20181638 Ver 1_Appx I Horizontal Directional Drill Cont Plan_20181130

M Mountain Valley Joint Permit Application
PIPELINEJu USACE — Wilmington District and NCDEQ
SAW -2018-008887
MVP Southgate Project
Standard Joint Permit Application
U.S. Army Corps of Engineers —
Wilmington District (SAW -2018-00887)
North Carolina Department of
Environmental Quality,
Division of Water Resources
Appendix I
HDD Contingency Plan
November 2018

Mountain Valley
MVP Southgate Project
Horizontal Directional Drill Contingency Plan
November 2018

IT Mountain Valley
PIPELINE Horizontal Directional Drill Contingency Plan
TABLE OF CONTENTS
1.0
INTRODUCTION.............................................................................................................. 1
2.0
PURPOSE...........................................................................................................................1
3.0
PREPARATION................................................................................................................. 1
4.0
TRAINING......................................................................................................................... 2
5.0
EQUIPMENT..................................................................................................................... 2
6.0
DRILLING PROCEDURES............................................................................................... 3
7.0
TERRESTRIAL IR PROCEDURES.................................................................................. 3
8.0
AQUATIC (UNDERWATER) IR PROCEDURES........................................................... 4
9.0
POTENTIAL PRIVATE WATER SUPPLY IMPACTS ................................................... 5
10.0
ABANDONMENT AND ALTERNATIVE CROSSINGS ................................................ 5
11.0
REQUIRED NOTIFICATIONS......................................................................................... 5
12.0
REFERENCES................................................................................................................... 6
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PIPELINE
IR
Project or Southgate Project
Horizontal Directional Drill Continqencv Plan
ACRONYMS
Horizontal Directional Drilling
inadvertent return
MVP Southgate Project
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PIPELINE Horizontal Directional Drill Continqencv Plan
1.0 INTRODUCTION
Horizontal Directional Drilling ("HDD") is a trenchless excavation method that is accomplished in three
phases. The first phase consists of drilling a small diameter pilot hole along a designed directional path.
The second phase consists of enlarging the pilot hole to a diameter suitable for installation of the pipe. The
third phase consists of pulling the pipe into the enlarged hole. HDD is accomplished using a specialized
horizontal drilling rig with ancillary tools and equipment. A properly executed HDD crossing will allow
for the pipeline to be installed in a minimally invasive manner.
The HDD method is proposed for the MVP Southgate Project ("Project" or "Southgate Project") crossings
in North Carolina of the Dan River in Rockingham County and Stony Creek Reservoir in Alamance County.
The inadvertent return ("IR") of drilling lubricant is a potential concern when HDD methods are utilized.
The HDD procedure for these crossings will utilize bentonite for drilling lubricant. In general, IRs can occur
as a result of existing rock fractures, low density soils, or unconsolidated geology. There is a potential for
inadvertent returns to directly impact surface and ground waters via existing or enhanced fracture zones or
if there is a release upland which flows over ground into wetlands or streams.
2.0 PURPOSE
The purpose of this Contingency Plan is to:
• Minimize the potential for an IR associated with horizontal directional drilling activities.
• Provide for the timely detection of an IR.
• Protect areas that are considered environmentally sensitive (streams, wetlands, other biological
resources, cultural resources).
• Provide an organized, timely, and "minimum -impact" response in the event of an IR.
• Provide that all appropriate notifications are made to the North Carolina Department of
Environmental Quality and other appropriate regulatory agencies, and that documentation is
completed.
• Provide an alternative crossing method if the HDD is deemed unsuccessful.
3.0 PREPARATION
Prior to implementation of the HDD, the Southgate Project and the contractor will identify the potential for
inadvertent releases at the HDD location. The review will include a visual review of entry and exit points,
and entire HDD drill path. The contractor will review the Project's HDD Geotechnical Investigations
Report, which may include descriptions of subsurface conditions, laboratory testing, design
recommendations, and construction recommendations.
In addition, private water supplies within 150 feet, if identified, will be protected by implementing the
following measures:
• The drilling contractor will review the site conditions prior to the start of work.
• Construction limits will be clearly marked.
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Horizontal Directional Drill Continqencv Plan
• Barriers will be erected between the bore site and nearby sensitive resources prior to drilling as per
the Project -specific Erosion and Sediment Control Plan.
• On-site briefings will be conducted for the workers to identify and locate sensitive resources at the
site.
• Provide that all field personnel understand their responsibility for timely reporting of IRs.
• Maintaining necessary response equipment on-site and in good working order.
The primary areas of concern for IRs occur at the entrance and exit points where the drilling equipment is
generally at their shallowest depths. The likelihood of an IR decreases as the depth of the pipe increases.
To minimize the potential extent of impacts from an IR, HDD operations will be continuously monitored
to look for observable IR conditions or lowered pressure readings on the drilling equipment. Early detection
is essential to minimizing the area of potential impact.
