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W PIPELINE uc
MVP Southgate Project
Appendix O
Water Resources Identification and Testing Plan
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PIPELINE Water Resources Identification and Testing Plan
TABLE OF CONTENTS
1.0
WATER RESOURCES IDENTIFICATION AND TESTING PLAN............................................1
2.0
IDENTIFYING WATER RESOURCES.........................................................................................1
2.1 Private Wells and Springs................................................................................................... 1
2.2 Public Water Supplies......................................................................................................... 2
3.0
WATER RESOURCE EVALUATION.......................................................................................... 2
3.1 Private Water Supplies........................................................................................................ 2
3.2 Public Water Suppliers....................................................................................................... 4
4.0
POST -CONSTRUCTION BASELINE WATER RESOURCE TESTING.....................................4
5.0
COMPLAINT RESOLUTION PROCESS......................................................................................5
6.0
REFERENCES................................................................................................................................ 5
LIST OF TABLES
Table 1 Private Water Supplies for Water Quality and Quantity Testing
Table 2 Target Analytes for Private Water Supply Testing
APPENDICES
Appendix A Information to be Collected from Water Supply Owners
Appendix B Private Well Yield Testing Protocol
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1.0 WATER RESOURCES IDENTIFICATION AND TESTING PLAN
The MVP Southgate Project ("Project" or "Southgate Project") prepared and will execute the
terms of this Water Resources Identification and Testing Plan ("Plan") to document pre -
construction (baseline) and post -construction water quality and quantity of privately owned
water supply systems.
This Plan summarizes protocols for identifying and assessing water supplies in the vicinity of the
Project and related components. The Project documented locations and characteristics of private
water supplies within 150 feet of the construction workspaces. The Project will conduct pre -
construction testing of private wells located within 150 feet of the construction workspace. Upon
request by a landowner who had a pre -construction test, a post -construction test will be
performed.
This Plan discusses the outreach methodology that will be followed by the Project, and the
general plan for testing.
Private water resources identified for water quality and quantity testing within 150 feet of the
construction workspace are summarized in Table 1. Prior to construction, the private water
supply owners will be contacted by the Project via certified mail to confirm the location and
characteristics of water resource(s) on the owner's property and to request permission for the
Project to conduct water quality and quantity sampling.
Field confirmation of private water sources has not been completed on some parcels because
property access permission has not been granted. Therefore, this Plan is subject to change
following the completion of field environmental investigations.
2.0 IDENTIFYING WATER RESOURCES
2.1 Private Wells and Springs
Private wells and springs located within 150 feet of the construction workspace will be identified
by route alignment civil surveying, as well as desktop review and field observation (where
property access was granted). The private water supply sources will be confirmed through pre -
construction water supply testing (see Table 1) as described in this Plan.
As part of the desktop review for potential drinking water sources an indirect method was
employed to supplement the civil survey to identify potential private wells. GIS data taken from
the various counties were used to identify if a structure was present on the parcel. To maximize
the potential for identifying private water resources all structures were assumed to have one or
more private wells.
As discussed in this Plan, the property owners identified by civil survey, and desktop review,
along the Project route will be contacted by the Project prior to construction via certified mail to
confirm drinking water sources on the identified property and to request permission to conduct
water quality and quantity testing.
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If a private property owner does not respond to the certified mail request for information within
approximately four (4) weeks of submittal by the Project, a second request will be sent. If no
response is provided to the Project through the second submittal, no further contacts will be
initiated with the property owner regarding water resources.
Private well and spring locations identified to date as described above, are listed in Table 1.
Appendix A provides a list of information that will be requested from the water supply owners
during the initial contact along with a request for permission to sample the water supply.
2.2 Public Water Supplies
Public water suppliers in Virginia and North Carolina were identified from publicly available
data sources (VDEQ, 2018, NCDEQ, 2018). Specific locations and conditions of the water
supply sources (wells, springs or surface water intakes) will be confirmed through contacts with
the public supply owner or operator.
