20140957 Ver 2_Attachment 14_Dodds Report_20170818

Attachment 14

ASSESSMENT OF THE ADVERSE HYDROGEOLOGICAL IMPACTS
RESULTING FROM CONSTRUCTION OF THE PROPOSED ATLANTIC
COAST PIPELINE IN WEST VIRGINIA, VIRGINIA, AND NORTH CAROLINA
Prepared for the Dominion Pipeline Monitoring Coalition
By Pamela C. Dodds, Ph.D., Licensed Professional Geologist
March 2017
EXECUTIVE SUMMARY
Since January, 2015, Atlantic Coast Pipeline, LLC (ACP) and Dominion Transmission,
Inc. (DTI) have submitted documents to the Federal Energy Regulatory Commission
(FERC) pertaining to the project description, location, and impacts for construction of a
gas pipeline extending 603.8 miles through West Virginia, Virginia, and North Carolina.
References to these previously submitted documents are included in the Draft
Environmental Impact Statement (DEIS), Docket Numbers CP15-554-000, CP15-554-
001, CP 15-555-000, and CP15-556-000), incorporated and submitted by the FERC
staff and made available to the public on December 31, 2016.
In the "Notice of Availability of the Draft Environmental Impact Statement for the
Proposed Atlantic Coast Pipeline, Supply Header Project, and Capacity Lease
Proposal", dated December 30, 2016, the FERC staff stated the following: "The FERC
staff concludes that approval of the projects would have some adverse and significant
environmental impacts; however, the majority of impacts would be reduced to less -than -
significant levels with the implementation of the Atlantic's and DTI's proposed mitigation
and the additional measures recommended in the draft EIS." This statement does not
recognize consideration of cumulative impacts, as required of all federal agencies by
the National Environmental Protection Act (NEPA).
The FERC staff opinion does not define the use of the word "significant" as meaning
statistically significant or significant with respect to any particular parameter. Nor does
the DEIS provide clarification of this terminology. There is ample opportunity to provide
metrics in an opinion concerning impacts:
1) Calculations of discharge within first and second order stream watersheds, using the
Rational Method or the TR -55 (developed by the Soil Conservation Service/Natural
Resources Conservation Service) provide the amounts of increased stormwater
discharge to streams resulting from deforestation and soil compaction in the pipeline
construction areas;
2) Calculations of downstream stream bank erosion and stream bed scour provide
quantities of sediment introduced to the streams as a result of increased stormwater
discharge from the pipeline construction areas;

3) Review of the Total Maximum Daily Loads (TMDLs) for the impacted streams
provides a maximum measure of Total Suspended Solids (TSS) and turbidity in streams
resulting from increased sedimentation;
4) Calculations of the Revised Universal Soil Loss Equation (RUSLE) provide a
measure of expected increases in sedimentation in streams resulting from pipeline
construction activities;
5) Measurements of embeddedness in the stream beds provide statistical evaluation of
the aquatic environments, including high quality aquatic environments that would be
adversely impacted by sediment from pipeline construction activities;
6) Bioassays of streams would provide statistical evaluation of stream quality; and
7) Percent effectiveness of the suggested best management practices used at the
pipeline construction areas would provide an evaluation of the expected increased
stormwater discharge and sedimentation.
Qualitative opinions are appropriate with respect to scientific research and
recommendations provided by government agencies. For example:
1) The West Virginia Geological and Economic Survey (WVGES) has determined
that landslide -prone areas occur mostly on slopes of 15% to 45% on red shale
bedrock.
2) The U.S. Geological Survey (USGS) emphasizes that "Groundwater is not a
renewable resource" and that groundwater and surface water are connected as
one integral system.
3) The Environmental Protection Agency (EPA) and the U.S. Department of
Agriculture (USDA) have embraced the River Continuum Concept as illustrating
the strong connection between headwater areas on mountain ridges and various
downstream areas. Larval insects, predominant in the forested headwaters,
break down organic matter used downstream by aquatic species higher on the
food chain.
4) The EPA has established TMDLs for sediment loads in streams.
5) The EPA has developed the Save Our Streams program to provide statistical
analysis and evaluation of stream quality.
The DEIS does not include a comprehensive list of specific soils series crossed by the
proposed ACP route. This information is necessary for RUSLE calculations.

The RUSLE calculations provided in the DEIS are inadequate and deficient because the
discharge area is not delineated and the soils are grouped as a complex.
The DEIS is deficient because Tier 1, Tier 2, and Tier 3 streams are not identified, even
though this information is available on the West Virginia, Virginia, and North Carolina
state environmental websites.
The DEIS is deficient because there is no consideration of impacts to groundwater due
to reduced recharge from increased stormwater runoff from the ACP construction areas.
The DEIS is deficient because the selected Best Management Practices will not prevent
sediment from accumulating in streams.
The DEIS is deficient because there are no calculations provided to estimate increased
stormwater discharge in watersheds of first order streams, second order streams,
and/or third order streams, which are the most critical streams in the river continuum.
The DEIS is deficient because there is no consideration of groundwater depletion with
respect to seeps and springs in headwater areas, stream baseflow, or residential wells.
The DEIS is deficient because there is no consideration of decreased groundwater
hydraulic head, due to dewatering and reduced groundwater recharge along the ACP
construction route, causing decreased baseflow to streams. The hydraulic head must
also be maintained and to prevent saltwater intrusion in aquifers of the Coastal Plain
Physiographic Province.
The DEIS is deficient because the sediment from the construction site, along with
sediment from downstream stream bank erosion and increased vertical scour, will
increase stream bed embeddedness, causing degradation of aquatic habitats.
The DEIS is deficient because the sediment introduced to the receiving streams due to
the proposed ACP construction activities will cause elevated concentrations of water
quality parameters, exceeding the Total Daily Maximum Levels established for these
parameters.
The DEIS is deficient because there is no consideration of the increased stream bed
embeddedness downstream of proposed ACP stream and river crossings and there
have been no bioassays conducted at these locations to establish the existing
conditions.
It can only be concluded that there will be significant, permanent damage to streams
receiving stormwater discharge from the proposed ACP construction areas and to
streams crossed by the proposed ACP route.

1.0 MEASUREABLY SIGNIFICANT CONSTRUCTION IMPACTS TO
WATERSHEDS
"Watershed" refers to all of the land that drains to a certain point on a river (Figure 1.0-
1). A watershed can refer to the overall system of streams that drain into a river, or can
pertain to a smaller tributary. Stream order is a measure of the relative size of streams.
The smallest tributary is a first order stream, which originates in the highest elevations.
Figure 1.0-1 — Headwaters of first order
high gradient streams are located at the
highest elevations on the watershed divides.
WATERSHED
Headwa
Watershed o-ibua�nes
t1-dplaiv \ maucsreun
Strahler (1952) defined a hierarchy of stream tributaries to depict the relationships of
stream order. Where two first order streams connect, a second order stream is
designated. Where two second order streams connect, a third order stream is
designated (Figure 1.0-2).
Figure 1.0-2 — Schematic diagram of the relationship of first order streams (designated
1", shown in blue), second order streams (designated "2", shown in green), and third
order streams (designated "3", shown in orange). First order streams form in headwater
areas at the highest elevations in watersheds. (Diagram based on Strahler, 1952).
1
1
2
1
2
1
Figure 1.0-2 — Schematic diagram of the relationship of first order streams (designated
1", shown in blue), second order streams (designated "2", shown in green), and third
order streams (designated "3", shown in orange). First order streams form in headwater
areas at the highest elevations in watersheds. (Diagram based on Strahler, 1952).

1.1 Watershed Sizes
The Federal Government Agencies have established a hierarchical ordering of
Hydrological Unit Codes (HUC), described as areas of land upstream from a specific
point on the stream (generally the mouth or outlet) that contributes surface water runoff
directly to this outlet point (Table 1.1-1).
Table 1.1-1 — Descriptions of Hydrological Unit Codes (HUC).
Code
Official Name
General Description
HUC-2
REGION
Major land areas. The lower 48 states have 18 total,
1 additional each for Alaska, Hawaii, and the
Caribbean. (21 total in US), called 1 ItLevel — or
Watershed 1St Level.
HUC-4
SUBREGION
Each Region has from 3 to 30 Subregions. The
Missouri River Region has 30 Subregions. The lower
48 states have 204 (222 total in US), called 211 Level.
HUC-6
BASIN
Accounting Unit 352 total in US), called 3rd Level.
HUC-8
SUBBASIN
Cataloging Unit. The smallest is 448,000 acres (700
square miles). Most are much larger. National HQ
compilations have this as the smallest size unit (2,149
total in US), called 4th Level.
HUC-10
WATERSHED
Typically from 40,000 to 25,000 acres (62 to 390
square miles). Work continues per new Interagency
guidelines presented to Federal Geographic Data
Committee on December 2000 (was formerly called
HUC-11), called 5th Level or Watershed 5th Level.
HUC-12
SUBWATERSHED
Typically from 10,000 to 40,000 acres (15 to 62
square miles). Work continues per new Interagency
guidelines presented to Federal Geographic Data
Committee on December 2000 (was formerly called
HUC-14), called 6th Level or Watershed 6th Level.
HUC designations were developed by Seaber, Paul R., F. Paul Kapinos, and George L.
Knapp ("Hydrologic Unit Maps", U.S. Geological Survey Water -Supply Paper 2294;
1987) as a "standardized base for use by water -resources organizations in locating,
storing, retrieving, and exchanging hydrologic data, in indexing and inventorying
hydrologic data and information, in cataloging water -data acquisition activities..." HUC-
8 Subbasin designations were based on a drainage area of greater than 700 square
miles (448,000 acres). The smallest HUC is the HUC-12 Subwatershed, which typically
encompasses an area from 10,000 acres to 40,000 acres. The HUC designations were
not intended to determine specific details for smaller watersheds of tributaries which
provide water quality and biotic functions of aquatic organisms for the overall watershed
evaluations.

