and baseflow was 120,214 Mgal/year and the storm water runoff component of streamfiow was 53,598 Mgal/year, for a combined outflow volume totaling 173,812 Mgal/year. Based on these results, Sullivan estimates that between 173,812 Mgal/year and 273,251 Mgal/year are contributed to adjoining counties on an annual basis via groundwater flow and streamfiow.

Hydrologic Budget Calculations

Hydrologic Equation and Assumptions - General Hydrologic Equation: Inflow = Outflow + Change in Storage - It is assumed that change in storage is negligible; as such, the general equation can be reduced to the following, which was used to conduct the calculations: Inflow = Outflow o Inflow component: total precipitation (P) o Outflow components: total evapotranspiration (ET), runoff to streams (R), groundwater outflow from subsurface flow and stream baseflow (GW), and consumptive use (CU) - Inflow and outflow component values were obtained or modified from Sanford et al. (2012). Augusta County’s area (972.9 mi2or 2.52 x l0 m2)was also obtained from Sanford et al. (2012). - The hydrologic budget was calculated under average and drought precipitation conditions. Drought conditions are represented by a 35 percent reduction to all inflow and outflow components except consumptive use. - Calculations of component volumes were generally conducted as follows: (J o Volume (million gallons per year [Mgal/year]) = Component Value (in/yr) * Unit Conversion (in to rn) * Augusta County’s Area (2.52 x io m2) * Unit Conversion (m3to Mgal)

Averaae Precipitation Conditions Calculations (1) Hydrologic Inflow Calculations: a. P = 41.2 in/yr * 0.0254 rn/in * 2.52 x io m2 * 2.64172 x 10-4 Mgal/rn3 = 730.416 Mgal/yr (2) Hydrologic Outflow Calculations: a. ET = 26.6 in/yr * 0.0254 rn/in * 2.52 x l0 m2 * 2.64172 x 10-4 Mgal/m3 = 449,747 Mgal/yr b. R = 4.9 in/yr * 0.0254 rn/in * 2.52 x io m2 * 2.64172 x 10-4 Mgal/rn3 = 82,848 Mgal/yr c. CU = 0.56 in/yr * 0.0254 m/in * 2.52 x io m2 * 2.64172 x 10-4 Mgal/rn3 = 9,468 Mgal/yr d. GW = 11.24 in/yr * 0.0254 rn/in * 2.52 x io m2 * 2.64172 x 10-4 Mgal/m3 = 190,043 Mgal/yr

Drouuht Precipitation Conditions Calculations (1) Hydrologic Inflow Calculations: * * * a. P = 28.08 in/yr 0.0254 rn/in 2.52 x Io m2 2.64172 x 10-4 Mgal/m3 = 474,770 MgaI/yr (2) Hydrologic Outflow Calculations: a. ET 17.27 in/yr * 0.0254 m/in * 2.52 x io m2 * 2.64172 x 10-4 Mgal/m3 = 291,997 Mgal/yr b. R = 3.17 in/yr * 0.0254 m/in * 2.52 x io m2 * 2.64172 x 10-4 Mgal/rn3 = 53,598 Mgal/yr c. CU = 0.56 in/yr * 0.0254 rn/in * 2.52 x 1O m2 * 2.64172 x 10-4 Mgal/m3 = 9,468 Mgal/yr d. GW = 7.11 in/yr * 0.0254 rn/in * 2.52 x iO m2 * 2.64172 x 10-4 Mgal/m3 = 120,214 Mgal/yr

0 Appendix B

Excerpted Figure from the Virginia Hazard Mitigation Plan (2013), Depicting Karst Regions and Historical Subsidence in Virginia 0 0 0