3.0 WATER RESOURCE EVALUATION
The following discussion outlines protocols water supply testing activities. The testing results
will be documented by the Southgate Project and provided directly to the water supply owner.
3.1 Private Water Supplies
1. The Southgate Project will conduct pre -construction testing of all private wells located
within 150 feet of the construction workspace. The Project will conduct post -
construction tests if requested by a landowner who had a pre -construction test. The
Project proposes to collect one sample approximately six (6) months before construction,
and a second sample within three (3) months prior to construction, and conduct a well
yield test (protocol described below).
2. All private property owners with a known or suspected water source (see earlier
discussion) will be contacted prior to construction as discussed below:
a. Send contact by mail to mailing address listed for the property owner;
b. If no response is received within approximately 4 weeks of sending the first letter, a
second follow-up letter will be sent;
c. If no response is provided by property owner after two (2) attempts this result will be
documented and the Project will suspend further contact to the property owner
regarding water quality testing;
d. If a property owner declines permission for the Project to conduct water quality
testing, this will be documented and the Project will suspend further contact with the
property owner regarding water quality testing;
3. Property and water supply access approval documentation will be secured by the Project
before entering the property. The property / supply owner will be notified prior to the
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Project entering the property for sampling. See Appendix A for information to be
collected from the water supply owner during initial and follow-up contact.
4. A two -person field crew will be deployed to collect water samples at the identified
locations.
5. The sampling location coordinates will be collected using GPS (1 -meter resolution) and
recorded.
6. Field testing, sample collection and sample management techniques will be implemented
consistent with industry standards and approved guidance (U.S. EPA, Virginia
Department of Environmental Quality and North Carolina Department of Environmental
Quality).
7. For surface water resources, a decontaminated or new one -time -use sample collection
device suitable for the surface water resource will be inserted in a flowing portion of the
spring or stream and the water sample transferred directly to the appropriate sample
container provided by the laboratory.
8. A decontaminated field meter will be inserted in a flowing portion of the spring or
stream, and the field parameters recorded along with date and time.
9. For water well testing, a water sample will be collected from a flowing spigot (after a
minimum of 10 minutes purging) upstream of any treatment system (if applicable) in
order to collect a raw water sample in the appropriate laboratory -prepared sample bottle
with appropriate preservatives. Field parameters will be analyzed at the time of water
sample collection.
a. If the well does not have a pump installed, or does not demonstrate artesian flow, a
new, disposable one-time use bailer and clean nylon string will be used to collect the
water sample. There will be limited ability to purge the well bore of water using the
bailer.
10. Water samples will be kept cool and transported \ to the analytical laboratory(ies) under
Chain of Custody.
11. The target analyte list is comprised of a general water quality analyte suite and pollutant -
specific suite (Table 2). The baseline target analyte list includes field parameters,
coliform bacteria, major elements and water quality parameters. The expanded target
analyte list adds a full suite of Volatile Organic Compounds and Semivolatile Organic
Compounds included in USEPA drinking water testing methods EPA 524.2, EPA 525.2,
respectively, and Total Petroleum Hydrocarbons buy EPA SW846 8015C.
a. The first pre -construction sampling event will be comprised analysis of the full
expanded target analyte list (Table 2). The second pre -construction sampling event
will include the baseline water quality (reduced list, Table 2) suite, unless there is a
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concern noted by the property owner, or if the Project observers a verified detection
of a VOC or SVOC or TPH from the first sampling event.
b. National Environmental Laboratory Accreditation Program ("NELAP")-accredited
laboratories will be utilized for water sample analyses. For samples collected in Virginia
the laboratories will have current Virginia (V)ELAP accreditation. For samples collected
in North Carolina the laboratories will be certified by the North Carolina Department of
Health and Human Services.