1.2 Watershed Delineation Sizes Providing Significantly Meaningful Metrics
In 2007, the U.S. Fish and Wildlife Service (USFWS) prepared a document, "Functional
Assessment Approach for High Gradient Streams", for the U.S. Army Corps of
Engineers to use in assessing impacts and mitigation with respect to processing Clean
Water Act 404 permit applications. High gradient headwater streams are characterized
as first and second order ephemeral and intermittent streams with channel slopes
ranging from 4% to greater than 10%, within watersheds of approximately 200 acres.
The significance of this report relates to the proposed MVP gas pipeline construction
with regard to how watersheds are evaluated. Because of the impacts of construction
on the functions of headwater areas in the watersheds of first order high gradient
streams, it is critical to evaluate these areas not simply as a small acreage within the
area encompassing the construction project, but rather as functionally contributing
areas which are the basis of water quality and aquatic habitat quality within the overall
watershed.
In order to evaluate the interactions of precipitation, stormwater discharge, groundwater
recharge and retention, and stream baseflow, calculations must be performed at the
headwater tributary level. Because first order high gradient streams are well defined
(Rosgen, 1994) and are considered to provide the basis for watershed evaluation
(USFWS, 2007), it is essential to select these smaller watersheds, typically 200 acres in
size, to evaluate the impact of construction projects.
It is critical to delineate the areas of different ground covers within a watershed in order
to accurately calculate stormwater discharge. In the Watershed Protection Research
Monograph No. 1, prepared by the Center for Watershed Protection (2003), it is
emphasized that the relationship between impervious cover and stream quality applies
to watersheds of first order streams, second order streams, and third order streams. It
is therefore extremely important to evaluate watersheds of the first order streams,
second order streams, and third order streams impacted by proposed ACP construction
in order to adequately determine the impacts of increased stormwater discharge due to
an increase in impervious surfaces.
In the "Rapid Watershed Planning Handbook", prepared by the Center for Watershed
Protection in 1998, it is emphasized that streams are impaired when impervious
surfaces are just 10 percent of a watershed and that streams cannot support aquatic life
when impervious surfaces cover 25 percent of the watershed area. At 12 percent
imperviousness, trout and other sensitive species cannot survive. At 8 percent to 10
percent impervious cover, the streams double in the size of the bed due to increased
volume, leading to increased stream bank erosion and loss of riparian buffers. The
impervious surface amounts increase the stormwater discharge, which is responsible
for the consequent erosion. It follows that where stormwater discharge is increased,
due to an increase in less permeable surfaces, even without strictly impermeable
surfaces, it is the increase of stormwater discharge to specific quantities that causes the
damage to streams. Watersheds must be evaluated for stormwater discharge from all

the ground covers within the watershed in order to determine if the stormwater
discharge is equal to or greater than the stormwater discharge that would result from a
10 percent impervious area within the watershed.
1.3 Construction Impacts to Watershed Functions
Forested ridges intercept rainfall so that it gently penetrates the ground as groundwater
rather than flowing overland as runoff. This means that 1) the rain will gently fall to the
ground and recharge groundwater and 2) the surface flow of rainwater on the ground
will be slower than in cleared areas, thereby reducing the velocity and quantity of
stormwater drainage. Conversely, deforestation removes the protective tree canopy,
causing increased stormwater discharge and decreased groundwater recharge. It is
stated in the DEIS that "Clearing and grading would remove trees, shrubs, brush, roots,
and large rocks from the construction work area and would level the right-of-way
surface to allow operation of construction equipment." The proposed ACP construction
would thus result in deforestation and soil compaction, causing increased stormwater
discharge and decreased groundwater recharge. Figure 1.3-1 provides an illustration
of a typical pipeline installation work corridor. Leveling of the work corridor and access
roads, along with trenching for pipe installation and for installation of cathodic protection
systems (within a deforested 25 -foot wide corridor), will intercept groundwater, thereby
reducing or eliminating the flow of water to rock fractures which serve as a conduit to
provide water to seeps, springs, and wetlands, as well as to streams during times of
drought. It is further stated that additional acreage is required for proposed additional
temporary workspaces, pipe yards, staging areas, access roads, and construction
associated with aboveground facilities. "The Virginia Department of Environmental
Quality's Ground Water Characterization Program recognizes that springs are one of
the most basic, important, and often times forgotten components of any hydrologic
study"
(http://www.deg.virginia.gov/Programs/Water/WaterSupplVWaterQuantitV/Groundwater
Characterization/Spring Database.aspx.)
Figure 1.3-1 — Leveled work
corridor for pipeline installation,
showing cut hillsides and
dewatering. Heavy equipment
and truck traffic, along with soil
stockpiles, will compact soils.

The WVDEP Erosion and Sediment Control Best Management Practices Manual
(WVDEP, 2006, revised August 29, 2016) states that for access roads and work areas:
"A 6 -inch course of crushed aggregate shall be applied immediately after grading.
Geotextile fabric should be applied to the roadbed for additional stability. In heavy duty
traffic situations, stone should be placed at an 8 to10 inch depth to avoid excessive
maintenance." Compacted access roads and work areas with gravel surfaces are
essentially impermeable.
1.4 Construction Impacts to Water Sources in Headwater Areas of Watersheds
As depicted in Figure 1.4-1, when rainwater is intercepted by trees on forested ridges,
the rainfall gently penetrates the ground surface and migrates downward through the
soil to bedrock. The water then flows through bedrock fractures and along bedding
planes to continue migrating downward or to form seeps and springs where the
fractures or bedding planes intercept the ground surface. Seeps and springs can occur
at various elevations on mountain slopes, depending on where the bedrock fractures or
bedding planes intercept the ground surface, providing water to headwater areas and
wetlands in headwater areas of first order high gradient streams. Seeps and springs
can also occur along streams and rivers. As the quantity of groundwater accumulates
beneath the ground surface, a hydraulic gradient forms, causing the groundwater to
move downgradient to nearby streams and rivers or to lower areas where the water may
reach streams and rivers that are farther away. The seeps and springs provide
groundwater to the streams during times of dry weather or drought.
Figure 1.4-1 — Forests on
ridges facilitate groundwater
recharge and reduced
stormwater runoff.
precipitation Mountain FORESTS
Cdf r
interception INTERCEPT RAINFALL
antl evaporation
Allowing Rainfall to
GENTLY REACH THE GROUND
•""�"••"•• lifter
anf[OW interception
and
evaporation
Thus Allowing
#o fn
LESS SURFACE RUNOFF
and
GREATER GROUNDWATER
nel. rainfall entering RECHARGE
mineral soil the foil
1.5 Construction Impacts to Soils and to the River Continuum
Headwater areas of first order streams provide the essential aquatic habitats for aquatic
species and associated terrestrial fauna and fowl within the entire length of the river
continuum in the overall watershed. The soils which have formed in the headwater

areas regulate the transport of surface water and also carbon, nitrogen, and oxygen.
The shade of the forest canopy provides the filtered light and lower temperatures critical
to maintaining the headwater aquatic habitats.
Specific soils series develop based on the following factors: parent material,
topography, climate, living organisms, and time. Soils scientists estimate that a time
period greater than 100 years is required for one inch of soil to form
(http://www.nres.usda.gov/wps/portal/nres/detail/wa/soils/?cid=nresl44p2 036333).
Soil is therefore considered to be a non-renewable resource.
The River Continuum Concept was developed by Vannote, R.L., G. W. Minshall, K.W.
Cummins, J.R. Sedell, and C.E. Cushing in 1980 and presented in the Canadian
Journal of Fisheries and Aquatic Sciences 37: 130-137. The U.S. Environmental
Protection Agency and the U.S. Department of Agriculture have embraced the River
Continuum Concept as illustrating the strong connection between headwater areas on
mountain ridges and various downstream areas. The River Continuum Concept
diagram (Figure 1.5-1) provides pie diagrams of predominant benthic aquatic
organisms associated with various locations, starting at the headwaters, along the river
continuum. Shredders, predominant in the forested headwaters, break down organic
matter used downstream by collectors, predators, and filter -feeders. The filter -feeders
are subsequently consumed by larger benthos and fish.
hreddars �,,
S f7l"'.�I dZ9r5
o�-�xx� predators
trout collectors
periphyton'coarse collectors
inaul
rticate
bs tier
ill—uth
srn
bass Y tis sl I lars
3Qir ate
rtt9l�e
hydsophytes graze
u 'S
5a
� � R
perch
e coarse
partimlate
rine matter
particulate
tier
a
hes
collectors
9 �­,i. Predators
ro -catfish
n
rz
Relative channel Width
Figure 1.5-1 — The River
Continuum (Vannote, et al; 1980)
illustrates the food chain connection
between headwater areas of first
order high gradient streams and the
wider, larger downstream areas in
the overall watershed.

