20140957 Ver 2_NC 401 Water Certification for ACP_20170819

Strickland, Bev
From:Alexandra Drown <[e-mail]>
Sent:Saturday, August 19, 2017 12:57 PM
To:SVC_DENR.publiccomments
Subject:NC 401 Water Certification for ACP
Hello,

I'm writing to share my thoughts on the NC 401 Water Certification, playing a critical role in the permitting of
the proposed Atlantic Coast Pipeline.

Thank you for taking the time to consider this.

Impacts on Groundwater
The ACP 401 application and construction detail fail to acknowledge the likely impacts of
construction and pipeline operation on local groundwater or to ensure measures will be taken
to prevent them. The project could decrease groundwater recharge, thus decreasing the
groundwater discharge to streams and wetlands, as well, thus decreasing stream baseflow and
ability to maintain the water level in wetlands during dry periods.
Trench construction and backfill changes the ability of water to flow (conductivity) through
impacted soils, which can cause preferential flow of groundwater or blocked flow. Higher
conductivity can cause an aquifer to drain more quickly and ease the pathway for contaminants
to reach wetlands and streams. Lower conductivity backfill would restrict groundwater flow
that intersects the trench. possibly diverting it from its natural discharge point.
For most of its length in NC, the ACP would be located above the Northern Coastal Plain Aquifer
system, especially vulnerable to contamination, with uppermost sand aquifers at shallow
depths being susceptible to human activities. Given the large number of households within ½
mile of the ACP corridor dependent on well water, construction could impact many household
water supplies. Also, areas of shallow bedrock must be surveyed for heavy metals, radioactive
materials and acid-producing rocks with potential to contaminate nearby water sources.
There are a large number of private wells within 150 ft. of the pipeline workspace in Nash,
Johnston and Cumberland Counties At the time of the DEIS release, ACP and its contractors had
not completed a survey of wells within 150 ft. due to lack of survey access. A 150 ft. buffer
between water wells and the construction workspace is not adequate. Approximate locations
for wells within 500 feet of construction workplace could be facilitated by GIS location of all
residences outside city limits or locations of public water utilities’ groundwater sources.
Surface disturbances, clearing and trenching can impact both surface water drainage and
groundwater recharge patterns, with the largest impacts to shallow surficial aquifers. No
protocols are in place to prevent impacts such as compaction from affecting recharge of
shallow aquifers or infiltration of toxic or hazardous materials, including fuels, oils, lubricants,
hydraulic fluids, and explosives.
ACP says it will test wells and springs within 150 feet of the construction workspace (within 500
feet of the construction workspace onlyin karst terrain). In addition to well yields, water quality
parameters to be tested include pH, total suspended solids, total dissolved solids, oil and grease
and a range of inorganic contaminants. The well testing, both before and after construction, Impacts on
Groundwater
The ACP 401 application and construction detail fail to acknowledge the likely impacts of
construction and pipeline operation on local groundwater or to ensure measures will be taken
1

to prevent them. The project could decrease groundwater recharge, thus decreasing the
groundwater discharge to streams and wetlands, as well, thus decreasing stream baseflow and
ability to maintain the water level in wetlands during dry periods.
Trench construction and backfill changes the ability of water to flow (conductivity) through
impacted soils, which can cause preferential flow of groundwater or blocked flow. Higher
conductivity can cause an aquifer to drain more quickly and ease the pathway for contaminants
to reach wetlands and streams. Lower conductivity backfill would restrict groundwater flow
that intersects the trench. possibly diverting it from its natural discharge point.
For most of its length in NC, the ACP would be located above the Northern Coastal Plain Aquifer
system, especially vulnerable to contamination, with uppermost sand aquifers at shallow
depths being susceptible to human activities. Given the large number of households within ½
mile of the ACP corridor dependent on well water, construction could impact many household
water supplies. Also, areas of shallow bedrock must be surveyed for heavy metals, radioactive
materials and acid-producing rocks with potential to contaminate nearby water sources.
There are a large number of private wells within 150 ft. of the pipeline workspace in Nash,
Johnston and Cumberland Counties At the time of the DEIS release, ACP and its contractors had
not completed a survey of wells within 150 ft. due to lack of survey access. A 150 ft. buffer
between water wells and the construction workspace is not adequate. Approximate locations
for wells within 500 feet of construction workplace could be facilitated by GIS location of all
residences outside city limits or locations of public water utilities’ groundwater sources.
Surface disturbances, clearing and trenching can impact both surface water drainage and
groundwater recharge patterns, with the largest impacts to shallow surficial aquifers. No
protocols are in place to prevent impacts such as compaction from affecting recharge of
shallow aquifers or infiltration of toxic or hazardous materials, including fuels, oils, lubricants,
hydraulic fluids, and explosives.
ACP says it will test wells and springs within 150 feet of the construction workspace (within 500
feet of the construction workspace onlyin karst terrain). In addition to well yields, water quality
parameters to be tested include pH, total suspended solids, total dissolved solids, oil and grease
and a range of inorganic contaminants. The well testing, both before and after construction,Impacts on
Groundwater
The ACP 401 application and construction detail fail to acknowledge the likely impacts of
construction and pipeline operation on local groundwater or to ensure measures will be taken
to prevent them. The project could decrease groundwater recharge, thus decreasing the
groundwater discharge to streams and wetlands, as well, thus decreasing stream baseflow and
ability to maintain the water level in wetlands during dry periods.
Trench construction and backfill changes the ability of water to flow (conductivity) through
impacted soils, which can cause preferential flow of groundwater or blocked flow. Higher
conductivity can cause an aquifer to drain more quickly and ease the pathway for contaminants
to reach wetlands and streams. Lower conductivity backfill would restrict groundwater flow
that intersects the trench. possibly diverting it from its natural discharge point.
For most of its length in NC, the ACP would be located above the Northern Coastal Plain Aquifer
system, especially vulnerable to contamination, with uppermost sand aquifers at shallow
depths being susceptible to human activities. Given the large number of households within ½
mile of the ACP corridor dependent on well water, construction could impact many household
water supplies. Also, areas of shallow bedrock must be surveyed for heavy metals, radioactive
materials and acid-producing rocks with potential to contaminate nearby water sources.
There are a large number of private wells within 150 ft. of the pipeline workspace in Nash,
Johnston and Cumberland Counties At the time of the DEIS release, ACP and its contractors had
not completed a survey of wells within 150 ft. due to lack of survey access. A 150 ft. buffer
between water wells and the construction workspace is not adequate. Approximate locations
for wells within 500 feet of construction workplace could be facilitated by GIS location of all
2

