Category Archives: HDD

Dominion’s Assault on the Blue Ridge


An update from the Pipeline Compliance Surveillance Initiative, Alleghany-Blue Ridge Alliance:

As reported previously, aerial photographs of apparent unauthorized construction work where Dominion Energy proposes to drill through the Blue Ridge Mountains for the Atlantic Coast Pipeline were obtained during recent surveillance flights conducted by the Pipeline Compliance Surveillance Initiative (CSI), a program of the Allegheny-Blue Ridge Alliance (ABRA). Requests for investigation and clarification were submitted to FERC and the Virginia DEQ.

In response to media inquiries concerning “noncompliance with restrictions against earth disturbance and construction prior to receipt of required approvals,” Dominion spokesman, Aaron Ruby, asserted that the company is doing nothing of the sort, and that it is instead doing a geotechnical survey. See Pipeline prep area allegedly being constructed, citizen group files against FERC, News Leader, 3/23/18

CSI Investigator, David Sligh, has responded on behalf of ABRA, objecting to Mr. Ruby’s characterization of the construction activity and noting that over a year ago, when pipeline opponents objected to inadequate geotechnical study of the proposed drilling, Dominion responded by declaring that geotechnical investigation had been “fully accomplished.” See Dominion’s pipeline story doesn’t add up, Letter to News Leader, 3/30/18

The Backstory and a Warning 

Dominion intends to drill 4,639 feet through the Blue Ridge under the George Washington National Forest, Appalachian National Scenic Trail, and Blue Ridge Parkway. Dominion’s plans call for use of horizontal directional drilling (HDD) and contingency use of direct pipe installation (DPI) if the HDD operation fails. Given the topographic and geophysical challenges at the site, the Forest Service initially conditioned any authorization for ACP construction on prior successful completion of the proposed HDD or DPI operations. This condition would have avoided a situation in which significant investment associated with premature ACP construction would be put at risk and in direct conflict with established legal protection of highly valued public resources. Should the HDD and DPI prove impracticable after ACP construction is underway, there will be a strong incentive for allowing an open-cut crossing of the Appalachian Trail and the Blue Ridge Parkway.

The proposed drilling operations will have an extreme environmental footprint, requiring extensive excavation for entry and exit workspace, pipe pullback, fabrication, and testing workspace, as well as siting of heavy equipment for pipe handling, and a network of access roads – all on steep mountainsides with multiple stream crossings. As with other aspects of the ACP, the public and regulatory review agencies have not had access to detailed construction plans. The areas and amount of excavation required for construction have been imprecisely specified at best.

The Dominion Pipeline Monitoring Coalition published a report in early 2017 describing both the risk of failure and the unavoidable environmental damage associated with the plans for drilling through the Blue Ridge. This report described the risk factors confronting both the HDD and contingency DPI operations. Although detailed geophysical investigation of the drill path is standard practice for assessing the feasibility of prospective HDD and DPI operations, the information considered during environmental review was limited in both scope and reliability. No subsurface borings were completed at or near the HDD endpoints and geophysical survey data were obtained for less than 25% of the drill path. See A High-Risk Proposal: Drilling Through the Blue Ridge Mountains for the Atlantic Coast Pipeline

Now, we learn that Dominion Energy is belatedly collecting data that should have been collected and made available during environmental review. 

Dominion Energy knows how to game the system:  defer collection and analysis of essential environmental data until after the review process is concluded and approvals have been obtained. 

Further info:

CSI Incident Report – submitted to DEQ, 3/13/18

Request for Investigation – Submitted to FERC, 3/22/18

CSI Seeks FERC Investigation of Potential ACP Violations

Apparent equipment staging area and new or reconstructed road and bridges observed during Pipeline Air Force surveillance flights. (3/11/18)

On March 14, 2018, we reported on the first incident report from the Compliance Surveillance Initiative (CSI), apparent unauthorized access road and staging area construction in the MP158 area, the Augusta County Horizontal Direction Drilling area. A request was filed March 22 on behalf of Allegheny-Blue Ridge Alliance (ABRA) with the Federal Energy Regulatory Commission (FERC) to investigate potential violations by Atlantic Coast Pipeline (ACP) of the Commission’s Certificate and Virginia’s water quality certification. Aerial photographs taken earlier in March by ABRA’s CSI showed what appears to be substantial construction work in an area of Augusta County, near the site from which ACP proposes to bore through the Blue Ridge Mountains. The photographs show new and improved roads, new bridges, and what appear to be equipment parking and staging areas.

The observed activities do not appear to have been authorized under any of the limited Notices to Proceed FERC has issued, which allow tree cutting by non-mechanized means. The request explains that these actions will impact water quality in a number of ways and that, since the State of Virginia has not approved erosion and sediment control and stormwater plans and its water quality certification is not effective, possible land disturbance, changes to stormwater flows, and other effects must not be allowed. The submittal to FERC also notes that ACP’s weekly status reports have not provided notice of any of these activities and that environmental compliance reports indicate these sites have not been inspected.

The submitters also asked that the Commission report on its investigative proceedings and findings to ABRA, the CSI, and the public and that it not invoke regulatory provisions to keep this information from citizens.

Proposed ACP Construction Schedule


Here is Dominion’s PROPOSED schedule for ACP construction.