Trees not only intercept rainfall so that it falls gently to the ground surface and is thus
able to penetrate the ground as groundwater recharge, but also store nutrients in their
trunks, branches, and roots (West Virginia Department of Natural Resources:
http://www.wvdnr.gov/Wildlife/Plants.shtm ). Fungi in the soil facilitate transport of
nutrients between trees and the soil. The soil stores nutrients which are processed by
soil microbes to regulate essential nutrient cycles involving oxygen, carbon dioxide,
nitrogen. Roots of the trees and of herbal vegetation help to stabilize the soil so that the
soil nutrients are not washed away by stormwater runoff. The ecological communities in
the headwater areas of first order high gradient streams consist not only of the
vegetation, but also the aquatic benthic macro invertebrates, fungi, and soil microbes.
Insect larvae, commonly grouped as shredders, constitute most of the aquatic benthic
macroinvertebrates in the headwater areas because they shred organic material into
components used by collectors and predators downstream.
2.0 GROUNDWATER
Groundwater recharge occurs from precipitation flowing downward through the soil to
weathered rock materials and to fractures, faults, bedding -plane separations, and joints
in the underlying bedrock. Seeps and springs form on mountain slopes where the
ground surface intercepts the bedrock fractures, faults, bedding -plane separations and
joints in the Appalachian Plateau Physiographic Province and the Valley and Ridge
Physiographic Province. The Valley and Ridge Physiographic Province herein
incorporates the Blue Ridge Physiographic Province. In the Piedmont Physiographic
Province, groundwater recharge from precipitation flows downward through the soil to
weathered rock materials and then into bedrock fractures, faults, bedding -plane
separations, and joints. However, in the Piedmont Physiographic Province, the flow of
groundwater is primarily through the weathered rock materials which occur as a thick
transition zone between soil and the underlying bedrock. Groundwater in the thick
wedge of unconsolidated sediments underlying Coastal Plain Physiographic Province is
recharged partially from precipitation, but mostly from groundwater flowing from the
transition zone of the Piedmont Physiographic Province into confined aquifers within the
Coastal Plain Physiographic Province.
2.1 Groundwater in the Appalachian Plateau Physiographic Province and the
Valley and Ridge Physiographic Province
In the Appalachian Plateau Physiographic Province, groundwater is recharged where
precipitation flows downward through faults, joints, bedding -plane separations, and
fractures in the underlying sedimentary rocks (Sheets and Kozar,2000). Although the
bedrock is mostly flat -lying in the Appalachian Plateau Physiographic Province, steep,
mountainous topography has developed due to erosion and downcutting through the

bedrock, creating deep V-shaped valleys. This erosional relief ranges from 200 feet to
1300 feet.
Bedrock underlying the Valley and Ridge Physiographic Province consists of
interbedded limestone and dolostone (carbonate rock), shale, and sandstone which has
been folded into anticlines and synclines and which has been highly faulted (Hollyday
and Hileman,1996). Groundwater is recharged from precipitation, which moves
downward through the soil and into the bedrock through joints, fractures, bedding -plane
partings, and dissolution openings (voids formed in the carbonate rocks).
Springs and seeps occur where the bedding planes, faults, and fracture sets intersect
the ground surface along mountain ridges (Figure 2.1-1). Seeps and springs maintain
the flow of water to headwater areas, where wetlands are located, and also to streams.
During times of drought, groundwater maintains a flow of water to streams. Where
there is deforestation and compaction of soil at the ground surface, there is a reduction
of groundwater recharge and, consequently, a reduction of available water through
fractures to maintain springs and seeps. Excavation and blasting intercepts
groundwater and also changes the amount and direction of groundwater flow. Seeps
and springs disappear where groundwater is no longer available. It is significant to note
that blasting activities along the ridges can destroy the areas where the springs occur,
changing the amount and direction of groundwater flow.
Figure 2.1-1 — Fractures within any
rock provide conduits through which
groundwater may flow downward or
at angles to the ground surface. Where
bedding planes of the rock or where
fractures in the rock intercept the
ground surface, it is common for springs
or seeps to occur. Seeps and springs
also provide water directly to streams.
Land surface
Springs
Bedrock
F
Fractures
Carbonate rock (limestone and dolostone) is present as bedrock underlying areas within
both the Appalachian Physiographic Province and the Valley and Ridge Province. A
distinctive karst terrain develops where surficial carbonate bedrock is present (Figure
2.1-2), consisting of numerous caves, crevices, cavities (voids), fractured rock,
disappearing streams, sinkholes, and springs. In areas where surficial sandstone or
shale overlies carbonate rock, karst features are not as noticeable. However, the karst
features (caves, crevices, cavities, disappearing streams, sinkholes, and springs) are
present in the underlying carbonate bedrock.

Figure 2.1-2 —
Features typical
of karst terrain.
Karst valley formed from
ccaleseing sinkholes
Sinkhole
- — Pond Disappearing i
Ginn!
spnng ` -- Solui3an
sinkhole— Cave Collapse --
�, -- —_ entrance sinkhole
River- _
Groundwater flow through carbonate bedrock in karst areas exhibits both diffuse flow
and conduit flow. Conduit flow consists of "integrated systems of openings ranging from
solutionally widened joints and bedding plane partings to pipelike passages many
meters in diameter" (White, 1988). Pipelike passages and larger solutionally widened
joints and bedding plane partings can be observed in the caves throughout the area,
and are also present, although inaccessible for observation, in limestone and dolomite
throughout the area. Dasher (2000) provides descriptions of groundwater in extensive
karst sub -basins of caves within the Greenbrier Limestone, which underlies a portion of
the proposed ACP construction route. Dye traces provide evidence of the groundwater
flow directions within the limestone. Springs attest to the flow of groundwater through
fractures and along bedding planes within the limestone, in addition to flow through
interconnected voids in the limestone. Groundwater flow within carbonate rock extends
far beyond the local area karst terrain. Where deforestation and compaction occurs in
the proposed ACP work corridor and associated areas, groundwater recharge is
reduced and has adverse impacts on groundwater within all bedrock, especially
carbonate bedrock, underlying the Appalachian Plateau Physiographic Province and the
Valley and Ridge Physiographic Province.
Surface water and groundwater are components in one integral unit. In its document,
"Sustainability of Ground -Water Resources", the USGS emphasizes that "Groundwater
is not a renewable resource". To understand this statement requires an understanding
of the global water budget and also an understanding that groundwater and surface
water are connected as one integral system. The global water budget, or hydrological
cycle, consists of precipitation, evaporation, and condensation. It is important to
recognize, however, that the hydrological cycle over the ocean (covering approximately
three-quarters of the earth) is essentially separate from the hydrological cycle over the
continents. Dennis Hartmann, in his book "Global Physical Climatology", provides an
excellent summary diagram (Figure 2.1-3) showing the pathways of the hydrological

cycle in terms of centimeters per year for the exchange of water. Through time, there
has been a delicate balance of the amount of precipitation transferred to the continents
from the hydrological cycle over the oceans and the amount of surface water flowing
into the ocean. In this slide, the arrow representing the amount of water from the
ocean's hydrological cycle indicates that 11 centimeters per year transfers from the
ocean to the continent. The arrow showing the runoff from the land surface indicates
that 11 centimeters flows back to the ocean from the continent. It is obvious that when
groundwater recharge is reduced and streamflow into the oceans is increased, a
situation is created where there is no longer a balance: when streamflow to the oceans
exceeds the amount of precipitation from the oceans back onto the continents, the
water in the continental hydrological cycle is lost forever.
GLOBAL WATER BALANCE
11(-27) 4R
IL 118 75
7
14'7 27 (-11)
LAN❑ 308 o£asa
OCEAN 70%.f—
Figure 2.1-3 — Our water resources are finite on our continents. Calculations of the
global water balance indicate that water transferred to land from the oceans is balanced
by water drainage from land to the oceans. If water drainage to the oceans exceeds the
amount of water transferred to land from the oceans, our water resources on land are
lost. (Units are in centimeters per year. Diagram by Dennis L. Hartmann, Global
Physical Climatology, 1994.)
2.2 Groundwater in the Piedmont Physiographic Province
In the Piedmont Physiographic Province, groundwater recharge from precipitation flows
downward through the soil to weathered rock materials and then into bedrock fractures,
faults, bedding -plane separations, and joints. However, in the Piedmont Physiographic
Province, the flow of groundwater is primarily through the weathered rock materials
which occur as a thick transition zone between soil and the underlying bedrock, as
depicted in Figure 2.2-1. Groundwater flows from the transition zone into fractures and
other openings in the bedrock.

Figure 2.2-1 — Groundwater is
stored mostly in the weathered rock,
or transition zone, above bedrock.
Groundwater flows through the
transition zone and through
fractures and other openings in the
bedrock in the Piedmont
Physiographic Province. (Figure
excerpted from Groundwater in
4 _lull
�j ON saturatetl zone
9i I_ll�'4�a.u�'C
•Yr�low water table ,
Al
�. relative '
u
w orage.
paces,
volume
Virginia,
http://www.virginiaplaces.org/watersheds/groundwater.html)
2.3 Groundwater in the Coastal Plain Physiographic Province
Groundwater in the thick wedge of unconsolidated sediments underlying Coastal Plain
Physiographic Province is recharged partially from precipitation and partially from
groundwater flowing from the transition zone of the Piedmont Physiographic Province
into confined aquifers within the Coastal Plain Physiographic Province (McFarland and
Bruce, 2006). Figure 2.3-1 depicts the groundwater flow in the Coastal Plain
Physiographic Province.