residences outside city limits or locations of public water utilities’ groundwater sources.
Surface disturbances, clearing and trenching can impact both surface water drainage and
groundwater recharge patterns, with the largest impacts to shallow surficial aquifers. No
protocols are in place to prevent impacts such as compaction from affecting recharge of
shallow aquifers or infiltration of toxic or hazardous materials, including fuels, oils, lubricants,
hydraulic fluids, and explosives.
ACP says it will test wells and springs within 150 feet of the construction workspace (within 500
feet of the construction workspace onlyin karst terrain). In addition to well yields, water quality
parameters to be tested include pH, total suspended solids, total dissolved solids, oil and grease
and a range of inorganic contaminants. The well testing, both before and after construction, Impacts on
Groundwater
The ACP 401 application and construction detail fail to acknowledge the likely impacts of
construction and pipeline operation on local groundwater or to ensure measures will be taken
to prevent them. The project could decrease groundwater recharge, thus decreasing the
groundwater discharge to streams and wetlands, as well, thus decreasing stream baseflow and
ability to maintain the water level in wetlands during dry periods.
Trench construction and backfill changes the ability of water to flow (conductivity) through
impacted soils, which can cause preferential flow of groundwater or blocked flow. Higher
conductivity can cause an aquifer to drain more quickly and ease the pathway for contaminants
to reach wetlands and streams. Lower conductivity backfill would restrict groundwater flow
that intersects the trench. possibly diverting it from its natural discharge point.
For most of its length in NC, the ACP would be located above the Northern Coastal Plain Aquifer
system, especially vulnerable to contamination, with uppermost sand aquifers at shallow
depths being susceptible to human activities. Given the large number of households within ½
mile of the ACP corridor dependent on well water, construction could impact many household
water supplies. Also, areas of shallow bedrock must be surveyed for heavy metals, radioactive
materials and acid-producing rocks with potential to contaminate nearby water sources.
There are a large number of private wells within 150 ft. of the pipeline workspace in Nash,
Johnston and Cumberland Counties At the time of the DEIS release, ACP and its contractors had
not completed a survey of wells within 150 ft. due to lack of survey access. A 150 ft. buffer
between water wells and the construction workspace is not adequate. Approximate locations
for wells within 500 feet of construction workplace could be facilitated by GIS location of all
residences outside city limits or locations of public water utilities’ groundwater sources.
Surface disturbances, clearing and trenching can impact both surface water drainage and
groundwater recharge patterns, with the largest impacts to shallow surficial aquifers. No
protocols are in place to prevent impacts such as compaction from affecting recharge of
shallow aquifers or infiltration of toxic or hazardous materials, including fuels, oils, lubricants,
hydraulic fluids, and explosives.
ACP says it will test wells and springs within 150 feet of the construction workspace (within 500
feet of the construction workspace onlyin karst terrain). In addition to well yields, water quality
parameters to be tested include pH, total suspended solids, total dissolved solids, oil and grease
and a range of inorganic contaminants. The well testing, both before and after construction,Impacts on
Groundwater
The ACP 401 application and construction detail fail to acknowledge the likely impacts of
construction and pipeline operation on local groundwater or to ensure measures will be taken
to prevent them. The project could decrease groundwater recharge, thus decreasing the
groundwater discharge to streams and wetlands, as well, thus decreasing stream baseflow and
ability to maintain the water level in wetlands during dry periods.
Trench construction and backfill changes the ability of water to flow (conductivity) through
impacted soils, which can cause preferential flow of groundwater or blocked flow. Higher
conductivity can cause an aquifer to drain more quickly and ease the pathway for contaminants
3

