20191435 Ver 1_HDD Contingency Plan_20191018

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HDD Inadvertent Return Contingency Plan
Dominion Energy - Johnson Pond Road
Fuquay-Varina, North Carolina
S&ME Project No. 733519075

HDD Inadvertent Return Contingency Plan
Dominion Energy - Johnson Pond Road
Fuquay-Varina, North Carolina
S&ME Project No. 733519075
Table of Contents
1.0 Introduction.......................................................................................................................1
2.0 Inadvertent Return Prevention Measures....................................................................2
2.1
Bore Profile Design.........................................................................................................................2
2.2
Pre -Drill Preventive Measures......................................................................................................2
2.2.1
HDD Drilling Supervisor.................................................................................................................2
2.2.2
Dominion Environmental Inspector.................................................................................................2
2.2.3
HDD Contractor...............................................................................................................................3
2.2.3.1
Monitoring of Mud Quality.......................................................................................................... 3
2.2.3.2
Controlled Drill Head Advance................................................................................................... 3
2.2.3.3
Pump Pressure................................................................................................................................3
2.2.3.4
Proper Tool and Equipment Sizing..............................................................................................3
3.0 IR Monitoring....................................................................................................................3
3.1 Mud Pressure Monitoring.............................................................................................................4
3.2 Ground Surface Inspection...........................................................................................................4
3.3 Surface Water Inspection...............................................................................................................4
4.0 Response Measures..........................................................................................................4
4.1 Loss of Drilling Fluid Circulation................................................................................................4
4.2 Notifications and Documentation................................................................................................5
4.3 Terrestrial (Upland) Releases........................................................................................................5
4.4 Surface Water Releases..................................................................................................................6
4.5 Wetland Releases............................................................................................................................6
5.0 Restoration and Post -Construction Monitoring.........................................................7
Appendices
Appendix I — Additional Figures
Appendix II - IR Contingency Minimum Required Equipment List
October 15, 2019

HDD Inadvertent Return Contingency Plan
Dominion Energy - Johnson Pond Road
Fuquay-Varina, North Carolina
S&ME Project No. 733519075
1.0 Introduction
Dominion Energy is proposing to construct approximately 1.6 miles of new 8-inch diameter plastic natural gas
main along Johnson Pond Road in the Town of Fuquay Varina, North Carolina. The Johnson Pond Road project will
start at the northwestern corner of the intersection of Johnson Pond Road and Hilltop Needmore Road. The
pipeline will continue in a northerly direction along the western side of Johnson Pond Road to the termination
point of the project. The new pipeline will be installed via a combination of open -cut trench construction and
horizontal directional drill (HDD). Two sections of pipeline will be installed via HDD beneath two streams, a
wetland area, and an intersecting road. The use of HDD as an installation method should minimize potential for
impacts to these features, particularly environmentally sensitive areas. See Figure 1 for drawings showing the
locations of the two HDDs and surrounding areas.
The first planned HDD is approximately 1,230 feet in length and will cross beneath Middle Creek and the
associated wetland area. The HDD location is proposed within and adjacent to the NCDOT-owned right-of-way
(ROW) along the west side of Johnson Pond Road, south of the intersection with Bells Lake Road. See Figure 2 for
the proposed HDD profile of the Middle Creek crossing.
The second planned HDD is approximately 597 feet in length and will cross Bells Lake Road and an unnamed
tributary to Middle Creek that flows through a culvert. The proposed installation is within the NCDOT-owned ROW
along the west side of Johnson Pond Road. See Figure 3 for the proposed HDD profile that will cross Bells Lake
Road and the unnamed tributary.
HDD operations have the potential for Inadvertent Returns (IR) of drilling fluids, or unintended release of drilling
fluids, during the HDD installation process. IRs occur due to migration of drilling fluids through subsurface
formations or soils other than the bore annulus and can be released to the ground surface, surface waters and/or
migrate to neighboring aquifers. Drilling fluids utilized during HDD activities primarily consist of bentonite clay
and water mixtures and are often referred to as drill mud. Small amounts of chemical additives (typically less than
1%) may be mixed with the drilling fluids to improve drilling performance, or in response to a release. Though not
classified as toxic or hazardous, these drilling fluids may adversely impact aquatic and/or terrestrial ecosystems if
an IR occurs.
Dominion Energy is committed to verifying that all project construction activities will be completed in an
environmentally responsible manner. Accordingly, this Inadvertent Return Contingency Plan has been developed
and outlines procedures to:
Minimize the potential for an IR.
Detect the first indications of an IR.
Prepare the HDD contractor so their response to an IR will be organized, timely and appropriate to
minimize environmental impacts.
Verify that notifications to appropriate parties and regulatory agencies are made.
October 15, 2019 1