WEST
EAST
PIEDMONT
PHYSIOGRAPHIC
PROVINCE CCASTAL PLAIN PHYSICJGRAPHIC PROVINCE
500 J FaIIZane - 5100
Surfioialaquifer SUFFOLK SCARP
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I I
L` 10 �a KILOMETERS
Figure 2.3-1 — Relationships and directions of groundwater flow in the Coastal Plain Physiographic Province and the
Piedmont Physiographic Province (McFarland and Bruce, 2006).

An aquifer refers to a geological formation which is permeable enough to transport
groundwater. The surficial aquifer in the Coastal Plain Physiographic Province is
designated as an unconfined aquifer because there are no confining, relatively
impermeable geological materials above the surficial aquifer. Groundwater recharge
occurs when precipitation infiltrates the surficial soil and migrates downward to the
water table.
Aquifers which occur below the surficial aquifer are limited to specific permeable
portions of the underlying geological formations. Relatively impermeable material, such
as clay, confines the uppermost and lowermost limits of the aquifer. Such aquifers are
considered to be confined aquifers. There are several aquifers in the coastal plain
which occur below the surficial aquifer as a wedge which begins at the Piedmont
Physiographic Province and increases with depth to the east under the entire coastal
plain. Although the major source of recharge for the deeper aquifers is associated with
the Piedmont Physiographic Province (Harned, 1989; Lautier, 1998) and, recharge also
flows downward from the surficial aquifer and also from each aquifer to the next deeper
aquifer.
The lower aquifers occur in hydraulically connected sediments within various geologic
formations at depth, such that the aquifers do not necessarily correlate with a specific
geologic formation. Less permeable deposits, such as silty clay, form confining units
between the lower aquifers. Groundwater from the higher aquifers flows downward to
lower aquifers at a rate of approximately 1 inch per year (Lautier, 1998). Although this
constitutes some recharge to successively lower aquifers, the overall groundwater
movement is to the east within each aquifer. Sediment variations laterally within the
geologic formations also result in variability with respect to groundwater availability at
specific locations.
Decreased groundwater recharge in the Piedmont Physiographic Province results in
decreased hydraulic head within the aquifers to the east, within the Coastal Plain
Physiographic Province. Additionally, it has been documented that long-term
withdrawals near Suffolk, Virginia, have resulted in a groundwater table decrease of 200
feet (McFarland and Bruce, 2006). The decrease in hydraulic head in the Coastal Plain
aquifers has already caused salt water intrusion from the ocean in aquifers in
northeastern North Carolina and constitutes a threat to Virginia Coastal Plain aquifers
(McFarland and Bruce, 2006).

DWR
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Saltwater
Intrusion
Freshwater
Figure 2.3-2 — Saltwater intrusion into aquifers results when groundwater is over -used
and when there is a decrease in the hydraulic gradient of the aquifer (North Carolina
Division of Water Resources illustration from
httD://aauiferstoraaeandrecovery.weeblv.com/saltwater-intrusion-nc.html).
3.0 CONSTRUCTION IMPACTS CAUSED BY DEWATERING
ACTIVITIES
It is stated in the DEIS that "when necessary, trench water would be removed and
discharged into an energy dissipation/sediment filtration device, such as a geotextile
filter bag and/or straw bale structure, to minimize the potential for erosion and
sedimentation." Although the DEIS does not include construction details, the
International Pipe Line & Offshore Contractors Association (www.iploca.com) provides
safety guidelines pertaining to pipeline construction: "[D]ewatering is necessary to be
able to excavate a flat, smooth, and stable bottom to lay the pipe... Groundwater
movement can also cause material to run off from under the pipe, which could then
bend under its own weight as could be unevenly supported. Groundwater removal is
also necessary to allow safe and convenient access to the workers who will often
perform various tasks in the trench such as inspecting, welding, coating, or repairing.
Pipeline buoyancy can also be a problem if water accumulates at the bottom of the
trench... Migration of fine materials ("fines") in or out of the pipe zone can result in loss
of pipe support and must be prevented. This can be accomplished through the use of
waterstops or geofabrics. Water should be removed from the trench before final grading
of the bedding. The trench should be kept dry during all phases of pipe installation."

Figure 3.0-1 — Examples of pipeline trench instability (www.iploca.com).
3.1 Consequences of Dewatering
Dewatering of near -surface groundwater or a near -surface perched aquifer removes
water from seeps and springs that support aquatic habitats in headwater areas of first
order high gradient streams. Deforestation and soil compaction decrease infiltration of
precipitation for groundwater recharge. Therefore, the combination of decreased
groundwater recharge along with dewatering of near -surface groundwater will result in
permanent depletion of water for seeps and springs in headwater areas of first order
high gradient streams. It is stated in the DEIS that the mainline trenches for 42 -inch
diameter pipeline and 36 -inch diameter pipeline will be 30 feet wide. This constitutes a
substantial area to be dewatered.
Groundwater in karst areas moves through carbonate rocks (limestone, dolostone) as
conduit flow. There is no discussion offered by FERC or ACP concerning an evaluation
of reduced groundwater recharge to karst aquifers.
Ge[p In ppnk
yj 1'
Wet clays and loams "slab off" Firm dry clays and loamy crack
Wet sands and gravel slide Sandy soil collapses straight down
Figure 3.0-1 — Examples of pipeline trench instability (www.iploca.com).
3.1 Consequences of Dewatering
Dewatering of near -surface groundwater or a near -surface perched aquifer removes
water from seeps and springs that support aquatic habitats in headwater areas of first
order high gradient streams. Deforestation and soil compaction decrease infiltration of
precipitation for groundwater recharge. Therefore, the combination of decreased
groundwater recharge along with dewatering of near -surface groundwater will result in
permanent depletion of water for seeps and springs in headwater areas of first order
high gradient streams. It is stated in the DEIS that the mainline trenches for 42 -inch
diameter pipeline and 36 -inch diameter pipeline will be 30 feet wide. This constitutes a
substantial area to be dewatered.
Groundwater in karst areas moves through carbonate rocks (limestone, dolostone) as
conduit flow. There is no discussion offered by FERC or ACP concerning an evaluation
of reduced groundwater recharge to karst aquifers.

3.2 DEIS Deficiencies Concerning Groundwater Mitigation
It is stated in the DEIS that there would only be localized, temporary alteration of
groundwater levels due to deforestation, grading, soil compaction, trenching, and soil
stockpiling. It is further stated that groundwater impacts would be minimized by using
temporary and permanent trench plug and interceptor dike. These practices are
designed to dewater the trench. These practices are inconsistent with preserving the
downward migration of precipitation through the soil to bedrock fractures which supply
water to seeps and springs in wetland and headwater areas of first order streams high
gradient streams in the Appalachian Physiographic Province, the Valley and Ridge
Physiographic Province and the Blue Ridge Physiographic Province.
The proposed ACP construction is located on mountain ridges and steep slopes of
mountain ridges. These areas are where the greatest amounts of precipitation provide
the greatest recharge of groundwater for the river continuum and for conduit flow in
karst terrain. As illustrated in Figure 3.2-1, when warm air masses encounter the
mountains, the air masses rise and become cooler, resulting in precipitation.
Precipitation is intercepted by the forest tree canopy so that the rain falls gently on the
ground surface. This process reduces stormwater runoff and increases groundwater
recharge by facilitating the penetration of water into the soil. Water migrates downward
through the soil to recharge groundwater. The groundwater accumulation at higher
elevations creates a hydraulic head which forces water downgradient to flow through
bedrock fractures, bedding plane partings, and faults. The hydraulic head thereby
causes water to replenish wetlands and headwater areas through seeps and springs
where the ground surface intercepts bedrock fractures, bedding plane partings, and
faults. The hydraulic head causes water to flow into residential wells. The hydraulic
head causes water to flow through seeps and springs into streams during times of low
stream water, providing a continued source of water to aquatic habitats. The hydraulic
head provides water for conduit flow in karst terrains. The hydraulic head in Coastal
Plain aquifers prevents saltwater intrusion. Where the hydraulic head is permanently
reduced by construction activities because of deforestation, soil compaction, and
dewatering for trenches, there will be a depletion of groundwater flow to seeps, springs,
wetlands, streams, and residential wells.

