20140957 Ver 2_No to the ACP in NC_20170814

Strickland, Bev
From:MARTHA W GIROLAMI <[e-mail]>
Sent:Monday, August 14, 2017 7:33 PM
To:SVC_DENR.publiccomments
Subject:No to the ACP in NC
This is my second comment on the ACP.

Atlantic Coast Pipeline (ACP) Comments on 401 Certification in North Carolina (NC)

2. The ACP construction will damage irreversibly our streams, wetlands, wetland forests, ground water, wells, rivers and ecosystems. The
risk of irreversible damage to our sensitive water quality is irrefutable. The unjustified and un-needed ACP is not worth ANY risk and the risk of
building this pipeline is incalculable and cumulative.

Below are three stories about pipeline construction, water damage and ethics.

The Mariner 2 pipeline in Pennsylvania (Sunoco LLC—now merged with Energy Transfer Partners): “as of 7/31/17, 202,000 gallons of drilling
fluids have been accidentally released in 90 different spill events…last week, a judge with the PA Environmental Hearing Board granted a two week halt to
horizontal direction drilling operations”
https://www.fractracker.org/2017/07/me2-drilling-fluid-spills/

This number and volume of “accidental” (incompetent) spills is unacceptable and the duty of DEQ is to deny the 401 Permit Certification to protect our
waters and their uses. This is a disaster happening cumulatively in 90 locations in PA . The Mariner 2 is only one pipeline of many, spilling and releasing
drilling fluids over and over in other states. These “inadvertent returns” must not be allowed. This kind of incompetence or pathetic drilling “technology” is
reason enough for DEQ to deny the 401 Certification Permit for the ACP. There is nothing to stop uncountable releases from happening in the ACP permit
application.

Also the Pipeline company uses drilling fluids consisting of water, bentonite clay and
“some chemical mixtures used to lubricate the drill bit”. What are these chemical mixtures?
All chemicals must be approved by DEQ and non-disclosure of proprietary additives must not be
allowed. These drilling fluids are foreign, non natural materials injected into soil and water and
wetlands. Calling a drilling fluid “non-toxic” is a meaningless term—where is the proof? What is
non-toxic when it enters the food chain, coats the plants and soil, enters the groundwater
and drinking water wells, and contaminates the water macro invertebrates and fish live in?

Rover Pipeline in Ohio (Energy Transfer Partners):
“The state EPA has proposed nearly $1 million in fines over violations that include allowing drilling mud (2 million gallons) to spill into wetlands, ponds and
streams along with pumping storm water into streams and fields. Most of the violations were in March and April (2017)
but some problems continue.”
“Just last week FERC ordered ETP to clean up and restore 6 acres of wetlands coated with more than a foot of drilling mud, remove mud contaminated with
diesel fuel from two quarries and monitor water near those sites.”

This level of contamination along the Rover pipeline route is unbelievable. How could this
be allowed? Illegal spillage of 2 million gallons of drilling muds! Illegal diesel fuel found in the drilling muds! Illegal disposal of drilling muds in
quarries! Illegal pumping rainwater from pipeline trenches into fields and streams outside the easement! This construction project is breaking one regulation
after another and is illegal by any measure.
No amount of fines or penalties will restore these waters of the state, lands or property.
So what was Rover pipeline to do when heavy rains fell? There is very little anyone could
do except watch the flood and pump water off your easement into fields and wetlands
and streams. But this is not legal and is very damaging! Similarly, North Carolina has enormous rainfalls and hurricanes. There is no way that the millions
of gallons of rain falling along the pipeline route will not spread sediment and drilling mud across the landscape.
https://www.usnews.com/news/best-states/ohio/articles/2017-07-20/dakota-access-developers-new-pipeline-rankling-regulators

The NC DEQ will not be able to police this level of assault on our water environment by the construction of the ACP. Nor would it make much
difference. Cumulative spills, sediment release, eroded stream banks, rain flushing out the trenches, illegal dumps of of rainwater,
drilling fluids, machinery oil and diesel leaks and spills, etc. would render any efforts by DEQ
meaningless. Additionally the drilling construction companies and DE/Dominion will be recalcitrant and refuse Stop Work orders and many spills will remain
unreported etc.
DEQ will not be able to react to spills and illegal dumping in a timely fashion. DEQ will be helpless to assist landowners when their streams, wells and
wetlands are ruined. Spill “clean ups” are in name only. Clean up is a fantasy. Spill damage is quick and irreversible. No one will be monitoring the
“return” to before the pipeline. And monitoring does not repair the harm.
DEQ does not have the staff and resources and magic to “fix” the polluted lands and waters of eastern NC during and after the ACP is built. These damages
are not trivial; they are major and permanent.
1

My friend Jane’s story:
Transco came onto her property in New Jersey to replace a 36 inch pipeline with a 30 foot easement. Their small horse farm was disabled and nearly ruined
by impacts from this sloppy, dangerous project. Heavy machinery was parked all over her farm fields compacting the soil; there were diesel spills from
machinery; no fencing was provided for her horse field that was cut in half with the pipeline trench 12 feet deep; Transco sold the topsoil from the excavation
site and the trench was packed with clay; there was no protection for children in the neighborhood around the trench or machinery.
Workers were contract, non English speaking, unsupervised and untrained. These workers started to cut the old pipeline with torches before the gas was
evacuated and no one knew where the turn off-valve was located (1 hour away) —fortunately my friend intervened.
Finally the homeowner incurred significant cost for a right of way attorney and later for an attorney to fight against Transco to stop a second parallel pipeline
(this was successful).

Above, I have reported three true pipeline stories out of many that happen over and over again to show DEQ how much damage will occur from the ACP
pipeline construction and thereafter.
If DEQ approves the 401 Certification Permit, then your department is unleashing these types of
damage to the environment and private property. Nothing will go as planned on paper by the
pipeline company or Dominion or DE. Mistakes and violations and gross pollution will be the norm and chaos will reign.
DEQ must think of the accumulative impacts of the following—
—soil compaction from machinery on fields and wetlands
—countless drilling mud spills
—undisclosed drilling mud constituents protected by proprietary claims
—toxic blasting compounds released to the land and water
—infiltration of drilling muds into shallow aquifers and drinking water wells
—stormwater overfilling trenches and pumped or spilled into wetlands and fields
—huge rainfalls further damaging stream banks, wetlands and causing enormous
soil erosion and sedimentation
—failure of directional drilling by untrained workers
—diesel fuel spillage or release into the work area and adjacent wetlands during rainfall
—cutting and breaking apart stream and river banks once held together with roots
—forest fragmentation
—retarded forest regrowth from drought and competition from vines and invasive plants
—introduction of invasive species into the wetlands, fields and forests
—disfunction of wetland from trenching and changes in drainage
—toxicity of herbicides used to retard forest growth tin the right of way.

2