12. Water resources testing activities (including the condition of the water resource and
equipment) will be photo -documented. All field activities and meter calibration for each
water resources sampling event will be documented.
13. The first pre -construction sampling event provided the Project with the opportunity to
evaluate the condition of each well, spring or intake, surrounding topography and land
characteristics and land -use, and generally assess the overall vulnerability of the water
supply to existing or future sources of impact.
14. The Southgate Project will provide the water supply owner with the water supply testing
results. Concurrent with providing the owner these results, the Project will discuss with
the owner any conditions that observed at the water supply that represent potential for
existing or future sources of impacts.
15. The second sampling event will also include well yield testing. The water supply owner
will be apprised of the well yield testing procedure, and the Project will request
permission to access the well for the quantity testing, at the owner's discretion.
16. The Southgate Project will consult with an owner who appears to have a compromised
water supply based on pre -construction sampling results. The Project will tailor an
evaluation protocol for the second round of water quality testing as appropriate to
evaluate the integrity of the water supply and ensure a comprehensive pre -construction
assessment is completed.
3.2 Public Water Suppliers
The Southgate Project will contact and discuss the Project with public water suppliers, and
address specific concerns. The Project is completing water supply contingency planning efforts
for public suppliers that have a surface water intake within three miles down gradient of a
pipeline water body crossing. The Project will communicate directly with the pubic suppliers,
and work directly with specific suppliers for contingency planning.
4.0 POST -CONSTRUCTION BASELINE WATER RESOURCE TESTING
Upon request by a landowner who had a pre -construction test, a post -construction test will be
performed. The Southgate Project will follow the same procedures described above for water
supply sampling, comprehensive target analyte list laboratory analysis and water quantity testing.
The Project will provide the post -construction monitoring results directly to the property owner.
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The Project will maintain water supply contingency planning efforts that are specified in the
respective supplier's Contingency Plan, through the construction period and until final land
reclamation is completed.
5.0 COMPLAINT RESOLUTION PROCESS
The potential for impacts to private water supplies and springs is negligible. However, if a claim
of impact is made by a water supply owner, a thorough investigation of the alleged impact will
be conducted by qualified groundwater and surface water scientists and engineers using industry -
standard hydrogeologic investigative practices. This will include a review of the timing of the
claim relative to the construction schedule, detailed interview with the supply owner, mechanical
evaluation of the water system, possible resampling and analysis of the supply, performance of a
hydrogeologic assessment, and other pertinent evaluations. Because each water supply system
and hydrogeologic setting is unique, the only means to establish a clear link between a water
supply quality or quantity issue and Project activities is through a comprehensive evaluation
leading to complaint resolution.
If the Southgate Project determines that an impact was related to its pipeline construction, then
the investigations described above will provide valuable information concerning the appropriate
remedies. Restoration of a water supply could include:
• temporary supplied water until the water quality returns to baseline;
• connection to secondary on-site sources, if available; and/or
• temporary treatment to establish baseline quality (or better).
If the hydrogeologic assessment indicates that a long term solution is needed, the Project would
provide the following as appropriate to restore water quality and quantity to pre- construction
conditions:
• a permanent treatment system; or
• a new on-site source (new water well); or a combination of source replacement and
treatment options.
6.0 REFERENCES
National Environmental Laboratory Accreditation Program (NELAP), 2016. http://www.nelac-
institute.org/content/NELAP/index.php
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Tables
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Project Mile Post
Table 1.
Private Water Supplies for Water Quality and Quantity Testing
Parcel Number
Water Source
Latitude
Longitude
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PIPELINE Water Resources Identification and Testing Plan
Table 2.
Target Analytes for Private Water Supply Testing
Target Analyte
(baseline water quality)
Notes / Rationale for Testing
pH
Field -measured indicator parameter characterizing the relative acid- base
nature of water and a major indicator of overall water quality.