Temperature
3000 -4°C
2250 2"C
V Prevailing wind
1500 19°C
Evaporation
k rid
Figure 3.2-1 — When warmer air masses rise over mountainous areas, the air masses
become cooler, causing precipitation. Precipitation on forested ridges provides
groundwater recharge and sustained hydraulic head to provide water for seeps, springs,
wetlands, streams, and residential wells.
3.3 Ground Surface Drainage and Original Contours Cannot Be Restored
After Pipeline Construction
It is stated in the DEIS that, "Atlantic and DTI would restore the ground surface to
original contours as closely as practicable and restore vegetation on the right-of-way to
establish surface drainage and recharge conditions as closely as possible to those prior
to construction." Leveling of the rugged mountain terrain for the 125 -foot+ wide work
corridor will require extensive excavation into hillsides and removal of bedrock outcrops.
It is not reasonable to consider that original contours could be restored after
construction. Additionally, there are no plans to restore a forested area within the work
corridor. It is the forest canopy that intercepts rainfall so that it gently falls to the ground
to penetrate the surficial soils and recharge groundwater. A grassed area cannot
accomplish this function.
4.0 IMPERVIOUS AREAS RESULT IN INCREASED STORMWATER
DISCHARGE AND INCREASED DOWNSTREAM STREAM
BANK EROSION AND SEDIMENT DEPOSITION IN STREAMS
4.1 Greater Stormwater Discharge Results from Impervious Work Corridor
Surfaces
A surface runoff coefficient is used in stormwater discharge calculations to determine
the peak stormwater runoff discharge for specific storms, such as a 24-hour 2 -year

storm. A forested area differs from the work corridor ground surface because the tree
canopy intercepts the rainfall, allowing the rainfall to gently reach the ground surface.
The tree canopy thereby reduces the intensity of the precipitation. Without protection of
the tree canopy, there will be greater intensity and, consequently, greater stormwater
runoff amounts and velocities. It is stated in the DEIS that 12,030.7 acres of land would
be disturbed and that "Following construction, 5,976.0 acres of new land would be
permanently maintained for operation and maintenance of the project facilities. The
remaining 6,054.7 acres... would be restored and allowed to revert to former use." This
statement is inconsistent with land cover runoff designations used in standard
engineering practices. The WV Department of Highways 2007 Drainage Manual
(Holmes and Chintala, 2007) provides information for determining sheet flow, which is
defined as "a shallow mass of runoff on a plane surface with the depth staying uniform
across the sloping surface. Typically, flow depths will not exceed two inches." The
sheet flow travel time is determined by an equation that uses a "roughness coefficient"
(provided in McCuen, et al, "Hydraulic Design Series 2, Highway Hydrology, October
2002) which reflects the surface roughness over which the surface water is flowing. A
gravel surface, which would be similar to the compacted construction work corridor, has
a roughness coefficient of 0.024. A grassed surface has a roughness coefficient
ranging from 0.15 to 0.24. A forested surface has a roughness coefficient ranging from
0.40 to 0.800. Pipeline construction in originally forested areas will result in measurably
higher stormwater discharge rates.
4.2 Greater Stormwater Peak Discharge Results from Deforestation and
Impermeable Work Corridor Surfaces
Increased impervious areas not only increase the amount of stormwater discharge to
receiving streams, but also increase the frequency of peak runoff rate because the
increased amount of impervious areas results in less infiltration (VDCR, 1999). As a
consequence, "it takes less rainfall to produce the same volume of runoff. Therefore, the
peak rate of runoff that normally occurs on a 2 -year frequency before development, may
occur several times a year following development." (VDCR, 1999).
A study of natural channels is presented in Leopold, et al (1964), concluding that natural
channels are shaped by the 1'/2- to 2 -year frequency storm event. However, with
increased frequency of the 2 -year peak rate, increased stream bank erosion will result.
The increased impervious areas resulting from the proposed ACP construction activities
will therefore result in greater downstream stream bank erosion, which will continue
after construction is completed.
Both vertical scour of the stream bed and stream bank erosion release sediment to the
streams, increasing embeddedness (Figure 4.0-1), which fills in the spaces between
pebbles and cobbles in the stream bed. These spaces serve as aquatic habitats for
insect larvae and minnows, which are necessary for the food chain within the river
continuum (Vannote, et al, 1980).

Heavily embedded
Lightly embedded
D water
® sand & silt
411M rocks
Figure 4.0-1 — Cobbles and pebbles provide aquatic habitats and protection for aquatic
organisms. Insect larvae, which constitute the base of the river continuum food chain,
reside on the cobbles and pebbles. Minnows and juvenile fish hide in the spaces
between cobbles and pebbles for protection. When sand and silt fill the spaces
between the cobbles and pebbles, the aquatic habitats and protection areas are
destroyed. When the aquatic habitats become heavily embedded or are removed for
trenching and stream crossing work spaces, they cannot be restored.
The consequences of embeddedness are provided by Jessup and Dressing (2015) as:
1) Displacement of interstitial habitat space; 2) Clogging of water movement under the
channel bed (hyporheic zone); 3) Decreased or altered primary algal productivity; 4)
Increased macroinvertebrate drift; 5) Abrasion or smothering of gills and other organs;
6) Uptake of sediment -bound toxicants that are increasingly associated with fine
particles; and 7) Larger scale homogenization or disturbance of habitat types."
The Virginia Department of Conservation and Recreation (VDCR) states in its
Stormwater Management Handbook (VDCR, 1999) that, "The cumulative effect of
sedimentation, scouring, increased flooding, lower summer flows, higher water
temperature, and pollution contribute to the overall degradation of the stream
ecosystem. Many studies have documented the decline of fish diversity in urbanized
watersheds. The aquatic insects which are a major food resource for fish are impacted
by the increased sediment load, trace metals, nutrients, and flow velocities.
Less noticeable impacts to the stream systems are changes in water temperature,
oxygen levels, and substrate composition." Increased stormwater discharge will result
from construction impacts to high gradient first order streams. Release of sediments
from downstream stream bank erosion and stream bed scour will elevate sediment
concentrations and turbidity in the stream water.
The USGS (Krstolic and Chaplin, 2007; Lotspeich, 2009; Messinger, 2009) bankfull
discharge classification system for streams in the Appalachian Physiographic Province,
the Piedmont Physiographic Province, and the Coastal Plain Physiographic Province is
based on streams with watersheds ranging from less than 200 acres to greater than

160,000 acres in order to show the relationship between peak flow and bankfull
discharge. This relationship demonstrates the connectivity between first order high
gradient streams and stream systems of higher stream order. Connectivity is related to
the River Continuum Concept (Vannote, et al., 1980). "Connectivity" is defined by the
Environmental Protection Agency (EPA, 2015) as "the degree to which components of a
watershed are joined and interact by transport mechanisms that function across
multiple spatial and temporal scales." The connectivity descriptors include the following
metrics: frequency, duration, magnitude, timing, and rate of change... of physical and
chemical fluxes to and biological exchanges with downstream waters.
5.0 STREAM CROSSINGS RESULT IN SEDIMENT DEPOSITION IN
STREAMS
In the DEIS, it is stated that, "There are 1,989 waterbody crossings on ACP and SHP
(some waterbodies are crossed more than once), a number which are classified as
warmwater or coldwater fisheries. Several waterbodies that are considered sensitive
due to the presence of sensitive aquatic species, such as trout, anadromous fish, or
federal or state/commonwealth protected species, would also be crossed. In -stream
pipeline construction across waterbodies could impact aquatic species and their
habitats, increase sedimentation and turbidity, alter or remove aquatic habitat cover,
cause stream bank erosion or scour, impinge or entrain fish and other biota during
water withdrawals, and increase the potential for fuel and chemical spills."
The increased sedimentation and turbidity ultimately increase embeddedness. The
increased embeddedness constitutes a significant degradation for streams that are
classified as warmwater or coldwater fisheries because the juvenile fish hide in the
spaces between cobbles and pebbles for protection. Streams are categorizes as Tier 1
(impaired), Tier 2, and Tier 3 (high quality). It is stated in the DEIS that, "Streams
cannot be categorized as Tier 1 or Tier 2 at this time, but would be assigned by the
WVDEP on a case-by-case basis during permitting...". This statement is inconsistent
with information provided on the West Virginia Department of Environmental
Protection's (WVDEP) website. Specifically, Tier 1 streams are impaired and
designated as 303(d), listed on the DEP website at
http://www.dep.wv.gov/WWE/watershed/IR/Documents/IR 2014 Documents/2014Finall
RDocuments/EPAApprovedWebSupplementsOnly.pdf . In compliance with the federal
Clean Water Act, Total Maximum Daily Loads (TMDLs) of various contaminants are
developed for Tier 1 streams. It is further stated in the DEIS that it is not possible to
identify Tier 3 streams and that WVDEP or VDEQ would need to identify these streams.
This is inconsistent with information on the WVDEP website, which lists Tier 3 streams:
http://www.dep.wv.gov/WWE/Programs/wqs/Documents/Tier%203%201nfo/WV Tier 3
Maps 20101006.pdf , http://www.dep.wv.govMWE/Programs/wqs/Pages/default.aspx.
Tier 2 streams are all other streams not listed as Tier 1 or Tier 3.