Figure 3.14-1: Karst Regions and Historical Subsidence

VIRGINIA DATA SOURCES: LEGEND: HAZARD IDENTIFICATION: DEPARTMENT r%t 0 USGS Engineering Aspects of Kant — I listorical Subsidence Long Kant Type: Fissures, tubes, and caves over 1,000 ft long; 50 ft to czIJT OF EMERGENCY Y. MANAGEMENT VGIN Jurisdictional Boundaries Kant Type (Long) over 250 ft vertical extent ESRI Stale Boundaries In moderately to steeply dipping beds of carbonate rock Shod Karst Type: Fissures, tubes and caves generally less ttsan 1000 ft long, 500 or less vertical extent PROJECTION: I A Lumber? Conforusal Conic In gently dipping to Oat- lying beds of carbonate rock North A pier?can Dcl pm 1983 Karsi Type (Short) Historical subsidence represents areas olextensive sinkhole development. In metamorphosed limestone, dolostone. and marble nl.snAmngR- A taiiw,,y if nn,tahfr hazard baa is slotted I,, be runt a: nan’s.:? or wghrna? so:ks • The psrpo,e ‘(sheiks, sen in’ so g’w general ,nih,ni,s,n of into, ihat mm he ,nsceØxhk so hazard, Is • In moderately to steeply dipping beds of carbonate rock Commonwealth of Virginia I lazard Mitigation Plan 2013 ante, so ,cte,s,h p’senl,ai risk in 7,, (‘ssmm,’n’. caleb mailable bit,: has been nsed hessind :1w angreul nie,,t Appendix C

Headwaters Soil and Water Consen’ation District’s Letter Addressing Dam Safety in Regard to Pipeline Construction Headwaters Soil and Water Conservation District 70 Dick Huff Lane Verona, VA 24482 ISWCD (540) 248-0148 www.headwatersswcd.org Wework with the wople who work ‘he land.

December 17, 2014

Federal Energy Regulatory Commission 688 Firsi Street, NE Washington, D.C. 20426

Docket#: PFI5-6-000 RE: Protection of Flood Control Dams

Headwaters Soil and Water Conservation District (SWCD) received pre-filling notification as a landowner and owner of easements affected within the proposed Atlantic Coast Pipeline.

The Headwaters SWCD has the operation and maintenance responsibility for eleven (II) flood control dams in Augusta County. Virginia. The proposed pipeline will cross a section of the county that has the potential to impact a number of those dams depending on the final route. These dams protect as many as 800 properties and hundreds of lives downstream in Augusta County and the City of Waynesboro.

To protect those properties and lives we request the following protections be a mandatory part of any federal approvals:

• Any easements obtained by Atlantic Coast Pipeline. LLC or its subsidiaries with landowmersmust protect the rights the district has under the existing easements to constmct. operate and maintain the dam.

• The pipeline cannot be installed through the embankment or the auxiliary (emergency) spiliway.

• Atlantic Coast Pipeline. LLC or its subsidiaries must avoid impacts such as damage to roads to and from the dams.

• Atlantic Coast Pipeline, LLC or its subsidiaries must adhere to all federal, state and local erosion and sediment control regulations to avoid possible soil erosion that may find its way to the reservoirs and cause deposition issues in the pooi. • Blasting is prohibited within three quarters of a mile (3/4 mile) distance of the dam because of shaking of the embankment caused by the pipeline construction. All rock must be removed within this distance with rock breakers on an excavator in lieu of blasting. Shaking of the embankment may lead to dam failure upon the next storm fill.

• Blasting between three quarters of a mile and one and a quarter mile distance (3/4 — 11/4 mile) of a dam will require a monitoring plan to ensure that nothing happened to the dam’s embankment.

Attached is a map with the location of dams within the county. The Headwaters SWCD asks that these safeguards for public safety be included as a part of any approvals.

Sincerely, gcahatc( A%/ct/1 Richard Shifiet, Chairman cc: Carole A. McCoy Atlantic Coast Pipeline 701 E. Cary Street, Richmond, VA 23219

Augusta County Board of Supervisors City of Staunton — Council City of Waynesboro - Council

Enclosure