Specific conductivity (mS/cm)
Field -measured indicator parameter characterizing the dissolved ion content
Calcium and Magnesium (mg/L)
of water and a major indicator of overall water quality.
Temperature (oC)
Field -measured indicator parameter that is a general water quality
descriptor.
Turbidity (turb. units)
Field -measured indicator parameter characterizing the suspended solids
Sodium and Potassium (mg/L)
content of water.
Total and Fecal coliform bacteria
Measures bacteria content of water. Indicator of surface water and / or septic
(MPN/100 ml)
field impact to the water well.
Total dissolved solids (TDS)
Measures amount of charged ions that are dissolved in water. Indicative of
(mg/L)
dissolved mineral content of the water.
Total suspended solids (TSS)
Measures amount of solid material suspended in water. Similar to turbidity
(mg/L)
field indicator, but provides a quantitative assessment of suspended solids
mass.
Hardness (mg/L)
Major water quality indicator. Hardness is commonly used to measure
dissolved calcium and magnesium. "Hard" water is high in dissolved
minerals. Hardness, TDS and Specific conductivity are evaluated in common
to characterize the relative mineralization of groundwater. Report in CaCO3
equivalent (mg/L).
Alkalinity (mg/L)
Measures the ability of water to neutralize acid (buffering capacity) and is
part of an overall water quality indicator. Report in CaCO3 equivalent (mg/L)
Sulfate (mg/L)
Common major anion (negatively -charged compound) in groundwater and at
high concentrations may lead to scaling of plumbing and impart poor taste to
potable water. This is also used to evaluate charge balance (balanced
anions and cations) of the overall water quality data set for each well.
Chloride (mg/L)
Common major anion (negatively charged) that is an indicator of overall salt
content of water. This is also used to evaluate charge balance (balanced
anions and cations) of the overall water quality data set for each well.
Nitrate (total) (mg/L)
Common major anion (negatively charged compound) that is typically used
as an indicator of surface water or septic influence on groundwater. Nitrate
and bacteria analyses are evaluated in tandem to identify potential impacts
to groundwater sources. This is also used to evaluate charge balance
(balanced anions and cations) of the overall water quality data set for each
well.
Bicarbonate (mg/L)
Common major anion (negatively charged compound) used to evaluate
charge balance (balanced anions and cations) of the overall water quality
data set for each well. Evaluating bicarbonate content along with alkalinity
assists in understanding overall water quality.
Calcium and Magnesium (mg/L)
Common major cation (positively charged element) that will assist in
characterizing overall water quality and Hardness, and will be used to
evaluate charge balance (balanced anions and cations) of the overall water
quality data set for each well.
Sodium and Potassium (mg/L)
Common major cation (positively charged element) that will assist in
characterizing overall water quality and to evaluate charge balance
(balanced anions and cations) of the overall water quality data set for each
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Table 2.
Target Analytes for Private Water Supply Testing
Target Analyte Notes / Rationale for Testing
(baseline water quality)
Tables -3 November 2018
well. High levels of sodium may also have health effects for persons with
high blood pressure.
Iron and Manganese (mg/L)
Common major cation (positively charged element) that will assist in
characterizing overall water quality and to evaluate charge balance
(balanced anions and cations) of the overall water quality data set for each
well. These major elements, when dissolved in water at a high enough
concentration, can have aesthetic concerns for staining home fixtures or
affecting laundry.
Volatile Organic Compounds
Volatile organic compounds such as petroleum products, chlorinated
(VOCs); EPA Method 524.2
compounds, solvents and degreasers, industrial chemicals, etc.
Semivolatile Organic Compounds
Semivolatile organic compounds potentially derived from industrial activity
(SVOCs); EPA Method 525.2
and materials.