6.0 STREAM WATER QUALITY
6.1 Water Quality Standards
Water quality standards are specified by the Federal Clean Water Act. West Virginia,
Virginia, and North Carolina have developed Total Maximum Daily Loads (TMDLs) of
contaminants to comply with the Clean Water Act. Additionally, state standards require
water quality protection. Water quality standards are specified in WV Code 47CSR2
(http://www.dep.wv.gov/WWE/Programs/wqs/Documents/47CSR2%20070816.pdf),
which establishes water quality standards for specific water use categories under §47-2-
6. Category A pertains to water supplies for human consumption. Category C pertains
to water contact for recreation. In this section, it is stated that "at a minimum all waters
of the State are designated for the Propagation and Maintenance of Fish and Other
Aquatic Life (Category B)... consistent with Federal Act goals." Category 131 pertains to
warm water fishery streams. Category B2 pertains to trout waters. Category B4
pertains to wetlands. Virginia and North Carolina have developed similar TMDLs and
have state laws pertaining to the protection of water quality.
Using West Virginia as an example, the following water quality standards (as provided
in WV Code 47CSR2) are pertinent for stormwater discharge from the proposed MVP
gas pipeline construction. Explanations of the relevance of these parameters are
provided along with the limits excerpted from WV Code 47CSR2:
• Parameter 8.1 Dissolved Aluminum (all Aquatic Life):
Aluminum is released to stream water with sediment from streambank erosion.
• Parameter 8.13 Fecal Coliform (all Human Health)
Fecal coliform is discharged to stream water with stormwater discharge. Sources
of fecal coliform include wildlife in forested areas and meadows, livestock in
pastures, and pets in urban areas. "Maximum allowable level of fecal coliform
content for Water Contact Recreation (either MPN or MF) shall not exceed
200/100 ml as a monthly geometric mean based on not less than 5 samples per
month; nor to exceed 400 /100 ml in more than ten percent of all samples taken
during the month."
• Parameter 8.15 Iron (all Aquatic Life and Water Supplies for Human
Consumption):
Iron is released to stream water with sediment from streambank erosion. "Iron
concentration limits are 1.5 mg/L for Water Supplies for Human Consumption;
1.5 mg/L for 131 and B4 Aquatic Life; and 1.0 mg/L for B2 Aquatic Life."
• Parameters 8.26 and 8.26.1 Radioactivity (all Aquatic Life, all Human Health,
and all Other Uses):
The intended gas to be transported in the proposed MVP gas pipeline is derived
from hydrofracturing of Marcellus shale and associated rock units. Marcellus
shale is contains naturally occurring radioactive elements which are transported

in the gas. Radon is one of the elements, which breaks down into lead,
considered a toxin. Where pig launchers are located, the gas escapes to the
surrounding area. Cleaning operations at the pig launcher locations release
radon and lead to the surrounding area. In reference to Parameter 8.26: "Gross
Beta activity is not to exceed 1000 picocuries per liter (pCi/I), nor shall activity
from dissolved strontium -90 exceed 10 pCi/I, nor shall activity from dissolved
alpha emitters exceed 3 pCi/I." In reference to Parameter 8.26.1: "Gross total
alpha particle activity (including radium -226 but excluding radon and uranium
shall not exceed 15 pCi/I and combined radium -226 and radium -228 shall not
exceed 5pCi/I; provided that the specific determination of radium -226 and
radium -228 are not required if dissolved particle activity does not exceed 5pCi/I;
the concentration of tritium shall not exceed 20,000 pCi/I; the concentration of
total strontium -90 shall not exceed 8 pCi/I in the Ohio River main stem."
• Parameter 8.29 Temperature (Aquatic Life 131):
Increased turbidity from sediment discharged to streams results in increased
temperatures. Deforestation also results in higher temperatures and can be
detrimental to aquatic species in the headwater areas of first order high gradient
streams. "Temperature rise shall be limited to no more than 5°F above natural
temperature, not to exceed 87°F at any time during months of May through
November and not to exceed 73°F at any time during the months of December
through April. During any month of the year, heat should not be added to a
stream in excess of the amount that will raise the temperature of the water more
than 5°F above natural temperature. In lakes and reservoirs, the temperature of
the epilimnion should not be raised more than 3°F by the addition of heat of
artificial origin. The normal daily and seasonable temperature fluctuations that
existed before the addition of heat due to other natural causes should be
maintained."
• Parameter 8.33 Turbidity (Aquatic Life B1, B2, 134; and Human Health A and C):
Turbidity results from the introduction of sediment into stream water. Sediment is
introduced to stream water from stormwater discharge and from streambank
erosion. "No point or non -point source to West Virginia's waters shall contribute
a net load of suspended matter such that the turbidity exceeds 10 NTU's over
background turbidity when the background is 50 NTU or less, or have more than
a 10% increase in turbidity (plus 10 NTU minimum) when the background
turbidity is more than 50 NTUs. This limitation shall apply to all earth disturbance
activities and shall be determined by measuring stream quality directly above and
below the area where drainage from such activity enters the affected stream. Any
earth disturbing activity continuously or intermittently carried on by the same or
associated persons on the same stream or tributary segment shall be allowed a
single net loading increase."

The 2006 West Virginia Erosion Sediment Control BMP Manual, revised August 2016,
(http://www.dep.wv.qov/WWE/Programs/stormwater/csw/Documents/E°/`20and%20S B
MP 2006.pdf) further explains that, "The primary numeric water quality standard
addressing earth disturbing activities is turbidity. Other criteria that could be violated by
runoff from a construction project include pH and iron. Turbidity is defined as an
expression of the optical property that causes light to be scattered and absorbed rather
than transmitted in straight lines through the sample. It is an indirect measurement of
how much suspended material is in a sample of water."
The U.S. Environmental Protection Agency (EPA) is the regulatory agency for the Clean
Water Act Section 402 Stormwater Permit. It is specifically stated by EPA that, "The
pollutant of concern during oil and gas -related construction is usually sediment
(expressed as total suspended solids or turbidity). Regardless of the type of pollutant(s)
in a discharge, all water quality standards of the receiving waterbody must be
protected." (https://www.epa.gov/npdes/oil-and-gas-stormwater-permittinq#when).
6.2 Total Maximum Daily Loads
The Erosion and Sediment Control Best Management Practices Manual (E&SC-BMP,
WVDEP, 2006) explains: "If construction activities will contribute pollutants for which a
specific receiving water is listed as impaired, permittees must comply with Total
Maximum Daily Loads (TMDLs) set for the receiving stream. Construction sites may be
designated as contributors to the impairment if a stream is listed as impaired because of
sediment or iron."
7.0 AREAS MOST SUSCEPTIBLE TO EROSION
7.1 Documentation of Sediment Release During Construction Activities Using
the Revised Universal Soil Loss Equation (RUSLE2)
In 1978, Wischmeier and Smith published the Universal Soil Loss Equation (USLE) to
estimate the soil loss due to erosion, which occurs naturally and during changes in land
use, such as construction. In 2013, the U.S. Department of Agriculture — Agricultural
Research Service published the Revised Universal Soil Loss Equation, Version 2
(RUSLE2) to estimate the amount of sediment transported to receiving streams, based
on soil, slope, land cover, and land use information. The U.S. Geological Survey
(USGS) conducted a study (USGS Study), described in USGS Fact Sheet FS -109-00
(Owens, et al, August 2000) to evaluate 1) the increase in sediment transported during
construction; and 2) the predictability of the Universal Soil Loss Equation. During the
study, the USGS monitored rainfall depth and intensity, water quality, water level, and
water runoff volume (discharge) for a 1.72 -acre commercial site with a slope of 8
percent and a 0.34 -acre residential site with a slope of 4 percent. Pre -construction,
during -construction, and post -construction results of the USGS Study included: 1) there

was excellent agreement between the soil loss loads predicted by using the USLE
calculations and the actual, measured sediment load; 2) the sediment load was 107
times greater during construction at the commercial site and 4 times greater at the
residential site; and 3) rainfall intensity was responsible for the greatest concentrations
of total and suspended solids. Where sediment is released to receiving streams during
construction activities, the sediment accumulates in the stream beds, increasing
embeddedness, which remains in the stream bed after construction has been
completed.
7.2 Inadequate Information Provided in the DEIS Pertaining to the Use of
RUSLE2
In the DEIS Supplements provided on January 10, 2017 by ACP to FERC, an example
of RUSLE2 calculations is presented in Appendix P. The example consists of using
overall soil complexes rather than individual soils series, so there is no specific
information about the amount of silt, clay, or sand content. Additionally, RUSLE2
calculations use stormwater discharge as one of the variables. Discharge is calculated
using the area of a specific drainage basin. In the ACP example, there is no description
of the drainage basin area being used. Instead, two non-descript areas in Bath County,
Virginia, are referenced by slope steepness. The information provided in Appendix P of
the DEIS does not provide adequate information to determine soil loss amounts in
specific areas.
7.3 Steep Slope Failure: Soil Landslides
It is stated in the DEIS that a considerable extent of the proposed ACP construction
area is susceptible to landslides: "In West Virginia, 73 percent of the AP -1 mainline
route would cross areas with a high incidence of and high susceptibility to landslides. In
Virginia, approximately 28 percent of the AP -1 mainline route would cross areas with a
high incidence of and high susceptibility to landslides (Highland, Bath, Augusta, and
Nelson Counties); 21 percent would cross areas with a moderate incidence of and high
susceptibility to landslides (Augusta, Nelson, and Buckingham Counties); and 7 percent
would cross areas with a moderate incidence of and moderate susceptibility to
landslides (Augusta County)." It is further stated that colluvium was observed on most
of the steep slopes. Colluvium consists of sediments, including clay -sized up to
boulder -sized sediments, which is deposited downslope by mass -wasting or overland
flow. It is further stated in the DEIS that "Signs of creep were often observed in the
colluvium." Also, the creep in the colluvium "can be an indication that slope instability
could be induced during pipeline construction activities." Creep is indicative of
continued downslope movement of the observed colluvium. With continued creep
during and after construction, sediment will continue to move downslope toward
receiving streams and sinkholes.
In the construction details provided in Appendix C of the supplementary DEIS
documents provided on January 10, 2017 by ACP to FERC, a revised landslide