HDD Inadvertent Return Contingency Plan
Dominion Energy - Johnson Pond Road
Fuquay-Varina, North Carolina
S&ME Project No. 733519075
obstructions. Based on these designs, the selected HDD Contractor can effectively pre -plan the drilling work and
prepare their project -specific risk management and contingency strategies. This report can be updated once
design and geotechnical work is completed.
2.0 Inadvertent Return Prevention Measures
In order to minimize potential environmental impacts associated with IRs, HDD profile designs have been created,
and planning for specific measures to be taken before, during, and after the HDD installation process have been
completed.
2.1 Bore Profile Design
HDD profile designs have been created using surface profile information and will be augmented with geotechnical
assessment data. Survey information has been used to design the drill profile such that potential obstacles are
avoided and an acceptable depth below the stream/wetlands is achieved. The geotechnical data will be used to
determine if the geologic soils and formations that are being drilled through will allow for effective steering and
control along the bore path and are conducive to containment of the drill mud. This information, combined with
HDD designer experience, will help to minimize the risks of an IR.
2.2 Pre -Drill Preventive Measures
Before the start or continuance of both of the HDDs, the following measures shall be implemented:
2.2.1 HDD Drilling Supervisor
The HDD Contractor shall have an HDD Drilling Supervisor present at all times during HDD operations. The HDD
Drilling Supervisor is responsible for making sure the HDD is implemented in accordance with the design. The
Drilling supervisor shall also confirm that all personnel are: 1) aware of their responsibilities if an IR occurs; 2)
aware of the location and proper deployment of materials and cleanup methods, and; 3) are capable of
completing the required actions.
2.2.2 Dominion Energy Environmental Inspector
A Dominion Energy Environmental Inspector shall be on -site and shall verify that:
Construction limits are clearly marked.
Sensitive resources within, and adjacent to, the construction workspace are flagged.
All required clearances or permits related to sensitive features have been obtained.
All setbacks and offsets from sensitive resources shall be maintained.
Coordination with the USACE and NCDWR to communicate anticipated HDD schedule has occurred.
Erosion and sediment controls are appropriate for the current and expected conditions, have been
installed, and are functioning properly.
A properly -stocked spill response kit is present at the drill site.
October 15, 2019