Total Petroleum Hydrocarbons
Range of petroleum products (see Note 1, below)
(TPH) EPA Method 1664
Note 1: Total Petroleum Hydrocarbon ("TPH") Method 1664 captures a broad range of petroleum related
hydrocarbons (including oil -range, diesel -range, gasoline -range and lighter -range). FERC suggested including Oil
and Grease, but this analysis would capture fats and greases from animals, fry oils, waxes, soap, etc. There is no
reasonable expectation that these types of substances will be associated with pipeline construction. The target
analyte list in Table 3, including Method 1664 TPH, will provide a comprehensive analysis of potential
contaminants in groundwater that would have a reasonably -expected potential derivation from pipeline
construction.
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PIPELINE Water Resources Identification and Testing Plan
Appendix A
Information to be Collected from Water Supply Owners
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1 Route Specific Sort Order
2 Parcel Number(s)
3 APN(s)
4 Name (Last, First or Company)
5 Permission to Enter
6 Date on Form
7 Signed
8 Address Line 1
9 Address Line 2
10 City, State, Zip
11 Telephone Number
12 Email Address
13 Preferred Day/Time of Contact
14 Community or Municipal Water
15 Water Wells
16 Drilled or Dug
17 Used for Drinking
18 Well Depth
19 Treatment System or Filter
20 Other Water Wells
21 Number of Other Wells
22 Drilled or Dug
23 Used for Drinking
24 Well Depth
25 Treatment system
26 Springs
27 Number of Springs
28 Used for Livestock/Irrigation
29 Streams
30 Number of Streams
31 Used for Livestock/Irrigation
32 Other Bodies of Water
33 Number of Other Bodies of Water
34 Description
35 Used for Livestock/Irrigation
36 Comments
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Appendix B
Private Well Yield Testing Protocol
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PIPELINE Water Resources Identification and Testing Plan
The following outlines the methodology for measuring pre -construction well yield at private
water supply wells. Public water supplies have documented production data and this will be used
for pre- construction baseline data.
Two procedures are presented below. The first is well yield testing when the well is accessible
for measuring water level during pumping and recovery. The second is a flow testing protocol
when the well is not accessible, or the property owner does not authorize the Project to access the
well but requests a well yield test.
If the property owner requests a post -construction well yield test, it is critical that the test be
conducted under the same conditions as the pre -construction test, to the extent possible, in order
to provide as accurate a comparison as possible. Since pumping rate and the test duration both
affect the well yield estimate, these parameters need to be nearly the same to compare results of
post -construction to pre -construction tests. If possible, the two tests should be conducted during
the same season of the year because seasonal variation of well recharge can influence the yield
estimate.
Yield Testing Protocol for Accessible Wells - Specific Capacity
The "specific capacity" of a well is the number of gallons of water produced per minute for each
foot of well drawdown.
A test duration of 1 hour at a pumping rate of 5 gallons per minute ("gpm") will be conducted to
estimate well specific capacity.
Procedure
Request that the well owner not operate the well for as long as practical prior to conducting
the test. Record when the owner last used the water system.
Well plumbing fixtures, such as the pressure shutoff switch, sediment filter and pressure tank
may need to be by-passed or disconnected to maintain a stable, steady pumping rate.
Ensure that the discharged water is collected, or discharged away from the well so that it
does not artificially recharge the well.
Measure and record the depth to water from the top of the well casing.
Measure and record the depth to the pump from the top of the well casing, if possible. Record
any pump installation data that are available.
Record time that flow testing begins.
The following measurements should be taken during the pumping period:
Pumping rate — measure at the start of the test; at five minute intervals during the initial
stages of the test; at 10 minute intervals during the latter stages of the test; and at the
conclusion of pumping. Adjust flow controls as necessary to maintain the optimal 5 gpm
pumping rate.
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Water level — measure at the start of the test; at one or two minute intervals during the
first 10 to 20 minutes; at five minute intervals during the remainder of the pumping
period; and at the conclusion of pumping.
Terminate pumping if the water level drops within 5 feet of the pump, so the pump is not
damaged by running it dry.
Record time that flow testing ends.