mitigation design is provided for two steep slope areas, one of which is within the
Monongahela National Forest and the second one of which is within the George
Washington National Forest, along the proposed ACP construction area. The plan
includes placement of rip -rap at the base of the slope. However, the plan does not
include an area where the rip -rap would be "keyed" into stable underlying material. If
the rip -rap is not properly keyed into stable material, it will fail during a landslide. Also,
soil nails are shown to extend 8 feet to 15 feet through a surficial steel mesh blanket
intended to stabilize the colluvium. The construction drawings and narrative do not
provide information about the depth to bedrock or the use of soil nails where bedrock is
encountered. The depth to bedrock is 20 inches to 40 inches at numerous locations
where steep slopes occur along the proposed ACP construction area. Although the
locations and results are not provided, it is stated in the DEIS that soil test pits were
excavated to depths of 50 inches. If bedrock is deeper than 50 inches, even though the
trench for the proposed ACP construction is approximately 10 feet deep in these
locations, there appears to be no substantial data to ascertain the depth to bedrock for
placement of soil nails. Specific soils information is provided by the Natural Resources
Conservation Service (NRCS). The specific soils information provides the depth to
bedrock for each soils series. In the DEIS, a table is presented that provides the
acreage of soils classified as shallow to bedrock. However, there is no comprehensive
table providing the specific soils which are present between specific mile posts along
the proposed ACP route.
7.4 Steep Slope Failure: Bedrock Landslides
The DEIS does not present any measurements for bedrock orientation on the numerous
steep slopes extending along the proposed ACP construction area. In the Appalachian
Plateau Province, the bedrock is predominantly flat -lying. The bedrock consists mostly
of interbedded shale, siltstone, and sandstone, which becomes unstable due to
differential weathering. The shale and siltstone weather more quickly than the
sandstone. The weaker shale and siltstone deteriorate such that the overlying
sandstone moves downslope when it is no longer supported by the weathered shale
and siltstone. In West Virginia, the West Virginia Geological and Economic Survey
(WVGES) has determined that landslide -prone areas occur mostly on slopes of 15% to
45% on red shale bedrock. Such slopes are pervasive throughout the areas in West
Virginia where the ACP route is proposed. Therefore, there is potential for significant
landslide occurrences that would result from construction of the proposed ACP in West
Virginia.
In the Valley and Ridge Physiographic Province and the Blue Ridge Physiographic
Province, the bedrock has been tilted and deformed by tectonic processes in the
geologic past. The bedrock consists of interbedded limestone, shale, siltstone,
sandstone in these physiographic provinces. Where bedrock is tilted away from the
work area, the limestone, shale, and siltstone deteriorate more quickly than the
sandstone such that the sandstone moves downslope when no longer supported by the
bedrock that weathers more quickly. Where the bedrock is oriented downslope,
bedrock slabs move downslope as landslides. Soil nails and wire mesh netting are
inconsequential in preventing the movement of bedrock slabs.

At all steep slope locations, the bedrock is fractured and there are bedding plane
partings and faults. The fractures and faults are usually at angles to the bedding plane
partings, facilitating the movement of bedrock wedges downslope. Information is
provided in the DEIS pertaining to the contours and the steep slopes; however, there is
no information about the bedrock orientation or the orientation of fractures and faults.
8.0 DEIS DEFICIENCIES OF BEST MANAGEMENT PRACTICES
Best Management Practices (BMPs) provide the only methods of managing stormwater
runoff in order to satisfy the requirements of the stormwater permits for which ACP has
not yet received. Evaluations of BMPs indicate that there will always be a certain
percentage of sediment in the stormwater discharge from a construction site that will
discharge to receiving streams. Although ACP has not provided construction details or
BMP typical drawings, the following BMPs are typically used in gas pipeline installation
areas:
• Temporary ROW Diversion Berm and Sediment Trap Outlet
• Silt Fence, Super Silt Fence and Belted Silt Retention Fence
• Compost Filter Sock
• Waterbars
• Trench Plugs
• Erosion Control Blanket/Flexterra/or equivalent
• Vegetative Stabilization
There are numerous ratings for BMPs, providing a range of percent effectiveness
values. However, there is agreement that none of the BMPs can provide 100 percent
effectiveness. In the Universal Soil Loss Equation guidance document prepared by
Wood (2015), the percent effectiveness is provided for the following: sediment trap, 80
percent; silt fence, 40 percent; vegetative buffer, 40 percent.
8.1 Temporary ROW Diversion Berm and Sediment Trap Outlet
This BMP typically consists of a sediment berm and ditch. The sediment trap outlet is
typically directed onto adjacent land. It is important to avoid concentrated flows where
the water is directed from the sediment berm to the outflow area in order to avoid
additional erosion hazards. The West Virginia Erosion and Sediment Control -BMP
Manual (E&SC-BMP Manual) specifies that the drainage area for this type of BMP
should not exceed 5 acres and that the minimum cross section should be adequate for
the anticipated flows but at a minimum must handle the peak discharge from a 2-
year/24-hour storm. ACP has not provided any drainage areas or peak discharge
calculations.

8.2 Silt Fence, Super Silt Fence and Belted Silt Retention Fence
The E&SC-BMP Manual states that, "Silt fence does not actually filter sediment from
muddy water", and cautions that, "Intercepted sediment laden water must always be
diverted to a sediment trap or sediment basin, never silt fence." Additionally, the ES&C-
BMP Manual provides that silt fence is installed properly only when it is "placed on the
contour", that is, perpendicular to the flow of the water. ACP has not provided any
construction plan sheets to reference proper placement of silt fencing.
8.3 Compost Filter Socks, Pumped Water Filter Bags
The E&SC-BMP Manual provides velocity maximums for various conveyances in
accordance with slope and material. It is critical that the Compost Filter Socks and
Pumped Water Filter Bags are in compliance with the velocity maximums. Delineations
of drainage areas are a requirement for velocities to be calculated. ACP has not
provided any drainage delineations, construction plan sheets, or calculations
determining runoff velocities.
8.4 Erosion Control Blanket/Flexterra/or equivalent and Vegetative Stabilization
The E&SC-BMP manual explains that "Erosion Control Blanket/Flexterra/or equivalent"
consist of netting or blanket materials that are used to stabilize disturbed surfaces and
promote the establishment of vegetation. They function by protecting the ground
surface from the impact of raindrops and stabilize the surface until vegetation can be
established. ACP has stated the use of steel mesh blankets at potential landslide
locations. However, the steel mesh blankets will only serve to prevent smaller rocks
from falling downslope, uncontrolled. Rock slabs and soil slumps will not be kept in
place by the steel mesh blankets.
8.5 Sediment Basins
One of the basic sediment control plan elements stated by the WVDEP
(http://www.dep.wv.qov/WWE/Programs/stormwater/csw/Documents/E%20and%20S B
MP 2006.pdf) is that "Prior to leaving a construction site, surface water runoff from
disturbed areas shall pass through a sediment basin/trap or other appropriate and
approved sediment removal BMP." The WVDEP Erosion Sediment Control BMP
manual states as an element that "Points of discharge and receiving streams shall be
protected from erosion due to increases in the volume, velocity, and peak flow rate of
surface water runoff from the project site."

The stormwater permit includes the definition of a "sediment basin" as "a temporary
structure consisting of an earthen embankment, or embankment and excavated area,
located in a suitable area to capture sediment -laden runoff from a construction site. A
sediment basin reduces the energy of the water through extended detention (48 to 72
hours) to settle out the majority of the suspended solids and sediment and prevent
sedimentation in waterways, culverts, streams and rivers. Sediment basins have both
wet and dry storage space to enhance the trapping efficiency and are appropriate in
drainage areas of five acres and greater." ACP has not provided any stormwater
discharge calculations for sizing sediment basins.
The Virginia Department of Environmental Quality's (DEQ) Stormwater Management
Manual (1999), states that for high intensity rainfall events, a bypass or diversion
structure is needed to allow large stormwater flows to bypass the BMP, thereby
preserving its integrity and avoiding flushing of previously captured sediments. This
results in sediment laden stormwater discharge to receiving streams.
Additionally, the DEQ states that with greater stormwater runoff from deforested land
surfaces, a greater volume of runoff will be stored in the sediment basin, with a
consequent longer duration of storage. Because the deforested land surfaces increase
the frequency of peak runoff, water in the sediment basin accumulates more frequently,
in addition to being stored longer. The result is that the sediment basin can quickly
degrade.
8.6 Trench Plugs
Trench plugs consist of relatively impermeable material placed in the trench to capture
water in the trench and direct the water downslope through a pipe toward a water bar.
The water is then directed downslope in an adjacent area. Depending on the volume of
water diverted by the water bar, the outflow may exhibit concentrated flow which will
cause additional erosion.
9.0 CUMULATIVE IMPACTS
Cumulative adverse impacts from construction of the proposed ACP result not only from
the physical extent of the proposed construction, but also from the specific location of
the proposed construction on mountain ridges and steep slopes. The Environmental
Protection Agency (EPA, 2015) stresses that, "All tributary streams, including perennial,
intermittent, and ephemeral streams, are physically, chemically, and biologically
connected to downstream rivers via channels and associated alluvial deposits where
water and other materials are concentrated, mixed, transformed, and transported.
Streams are the dominant source of water in most rivers, and the majority of tributaries
are perennial, intermittent, or ephemeral headwater streams. Headwater streams also
convey water into local storage compartments such as ponds, shallow aquifers, or