HDD Inadvertent Return Contingency Plan
Dominion Energy - Johnson Pond Road
Fuquay-Varina, North Carolina
S&ME Project No. 733519075
Appropriate response equipment is on -site and in good working order (Minimum required equipment is
listed in Appendix II but may be modified by the Dominion Energy Environmental Inspector based on
current and expected conditions at the site at the time of installation).
A pre -construction meeting is conducted with contractor personnel to identify and locate sensitive
resources at the site and to review the Inadvertent Return Contingency Plan for the HDD.
Subsequent daily briefings with contractor personnel are conducted.
2.2.3 HDD Contractor
The HDD Contractor shall perform the HDD utilizing reasonable measures to minimize the risk of IRs while
ensuring the completion of a successful HDD. These measures include, but are not limited to, the following:
2.2.3.1 Monitoring of Mud Quality
Monitoring of drilling fluid (mud) pressures, viscosities, circulation, and returns shall be completed during all
drilling activities to verify that the mud handling equipment is operating within the expected parameters of the
anticipated soil conditions. The soil returns will be continuously monitored and adjustments made as necessary.
2.2.3.2 Controlled Drill Head Advance
The HDD Operator will advance the drill head at a pace that permits sufficient time for soil cuttings to be flushed
from the borehole by the drilling fluids. Attempting to advance the drill head too quickly can cause plugging to
occur due to build-up of cuttings in the annular space. Continuing to advance the drill head when plugging has
occurred will cause annular space pressures to increase, which could lead to an IR. If plugging occurs, the drill
head advance shall be slowed, stopped, or reversed as necessary to clear the build-up of cuttings. Swabbing the
drill hole may also be required to clear excess build-up of cuttings. Pump Pressure
Drilling mud pump pressure will be maintained at a level above the minimum pressure required to keep the
annular space clear of cuttings and promote good drilling fluid circulation. However, this pressure should not be
exceeded more than is necessary and should be maintained well below the maximum allowable annular mud
pressure. Calculations will be completed to provide the minimum and maximum mud pressures along the drill
path based off the provided geotechnical and surface survey information.
2.2.3.3 Proper Tool and EcuiPment Sizing
Appropriately sized (diameter) drill heads and reamer bits will be used to maintain proper annular space size
through the drill, especially in the curves of the drill path. This will allow sufficient annular space for the circulation
of drilling fluids. An appropriately sized drill rig shall also be selected so that the HDD can be completed
successfully.
3.0 IR Monitoring
The HDD Contractor will verify that operations are monitored for the occurrence of IRs using each of the following
methods, as appropriate:
October 15, 2019

HDD Inadvertent Return Contingency Plan
Dominion Energy - Johnson Pond Road
Fuquay-Varina, North Carolina
S&ME Project No. 733519075 11 E
3.1 Mud Pressure Monitoring
The HDD Contractor is responsible for continually monitoring mud pressures during all HDD activities. Sudden
loss of mud pressure could indicate an IR to the surface, loss of fluid into a pre-existing void or fractured rock,
blockage of the return path, or borehole collapse. Upon loss of mud pressure, investigation of the cause of mud
pressure loss should commence. Drilling activities should be slowed or cease, and mud flow from the pump
should be slowed until the cause is determined.
3.2 Ground Surface Inspection
Visual inspection of the ground surface for indications of escaping drilling fluids shall be completed along the
path of the HDD, with priority given to environmentally -sensitive areas. To the extent practicable, and without
trespassing outside the approved workspace, the inspection should cover a corridor that is at least 300 feet wide,
centered on the drill. Inspections shall be made relative to the rate of advance of the drill head; however, a full-
length inspection pass shall be made at least once every hour while pumping drilling fluids. Indications of a
release shall be reported immediately to the HDD Drilling Supervisor and Dominion Energy Pipeline Inspector.
3.3 Surface Water Inspection
Inspection passes shall be made at least once every hour while pumping. Indications of an IR shall be reported
immediately to the HDD Drilling Supervisor and Dominion Energy Pipeline Inspector. If operating parameters
indicate the possibility of an IR under water, the water inspection will become continuous (during daylight only)
until the location of the suspected inadvertent release is found, the drill is completed, or measures to remedy the
inadvertent release using approved additives or other operations adjustments have been successful. Inspections
will be made from an elevated position on land with an unobstructed view of the water body. If required,
completion of turbidity sampling that might indicate an IR is occurring will be taken at sites upstream and
downstream of the HDD crossing.
4.0 Response Measures
Contractor personnel are responsible to report indications of an IR or an observed IR to the on -site Dominion
Energy Pipeline Inspector. If either of these conditions are reported and confirmed, HDD operations are to
immediately cease. HDD activities shall not resume until cleanup procedures are complete and appropriate
agencies have authorized resumption of work.
Containment and removal of drilling fluid releases to the surface will be performed where practical and where
there will be a net benefit in the reduction of overall environmental impacts. Response actions will be coordinated
through the on -site Dominion Energy Environmental Inspector, Dominion Energy Pipeline Inspector, Dominion
Energy Gas Transmission Construction Manager and Dominion Energy Environmental Lead.
4.1 Loss of Drilling Fluid Circulation
As stated in section 3.1, mud pressure loss and fluid circulation loss can indicate an IR at the surface. In the event
of loss, or reduction, of drilling fluid circulation the following measures should be taken:
October 15, 2019 4