At the conclusion of the pumping test, commence recovery measurements in accordance with
the following guidelines:
0 — 5 minute interval: every 30 seconds
5 - 10 minute interval: every 60 seconds
10 - 20 minute interval: every two minutes
20 - 60 minute interval: every five minutes
If after one hour the level of recovery is less than 50% of the depth of drawdown, continue to
measure water levels at five minute intervals until water level has recovered to 90% of the
depth of drawdown or until three hours since the start of recovery, whichever occurs first.
Tabulate pumping rate, drawdown and recovery data, and prepare a graph of water level vs.
time.
Well yield can be calculated from specific capacity by multiplying the available drawdown in the
well (the distance between the static water level and the normal pump setting in feet) with the
specific capacity (units in gallons per minute per feet of drawdown), the result having the units
of gpm. This calculated yield takes into consideration both the storage capacity of the well and
the aquifer performance under the limited conditions of the specific capacity test.
SC=R/D
Where: SC = specific capacity (gpm/ft), R = adjusted discharge rate (gpm), and D = total
drawdown (ft.)
R = (Vt - Vs) / t
Where: Vt = total volume of water discharged during test (gallons), Vs = volume of water
discharged from borehole storage (gallons), and t = duration of the test (minutes).
Vs=23.5Dr2
Where: Vs = volume of water discharged from borehole storage (gallons), D = total drawdown
(feet), r = well radius in feet.
(Note, for a standard 6-1/2 inch diameter well, Vs = 1.72 gal./ft. X D) Yield (gpm) = AD x SC
Where: AD = available drawdown (ft) = depth to pump intake - static water level - 5 ft.
Well storage may be overemphasized in specific capacity tests. Unlike a long -duration test of a
high-performance, industrial well, a short -duration test of a low -yielding well, especially a deep
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well, may result in borehole storage water representing most of the water discharged during the
test. A borehole storage problem becomes significant if the specific capacity is then multiplied
by the available drawdown to calculate a yield. A poor -performing, unreliable well can appear to
have a relatively good yield when borehole storage is large relative to the specific capacity.
Mountain Valley will document both specific capacity from the test, and calculated well yield.
Yield Testiniz Protocol for Inaccessible Wells - Peak Demand Test
The Peak Demand Test (PDT) will be used if a well is inaccessible for direct monitoring of water
level during pumping and recovery. The PDT is used to simulate well usage during peak
demands, and does not provide an actual yield value. It only tests a delivery system's ability to
provide water to the user.
Procedure
The test will be performed by running the water from an outdoor spigot or indoor faucet.
If possible, well plumbing fixtures, such as the pressure shutoff switch, sediment filter and
pressure tank may need to be by-passed or disconnected to maintain a stable, steady flow
rate.
Ensure that the discharged water is collected, or discharged away from the well so that it
does not artificially recharge the well.
Open spigot or faucet for flow at 5 gpm for 15 minutes and then stop flow for recovery for 15
minutes.
The on/off pumping cycles are repeated for 4 hours or until the well fails, whichever comes
first.
Record time at the beginning and end of each cycle.
The discharge rate (flow rate) will be recorded every 5 minutes (three times per pumping
cycle).
If the pump intake breaks suction and the discharge rate drops noticeably, record the time
when this occurs.
The parameters of the PDT must be carefully recorded. Maintaining a constant discharge rate can
be difficult to achieve because an in-place water delivery system for a home can be difficult to
control and the discharge rate may decline as the test advances.
Because the PDT does not require entry to the well bore, liability concerns from well damage are
less. The test also provides a means of testing water supplies not physically accessible for water
level measurements. A disadvantage of the test is that the PDT takes longer to perform than the
short -duration specific capacity test. Because of the on -and -off cycles, the PDT will not
adequately test the well if its duration is shortened to less than 4 hours. The PDT should only be
allowed where borehole access requires an extraordinary effort, or the well owner does not
authorize entry.
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