stream banks, and into regional and alluvial aquifers; these local storage compartments
are important sources of water for maintaining baseflow in rivers."
Rosgen (1994) developed a methodology for classifying stream types that provides
criteria for determining the stream type's sensitivity to disturbance, the sediment supply,
and the streambank erosion potential influence. Metrics for determining stream type
sensitivity include measurements of stream slope, stream bed material, bankfull
discharge, entrenchment (ratio of the width of the flood -prone area to the bankfull width
of the channel), and sinuosity. The U.S. Geological Survey (USGS) used the Rosgen
metrics to develop bankfull discharge curves in order to typify stable streams in different
physiographic provinces (Krstolic and Chaplin, 2007; Lotspeich, 2009; Messinger,
2009). When the typical bankfull discharge for a stream changes, the stream is no
longer stable. Bankfull discharge is exceeded due to higher peak flows of stormwater
runoff.
Use of these metrics, along with the Universal Soil Loss Equation (USLE) or Revised
Universal Soil Loss Equation (RUSLE) and with determination of the increase in
stormwater discharge due to the proposed ACP construction, provides the foundation
for determining the significance of environmental damage to streams resulting from the
proposed ACP construction.
In order to evaluate the interactions of precipitation, stormwater discharge, groundwater
recharge and retention, and stream baseflow, calculations must be performed at the
headwater tributary level. Because first order high gradient streams are well defined
and are considered to provide the basis for watershed evaluation (USFWS, 2007), it is
essential to select these smaller watersheds, typically 200 acres in size, to evaluate the
impact of construction projects.
Cumulative impacts can be assessed by measurements and calculations. Cumulative
impacts due to deforestation and soil compaction (creation of impervious surfaces)
can be measured in watersheds of first order streams, second order streams, and third
order streams. Increased stormwater discharge from construction activities can be
calculated by use of standard engineering equations. Increased sediment discharge
from construction activities can be predicted by the use of the Revised Universal Soil
Loss Equation. Increased stream bank erosion due to increased stormwater discharge
can be estimated from bankfull discharge curves. Cumulative adverse impacts to
groundwater can be measured by stream baseflow calculations.
However, in the DEIS, it is simply stated that the proposed ACP construction "would
result in temporary to long-term impacts on aquatic resources. Long-term impacts
related to slope instability adjacent to streams has the potential to adversely impact
water quality and stream channel geometry, and therefore downstream aquatic biota.
Atlantic and DTI would attempt to mitigate these impacts...". Increased sedimentation
in streams causes permanent increased embeddedness. Colluvial creep on steep
slopes is continuous and will provide a permanent supply of sediments to receiving
streams. Deforestation, soil compaction, and dewatering will permanently deplete

groundwater flow to seeps and springs that provide water to wetlands, headwater areas,
stream baseflow, and residential wells, and will permanently reduce the groundwater
hydraulic gradient. In the Coastal Plain Physiographic Province, the decreased
hydraulic gradient will result in permanent saltwater intrusion. In karst terrain,
decreased groundwater will permanently degrade cave environments and flow to
springs.
10.0 CONCLUSIONS
There will be permanent, significant adverse impacts to extensive areas where the ACP
construction is proposed. These impacts include:
1) Permanent increased stormwater discharge to streams due to deforestation and
soil compaction in the proposed pipeline construction areas;
2) Continual downstream stream bank erosion and stream bed due to increased
stormwater discharge from the proposed pipeline construction areas;
3) Continual release of sediment to streams, causing continual turbidity and
permanent embeddedness;
4) Continual degradation of the functions within first order high gradient streams,
which will adversely impact the food chain in the River Continuum;
5) Increased threat of landslides where proposed construction disturbs steep
slopes;
6) Depletion of groundwater resources due to impervious surfaces and dewatering;
7) Decrease of the groundwater hydraulic head which moves groundwater to
streams and residential wells, and prevents saltwater intrusion into coastal plain
aquifers.
Best Management Practices simply do not prevent all sediment from a construction site
from being transported by stormwater discharge to receiving streams. It is stated in the
DEIS that these impacts would only be temporary and localized. However, the location
of the proposed ACP construction within sensitive watersheds of first order high
gradient streams will permanently impact the entire River Continuum.

11.0 REFERENCES
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Curriculum vitae for
Pamela Crowson Dodds, Ph.D., L.P.G.
P.O. Box 217
Montrose, WV 26283
pamelart(d)-hughes.net
My education includes a bachelor's degree in Geology and a doctoral degree in Marine Science
(specializing in Marine Geology), both from the College of William and Mary in Williamsburg,
VA. I have a Credential in Ground Water Science from Ohio State University and I am a
Licensed Professional Geologist. I have held teaching positions at the high school level and at
the college level, and have provided geology and hydrogeology presentations, workshops, and
classes to state and federal environmental employees, to participants in the Regional
Conference in Cumberland, MD for the American Planning Association, and to participants in
the WV Master Naturalist classes. I have served as an expert witness in hydrogeology before
West Virginia government agencies.
As a Hydrogeological Consultant (2000 — Present), I have conducted hydrogeological
investigations, provided hydrogeological assessment reports, served as an expert witness in
hydrogeology before the West Virginia Public Service Commission in three cases and before
the West Virginia Environmental Quality Board in one case, and provided numerous
presentations and workshops in hydrogeology to state and federal environmental employees
(including USFWS and WV FEMA Managers), participants in the Regional Conference in
Cumberland, MD for the American Planning Association, participants at civic and landowner
meetings, and participants in the WV Master Naturalist classes.
As a Senior Geologist for the Virginia Department of Environmental Quality (1997-1999), 1
determined direction of groundwater flow and the pollution impacts to surface water and
groundwater at petroleum release sites and evaluated corrective actions conducted where
petroleum releases occurred. At sites where the Commonwealth of Virginia assumed
responsibility for the pollution release investigation and corrective action implementation, I
managed the site investigations for the Southwest Regional Office of the Virginia Department of
Environmental Quality (DEQ). This included project oversight from contract initiation through
closure.
As a Senior Geologist and Project Manager for the Environmental Department at S&ME, Inc.
(Blountville, TN, 1992-1997), 1 conducted geology and groundwater investigations. I supervised
technicians, drill crews, geologists, and subcontractors. The investigations were conducted in
order to obtain permits for landfill sites and to satisfy regulatory requirements for corrective
actions at petroleum release sites. My duties also included conducting geophysical
investigations using seismic, electrical resistivity, and ground penetrating radar techniques. I
conducted numerous environmental assessments for real estate transactions. I also conducted
wetlands delineations and preparation of wetlands mitigation permits.
As the District Geologist for the Virginia Department of Transportation (1985-1992), my job
duties included obtaining and interpreting geologic data from fieldwork and review of drilling
information in order to provide foundation recommendations for bridge and road construction.
My duties included supervision of the drill crew and design of asphalt and concrete pavements
for highway projects. Accomplishments included preliminary foundation investigations for
interstate bridges and successful cleanup of leaking underground gasoline storage tanks and
site closures at numerous VDOT facilities.

While earning my doctoral degree at the College of William and Mary, I worked as a graduate
assistant on several grant -funded projects. My work duties included measuring tidal current
velocities and tidal fluctuations at tidal inlets; land surveying to determine the geometry and
morphology of numerous tidal inlets; determining pollution susceptibilities of drainage basins
using data from surface water flow parameters, hydrographs, and chemical analyses;
developing a predictive model for shoreline erosion during hurricanes based on calculations of
wave bottom orbital velocities resulting from various wind velocities and directions; performing
sediment size and water quality analyses on samples from the Chesapeake Bay and James
River; conducting multivariate statistical analyses for validation of sediment laboratory quality
control measures; reconnaissance mapping of surficial geologic materials in Virginia, North
Carolina, and Utah for publication of USGS Quaternary geologic maps; teaching Introductory
Geology laboratory classes at the College of William and Mary; and serving as a Sea Grant
intern in the Department of Commerce and Resources, Virginia.
EDUCATION:
College of William and Mary
Williamsburg, VA 23185
Ph.D., 1984
Major: Marine Science (Marine Geology)
Flint Hill Preparatory
Fairfax, VA
High School Diploma, 1968
JOB-RELATED TRAINING COURSES:
College of William and Mary
Williamsburg, VA 23185
B.A., 1972
Major: Geology
2007: Certified Volunteer Stream Monitor, West Virginia (Dept. of Environmental
Protection)
2006: Certified Master Naturalist, West Virginia (Dept. of Natural Resources)
1996: Karst Hydrology, Western Kentucky University
1996: Global Positioning Systems (GPS) for Geographic Information Systems
(GIS) applications, seminar conducted by Duncan-Parnell/Trimble
1995: Safe Drinking Water Teleconference, sponsored by the American Water
Works Association
1992-1998: OSHA Hazardous Waste Site Supervisor training with annual
updates
1990: Credential in Ground Water Science, Ohio State University
JOB-RELATED LICENSE:
PROFESSIONAL ORGANIZATIONS
Licensed Professional Geologist: TN #2529 Geological Society of America
West Virginia Academy of Sciences
National Speleological Society