HDD Inadvertent Return Contingency Plan
Dominion Energy - Johnson Pond Road
Fuquay-Varina, North Carolina ... s
S&ME Project No. 733519075 "'� ■ ■ ��
Notify the Dominion Energy Pipeline Inspector and Dominion Energy Environmental Inspector of the loss
of fluid circulation.
Retract the drill head a short distance, if deemed appropriate.
Discontinue drilling operations to investigate the loss of fluid circulation.
Pump drilling fluid into the borehole for approximately 15 minutes without advancement of the bore
head.
If fluid circulation is regained, resume drilling operations. The HDD Drilling Supervisor will notify the
Dominion Energy Pipeline Inspector, Dominion Energy Environmental Inspector, and Dominion Energy
Environmental Lead and continue visual monitoring of the project area for signs of drilling fluid release.
If a drilling fluid release is detected, discontinue drilling and implement mitigation measures as detailed in
this contingency plan.
HDD Contractor shall monitor and adjust fluid properties, fluid volumes, and rate of penetration to match
ground conditions and maintain circulation and borehole stability once drilling operations resume.
4.2 Notifications and Documentation
If there is an IR or other environmental or safety incident, the HDD Contractor shall report the incident to the on -
site Dominion Energy Environmental Inspector or Dominion Energy Pipeline Inspector immediately and directly.
The Dominion Energy Environmental Lead will be responsible for making the appropriate regulatory agency
notifications.
Documentation of the IR shall include:
Initial indication/observation of the IR and time observed.
Location of the IR.
Resources impacted by the IR.
Location of the drill head/reamer.
Stage of the HDD.
Times of notification and who was notified.
Actions taken in response to the IR and times those actions were taken.
Amount of drilling fluid loss.
Containment methods employed.
Effectiveness of containment methods.
Photos (before, during and after cleanup).
4.3 Terrestrial (Upland) Releases
The HDD Drilling Supervisor will utilize the appropriate combination of hay bales, silt fence, compost filter sock,
wattles, pumps, hoses, and other measures that will most effectively contain and remove drilling fluids from
upland areas. The HDD Drilling Supervisor shall make the determination of the appropriate equipment and
materials to be used, with approval of the Dominion Energy Pipeline Inspector and Dominion Energy
Environmental Inspector. The actions may include:
Constructing a small pit or sandbag coffer around the IR location(s), installing a section of silt fence,
compost filter sock, and/or hay bales to trap as much drilling fluids as possible, and placing a pump hose
October 15, 2019