to reach wetlands and streams. Lower conductivity backfill would restrict groundwater flow
that intersects the trench. possibly diverting it from its natural discharge point.
For most of its length in NC, the ACP would be located above the Northern Coastal Plain Aquifer
system, especially vulnerable to contamination, with uppermost sand aquifers at shallow
depths being susceptible to human activities. Given the large number of households within ½
mile of the ACP corridor dependent on well water, construction could impact many household
water supplies. Also, areas of shallow bedrock must be surveyed for heavy metals, radioactive
materials and acid-producing rocks with potential to contaminate nearby water sources.
There are a large number of private wells within 150 ft. of the pipeline workspace in Nash,
Johnston and Cumberland Counties At the time of the DEIS release, ACP and its contractors had
not completed a survey of wells within 150 ft. due to lack of survey access. A 150 ft. buffer
between water wells and the construction workspace is not adequate. Approximate locations
for wells within 500 feet of construction workplace could be facilitated by GIS location of all
residences outside city limits or locations of public water utilities’ groundwater sources.
Surface disturbances, clearing and trenching can impact both surface water drainage and
groundwater recharge patterns, with the largest impacts to shallow surficial aquifers. No
protocols are in place to prevent impacts such as compaction from affecting recharge of
shallow aquifers or infiltration of toxic or hazardous materials, including fuels, oils, lubricants,
hydraulic fluids, and explosives.
ACP says it will test wells and springs within 150 feet of the construction workspace (within 500
feet of the construction workspace onlyin karst terrain). In addition to well yields, water quality
parameters to be tested include pH, total suspended solids, total dissolved solids, oil and grease
and a range of inorganic contaminants. The well testing, both before and after construction Impacts on
Groundwater
The ACP 401 application and construction detail fail to acknowledge the likely impacts of
construction and pipeline operation on local groundwater or to ensure measures will be taken
to prevent them. The project could decrease groundwater recharge, thus decreasing the
groundwater discharge to streams and wetlands, as well, thus decreasing stream baseflow and
ability to maintain the water level in wetlands during dry periods.
Trench construction and backfill changes the ability of water to flow (conductivity) through
impacted soils, which can cause preferential flow of groundwater or blocked flow. Higher
conductivity can cause an aquifer to drain more quickly and ease the pathway for contaminants
to reach wetlands and streams. Lower conductivity backfill would restrict groundwater flow
that intersects the trench. possibly diverting it from its natural discharge point.
For most of its length in NC, the ACP would be located above the Northern Coastal Plain Aquifer
system, especially vulnerable to contamination, with uppermost sand aquifers at shallow
depths being susceptible to human activities. Given the large number of households within ½
mile of the ACP corridor dependent on well water, construction could impact many household
water supplies. Also, areas of shallow bedrock must be surveyed for heavy metals, radioactive
materials and acid-producing rocks with potential to contaminate nearby water sources.
There are a large number of private wells within 150 ft. of the pipeline workspace in Nash,
Johnston and Cumberland Counties At the time of the DEIS release, ACP and its contractors had
not completed a survey of wells within 150 ft. due to lack of survey access. A 150 ft. buffer
between water wells and the construction workspace is not adequate. Approximate locations
for wells within 500 feet of construction workplace could be facilitated by GIS location of all
residences outside city limits or locations of public water utilities’ groundwater sources.
Surface disturbances, clearing and trenching can impact both surface water drainage and
groundwater recharge patterns, with the largest impacts to shallow surficial aquifers. No
protocols are in place to prevent impacts such as compaction from affecting recharge of
shallow aquifers or infiltration of toxic or hazardous materials, including fuels, oils, lubricants,
hydraulic fluids, and explosives.
4

ACP says it will test wells and springs within 150 feet of the construction workspace (within 500
feet of the construction workspace onlyin karst terrain). In addition to well yields, water quality
parameters to be tested include pH, total suspended solids, total dissolved solids, oil and grease
and a range of inorganic contaminants. The well testing, both before and after construction,must include all
water supply wells within 500 feet of the construction workspace (rather than
150) and include ALL substances which could impact groundwater, including explosives,
lubricants, and components of natural gas liquids. All well tests must be performed by certified
labs to detection levels below NC groundwater (2L) standards. Results must be reported to well
owners and DEQ within 20 days, with instructions for initiating a contamination claim.
Possible contaminated sites that could be disturbed during construction include one Superfund
site and 3 brownfield sites located in NC close to the main pipeline, as well as 9 leaking
underground storage tank sites. These sites must be well marked and well testing within 1,00
feet must include all known contaminants of concern.
All pollution prevention plans prepared by ACP to avoid or minimize impacts during
construction and operation must be readily available to the public in plain language, and
reviewed as part of the permit. The enforcement of construction violations at all stages must be
transparent. Refueling or handling of fuels and other toxic or hazardous materials must be
prevented within 500 feet of wetlands, private water supplies or municipal water supply wells.

Regards,
Alex Drown
350 Asheville/ACP Group Leader

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