No oil or gas wells were identified within 0.25 mile of the Project areas based on review of Virginia and
North Carolina databases (VDMME, 2018 and NCGS, 2016).
4.0 TRAINING
Prior to the start of construction, the Site Supervisor/Foreman will ensure that the crew members receive
training on the following:
• The provisions of this Contingency Plan.
• Inspection procedures for IR prevention and containment equipment materials.
• Contractor/crew obligation to immediately stop the drilling operation upon first evidence of the
occurrence of an IR and to immediately report any IRs to the Project's Environmental Inspector
and Environmental Coordinator.
• Contractor/crew member responsibilities in the event of an IR.
• Operation of release prevention and control equipment and the location of release control materials,
as necessary and appropriate.
• Protocols for communication with agency representatives who might be on site during the clean-
up effort.
• Copies of this contingency plan and the contractor's site specific contingency plan will be
maintained at the HDD entry and exit sites in a visible and accessible location at all times.
5.0 EQUIPMENT
The Site Supervisor will verify that:
• All equipment and vehicles are inspected and maintained daily to prevent leaks of hazardous
materials.
• Spill kits and spill containment materials are available on-site at all times and that the equipment
is in good working order.
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Horizontal Directional Drill Continqencv Plan
• Equipment required to contain and clean up an IR is available at the bore sites during drilling
activities.
*NOTE: It is the drilling contractor's responsibility to provide any IR containment materials that are
necessary to respond to the release of drill fluids. The materials listed in this contingency plan are not to be
considered inclusive and may require additional equipment depending on site conditions.
6.0 DRILLING PROCEDURES
Drilling pressures will be closely monitored so they do not exceed those needed to penetrate the formation.
Pressure levels will be monitored continuously by the operator. Pressure levels will be set at a minimum
level to reduce the risk of IRs. During the pilot bore, maintain the drilled annulus. Cutters and reamers will
be pulled back into previously drilled sections after each joint of pipe is added.
Entry and exit pits will be enclosed by sediment barriers as specified in the Project -specific Erosion and
Sediment Control Plan and straw bales. A spill kit will be on-site and used if an IR occurs. Except as noted
below, a vacuum truck will be readily available on-site prior to and during all drilling operations. Per the
Project's Spill Prevention, Control, and Countermeasure plan, containment materials (straw, fabric filter
fence, sand bags, spill kits, boom and turbidity curtain, etc.) will be staged on-site at a location where they
are readily available and easily mobilized for immediate use in the event of an IR. Filter Fence or Filter
Sock will be installed between the bore sites and the edge of water sources prior to drilling.
If the site of the IR is not able to be accessed by a vacuum truck, a pump with sufficient power to convey
the released drill fluid to a containment area will be used instead. Along with the pump, an adequate amount
of hose, several filter bags, straw bales, sand bags, and 18" Fabric Filter Fence (or Compost Filter Sock)
will be kept on site to create a containment area on site.
Once the drill rig is in place and drilling begins, the drill operator will stop work immediately whenever the
pressure in the drill rig drops or there is a lack of returns in the entrance pit. At this time the Site
Supervisor/Foreman will be informed of the potential IR. The Site Supervisor/Foreman and the drill rig
operator(s) will work to coordinate the likely location of the IR. The location will be recorded and notes
made on the location and measures taken to address the concern. Measures will then be taken according to
the type of IR (i.e. Terrestrial or Aquatic) as listed below. The Site Supervisor/Foreman will then begin
notifying the appropriate parties as listed in the "Contacts" section of this document.
Water containing mud, silt, drilling fluid, or other materials from equipment washing or other activities,
will not be allowed to enter a lake, flowing stream, or any other water source. The bentonite used in the
drilling process will be either disposed of at an approved disposal facility or recycled in an approved
manner. Other construction materials and wastes will be recycled, or disposed of, as appropriate.
7.0 TERRESTRIAL IR PROCEDURES
• Stop work immediately.
• The bore stem will be pulled back to relieve pressure on the IR.
• Isolate the area with hay bales, sand bags, filter sock, or silt fencing to surround and contain the
drilling mud.
• Determine and document the following to the extent reasonably possible:
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o Quantity (gallons) of material released
o Distance (feet) to the nearest waterbody
o Name of the waterbody affected, if any
Horizontal Directional Drill Continqencv Plan
• Immediately contact the appropriate parties as listed in the "Required Notifications" section at the
end of this document.
• A mobile vacuum truck (or pump if in an inaccessible area) will be used to pump the drilling mud
from the contained area and into either a return pit or (if using a pump) into a filter bag surrounded
by 18" Fabric Filter Fence or Compost Filter Sock.
• Once excess drilling mud is removed, the area will be seeded and/or replanted using species similar
to those in the adjacent area, or allowed to re -grow from existing vegetation.
• When there is no visible indication of flow at the IR location, the IR will be considered stabilized.