HDD Inadvertent Return Contingency Plan
Dominion Energy - Johnson Pond Road
Fuquay-Varina, North Carolina
S&ME Project No. 733519075 11 E
in the pit to pump the drilling fluid back to the bore site or temporary holding area or vessels (i.e. vac
truck).
Reducing drilling fluid pressures.
Thickening drilling fluid mixture; and/or
Adding pre -approved loss circulation materials to the fluid mixture, such as wood fibers or shredded
paper.
If the HDD Contractor determines the fluids are reusable, the HDD Contractor shall instruct the recovery crew to
pump the contained and recovered fluids to on -site tanks for reuse. Otherwise, the fluids will be transported off -
site for disposal at an approved facility. Dominion Energy will obtain landowner permission prior to accessing
upland sites for fluids containment and removal operations, except in emergency cases where inaction would pose
an imminent threat to human health, environmentally sensitive areas, or public/private property.
4.4 Surface Water Releases
If an IR occurs within streams and/or wetlands, drilling operations will cease until the HDD Drilling Supervisor,
Dominion Energy Pipeline Inspector and Dominion Energy Environmental Lead have had an opportunity to
examine the site and evaluate the threat to the waterbody. A turbidity curtain (Type 3 DOT or approved
equivalent) will be installed per manufacturer instructions within the waterbody at the site of the inadvertent
return location to confine suspended solids from the IR until an observable degree of settlement occurs. If
necessary, the containment shall remain in place throughout HDD installation and until settlement renders
turbidity inside the containment similar to the adjacent waters based on visual inspection, the threat to sensitive
resources has passed, or the Dominion Energy Environmental Lead authorizes removal of the turbidity curtain.
Removal of the diluted drilling fluids is not anticipated, unless dictated by unusual circumstances or directed by
environmental agencies, and subject to Dominion Energy approval.
Drilling operations shall not cease during the pipe pullback process in the event of an inadvertent release due to
significant risk of causing the pull to be stuck and unable to resume. In this case the turbidity curtain would be
installed to confine suspended solids.
4.5 Wetland Releases
Upon confirmation of an IR in wetlands, HDD operations will cease. Containment and removal of drilling fluids
released to wetlands shall be performed after consultation with the appropriate regulatory agencies. The HDD
Contractor shall assist the on -site Dominion Energy Environmental Inspector with the following steps:
Measure the area directly affected by the released drilling fluids. The area affected may be estimated from
a distance, if access to the affected area for measurement would result in additional unacceptable
negative impacts or is not otherwise feasible.
The Dominion Energy Environmental Inspector or a qualified wetland biologist will characterize the type
of impact caused by the released drilling fluids (e.g., temporary, vegetation only, permanent, change in
surface hydrology). The Dominion Energy Environmental Inspector or Dominion Energy Environmental
Lead will seek regulatory agency concurrence, if required.
October 15, 2019

HDD Inadvertent Return Contingency Plan
Dominion Energy - Johnson Pond Road
Fuquay-Varina, North Carolina
S&ME Project No. 733519075
The HDD Contractor, Dominion Energy Pipeline Inspector, and the on -site Dominion Energy
Environmental Inspector shall jointly estimate the additional area, if any, likely to be affected if the drilling
were to proceed and the drilling fluids were not contained and removed.
In consultation with the HDD Contractor, the on -site Dominion Energy Environmental Inspector will
estimate and characterize the additional impacts to wetlands likely to occur as a result of accessing the
affected area for containment and removal of the drilling fluids.
The on -site Dominion Energy Environmental Inspector will estimate any reduction in impacts that might
be achieved if the released fluids were removed.
If it is determined that the released drilling fluid is to be contained and recovered, the HDD Drilling
Supervisor, in consultation with the Dominion Energy Pipeline Inspector and Dominion Energy
Environmental Inspector, shall direct the personnel or placement of equipment at the applicable points of
fluids release and transfer the contained fluids to a hopper barge or tank for subsequent reuse or
disposal.
If the decision is made to forgo containment and proceed with the drill, the on -site Dominion Energy
Environmental Inspector will continue to observe the location of the release. If impacts continue, the
Dominion Energy Pipeline Inspector will periodically reevaluate the decision to continue until containment
and removal arejustified or the HDD is complete.
Access to wetlands will be done in such a manner as to cause the least impacts to vegetation and surface
hydrology, and only with prior agency approval. Because of site -specific variables such as distance from
open water, surface hydrologic conditions, and vegetation cover, selection of the most appropriate access
method will be made on a case -by -case basis, subject to approval by the Dominion Energy Pipeline
Inspector and Dominion Energy Environmental Inspector. The least number of personnel and equipment
necessary to accomplish the task safely in a timely manner shall be deployed.
Following containment and removal, the HDD Contractor will continue to monitor the crossing location
for additional releases as the drilling work progresses.
Impacts to wetlands from inadvertent releases will be measured, assessed, and recorded by the Dominion
Energy Environmental Inspector with assistance from the HDD Contractor, to support mitigation or
restoration measures that may be necessary.
Upon completion of the boring, the HDD Contractor will remove containment and recovery equipment,
tools, supplies, materials, wastes, and debris from the wetlands.
5.0 Restoration and Post -Construction Monitoring
Impacted areas will be restored to pre-existing contours. Upland areas shall be restored through typical right-of-
way practices of seeding and mulching as described in the reclamation plan for the project.
Restoration of wetlands may vary depending on the extent of disturbance to the upper soil layer and vegetation
during the initial IR response.
In the event of a drilling fluid release in streams and/or wetlands, a site -specific, post- remediation protocol shall
be prepared and submitted to the USACE and NCDWR. Once approved, the plan implemented under the
direction of Dominion Energy. This protocol will be based on the specific parameters of the release, including
volume, location and extent. The goal of the plan will be to determine what adverse effects may have occurred in
October 15, 2019

HDD Inadvertent Return Contingency Plan
Dominion Energy - Johnson Pond Road
Fuquay-Varina, North Carolina
S&ME Project No. 733519075
the impacted area of release. Efforts may include random sampling of each habitat and comparison of impacted
habitats to non -impacted habitats. Pre -drilling data for this project will be used for comparative purposes.
At a minimum, an inspection of the entire drill path will occur within 48 hours of completion of drilling activities. A
letter report will be prepared to summarize fluid deposits that are identified. If there is no drilling fluid release,
post drilling monitoring will consist of an underwater investigation to be performed within 30 days after
completion of drilling activities. Drilling fluid releases that persist beyond completion of drilling activities shall be
removed within 30 days of completion of drilling, if requested by the Federal or State regulatory agencies having
jurisdiction.
October 15, 2019

Appendices

Appendix I - Figures

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o NORTH CAROUNA WAS CONVERTED INTO 1-FOOT CONTOURS USING ARCGIS SPATIAL ANALYST. NATURAL RESOURCES 1
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PROJECT NUMBER:
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PROPOSED 1,230' - 8" PLASTIC GAS MAIN
PROFILE LOOKING WEST
Dominion
Energy,
o
o -
PROPOSED DIRECTIONAL BORE
a JOHNSON
POND RD
> FUQUAY VARINA,
NORTH CAROLINA
w w
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DRAWN BY- JOSUE ALCARAZ DRAWING NO.
CHECKED BY-
0067344
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APPROVED BY JOSUE ALCARAZ
z
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Figure 3 — Bells Lake Road HDD Profile
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O r N M't 0 CO h w M CD N M L7 (D h O M O N M I lti (D h M M 0 N M If) O h M M 0 r- N M't If) (fl I-O M 0 N M't 0 (D h co M O N co I Ln Co I- co O � N M� Lo Co h 00 O CD
t t t t t t t t t t t t t t t t t t t t t t t t t t t t t t t t t t t t t t t t t t t t t t t + t + t t t t t + t t + t t t t t t t t + t t t t t t t t t + t t t
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PROPOSED 597' - 8" PLASTIC GAS MAIN
PROFILE LOOKING NORTHWEST
Dominion
Energy,
g ° PROPOSED DIRECTIONAL BORE
JOHNSON POND RD
_
FUQUAY VARINA, NORTH CAROLINA
o �
DRAWN BY-JAC03 SMITE DRAWINONO.
CHECKED BY, 0167344
APPROVED BY-JOSUE ALCARAZ
1010912019 SCALE-NTS SHCCTI of 1

Appendix II
IR Contingency Minimum Required Equipment List
4" — 6" Trash Pumps
40' Suction Hose
1500' Lay Flat Hose
Straw Bales — Entry and exit side
Silt Fence
Sand Bags
Plastic Sheeting
Shovels, brooms, and appropriate hand tools
Generator and Flood Lights for night work
Frack Tanks (2) or mud pit large enough for excess mud
Super Sacks (3) if needed to contain mud
MSDS for the drilling mud and additives
Long Reach Excavator for containment and cleanup of drilling mud