After the IR is stabilized, document the IR from discovery through post -cleanup conditions with
photographs and prepare an IR incident report describing time, place, actions taken to remediate IR, and
measures implemented to prevent recurrence. The incident report will be provided to the Project
Environmental Coordinator within 24 hours of the occurrence.
8.0 AQUATIC (UNDERWATER) IR PROCEDURES
• Stop work immediately.
• The bore stem will be pulled back to relieve pressure on the IR.
• Isolate the area with hay bales, sand bags (cofferdam), plastic sheeting, filter sock, silt fence or
other appropriate containment structure to surround and contain the IR;
• Immediately contact the appropriate parties as listed in the "Required Notifications" section at the
end of this document.
• Utilize clean water pumps to establish a pump around to convey upstream flow around the IR;
• Turbidity curtains may be deployed (depending on site conditions at time of IR);
• Determine and document the following to the extent reasonably possible:
o Quantity (gallons) of the IR
o Quantity (gallons) that was released to the waterbody
o Distance (feet) the material traveled down the waterbody
o Name of the affected waterbody
• A mobile vacuum truck (or pump if in an inaccessible area) will be used to pump the drilling mud
from the contained area and into either a return pit or (if using a pump) into a filter bag surrounded
by 18" Fabric Filter Fence or Compost Filter Sock.
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• Drilling mud will be collected and typically recycled through the drilling mud reclaimer, reused or
disposed of at a licensed disposal facility.
• When there is no visible indication of flow at the IR location, the IR will be considered stabilized.
After the IR is stabilized, document the IR from discovery through post -cleanup conditions with
photographs and prepare an IR incident report describing time, place, actions taken to remediate IR, and
measures implemented to prevent recurrence. The incident report will be provided to the Project
Environmental Coordinator within 24 hours of the occurrence.
9.0 POTENTIAL PRIVATE WATER SUPPLY IMPACTS
If an IR impacts a private drinking water supply, the Southgate Project will supply temporary drinking
water supply in accordance with the Project's Water Resources Identification and Testing Plan immediately
after the problem is discovered. The temporary water would be supplied until testing confirms that the water
quality of the water supply returns to baseline. Additional long-term measures will be employed in
accordance with the Water Resources Identification and Testing Plan if necessary, including the installation
of permanent treatment, connection to a secondary water source, or establishment of a new on-site source.
10.0 ABANDONMENT AND ALTERNATIVE CROSSINGS
If the HDD installation is unsuccessful and the Southgate Project determines abandonment of the HDD is
necessary, the Project's proposed alternative is to use the Contingency Plan. The Contingency Plan includes
implementation of an open cut dry ditch crossing method. This alternative crossing method would require
Federal Energy Regulatory Commission and other environmental permitting approvals.
11.0 REQUIRED NOTIFICATIONS
In the event of an IR, the following parties are to be notified IMMEDIATELY: EQM Midstream Partners,
LP Environmental Team:
Mr. Cory Chalmers
Environmental Coordinator 304-848-0061 (office)
304-627-8173 (cell)
Ms. Megan Stahl
Environmental Permitting - Supervisor 412-553-7783 (office)
412-737-2587 (cell)
Ms. Hanna McCoy
Director - Environmental Permitting 724-873-3476 (office)
412-216-9316 (cell)
Include the following information:
• Time the spill was first identified
• Description of where the spill occurred — Project MP/Station
• Latitude and Longitude of spill
• Size of spill and control measures in place
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• Name of affected water resource (if known/applicable)
Photographs of spill area and corrective measures — when available. (Do not wait to notify the
Project until pictures are available. Photo documentation should begin immediately upon detection
and continued throughout the duration of the cleanup).
The Southgate Project Environmental Department will contact State and/or Federal environmental agencies
(if applicable) for notification requirements in the event of an IR.
12.0 REFERENCES
This Contingency Plan was adapted from the following websites:
http://www.blm. gov/pgdata/etc/medialib/blm/wy/information/NEPA/cfodocs/greencore.Par.0871.File. dat/
P ODappH.pdf
https://www.csx.com/index.cfin/library/files/customers/property-real-estate/permitting/sample-fraction-
mitigation-plan/
http://www. energy. ca.gov/sitingcases/smud/documents/applicants_files/Data_Response_Set-
1 Q/APPENDIX_C_FRAC_OUT_PLAN3.PDF
Other References include:
Virginia Department of Environmental Quality (VDEQ). 2018. Division of Mineral Mining. Available
online at: https://dmme.virginia.gov/DMM/uraniumpermit.shtml Accessed July 19, 2018.
North Carolina Geological Survey (NCGS). 2016. NC Oil and Gas Wells. Available online at:
https://files.nc. gov/ncdeq/Energy%20Mineral%20and%20Land%20Resources/Energy/documents/Energy
/NC—Oil—%26—Gas Wells_terrane_plot.jpg Accessed July 16, 2018.
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