Don’t forget that when they sent their original “we want your land” letters in spring 2014, Dominion planned to start construction of the ACP in the Fall of 2016 and have it in service sometime early in 2018. But Dominion did not expect so many people and organizations to fight back! And now, 3.5 years later, construction hasn’t started yet, but Dominion has a proposed construction plan.

According to their October 18, 2017, FERC filing, Dominion hopes to start the horizontal directional drilling (HDD) under the Blue Ridge Parkway at the entrance to Wintergreen on April 2, 2018, with work continuing for 372 days, finishing up on April 9, 2019.

In the rest of the Nelson (and much of Augusta) construction is included in “Spread 5.” Dominion proposes starting with a one-day (yes, one day only!) environmental mitigation training on March 6, 2019. They expect construction to start on March 15, 2019 and anticipate it will take 123 days, ending by September 3, 2019. They then plan 30 days of restoration work between September 4 and October 15, 2019. (Apparently Dominion believes the process of restoring the mountains to their “original contours” should go pretty quickly!)

The planned “commissioning” process would begin before the restoration is complete and is expected to last from August 1 – October 31, 2019.

Dominion’s proposed plan does not specify when tree felling might happen along our part of the route. However tree felling, planned in both 2018 and 2019 in Virginia overall, is slated for September-March in areas where migratory birds are a concern and for November-March in areas where bats are a concern.

They plan to begin construction of the Buckingham compressor station on June 1, 2018, and anticipate finishing on August 16, 2019. Compressor station construction workers will also get a single day of environmental and mitigation training, currently scheduled for May 22, 2018.

Dominion plans call for the rest of the construction in Buckingham (which is part of “Spread 6”) to start on February 18, 2018 and continue through November 5, 2018.

Remember – this is Dominion’s proposed schedule. They never expected to run into so much resistance. And we are STILL fighting. And we have lawyers that are STILL fighting, including filing new legal challenges that could not be filed until after FERC made its decision. There are lots of required permits that STILL have not been issued — including permits that Nelson County has the authority to refuse. The longer and louder we fight, the more people are having to listen. Even long-time FERC Commissioner Cheryl LaFleur voted AGAINST the approval of the ACP. A couple of years ago, such a thing would have been unthinkable.

So, keep making your voices heard! Tell people we won’t pipe down. Tell DEQ and the Water Control Boards not to compromise Virginia’s waterways in service of Dominion’s profits. And make sure you let your elected (and to-be-elected) representatives — especially the local ones — know that you expect them to support us in fighting to keep the ACP off our lands.

Just Compensation from ACP for Wintergreen Property Owners


As a Wintergreen property owner, you may be entitled by law to receive “just compensation” for any decrease in your Wintergreen property value caused by Dominion’s Atlantic Coast Pipeline (ACP).

Dominion plans to take a 4+ acre easement from the Wintergreen common area near the front gate to construct a 42-inch wide natural gas pipeline. With FERC approval, Dominion can condemn the property for the ACP project.

Dominion will use more than 4 acres of Wintergreen common area and other private property rights to drill a 4,000-foot tunnel under the mountain that supports the Blue Ridge Parkway. The drilling operation will be performed 24/7 for up to 18 months on Wintergreen common area property immediately in front of the Mountain Resort’s only entrance and exit. Construction will require the removal of thousands of trees and will further require importing 6 million gallons of water from the James River for drilling. From the drilling site in front of the Wintergreen gatehouse, the pipeline would continue up Piney Mountain, also Wintergreen property, cross through Fortune’s Point next to Fortune’s Ridge, then continue east to Nellysford and beyond. Dominion plans to utilize Wintergreen roads for access and construction purposes.

By taking Wintergreen common area owned by the Wintergreen Property Owners Association (WPOA), the ACP will take and damage each owner’s easement of use and enjoyment in those same common areas during and after construction, caused by construction and operation of a natural gas pipeline, reduction in WPOA and resort services, marketplace stigma for safety concerns and other reasons that cause a loss in property values. This issue applies to all WPOA members. Each member is entitled to “damages,” which are calculated individually as the unique decrease in value to each owner’s property rights affected by the pipeline project. Local realtors have already seen a drop of 10 percent or more in Wintergreen property values since the pipeline was announced. What does this decline mean for your property? Will it get worse?

If you are a Wintergreen property owner, more information is here.
http://www.friendsofwintergreen.com/lawsuit/

Drilling Mud Is Apparently Difficult to Control

Sunoco is currently building the Mariner East 2 pipeline through Chester County PA. On July 7, 2017, NPR reported that “Around a dozen Chester County households experienced cloudy water or loss of supply from their private wells this week, forcing some families from their homes near a location where Sunoco Pipeline is conducting horizontal directional drilling about 150 feet below ground for the construction of its Mariner East 2 pipeline.” Some families are now staying at local hotels.

The NPR report continues, “Sunoco spokesman Jeff Shields said the company is investigating the cause of the water problems in West Whiteland Township, which were first reported to the Township on Monday. The company is now a subsidiary of Energy Transfer Partners. The company has tested 11 private water wells, and was due to test another nine on Friday to determine whether its horizontal directional drilling (HDD) caused the water problems, Shields said. Although test results had not been given to West Whiteland Township officials by late morning, Shields indicated that HDD was the cause.”

Note that EDP is the company that spilled more than 2 million gallons of drilling fluid in Ohio, causing FERC to curtail work on the Rover pipeline in northern Ohio (see our story on May 11, 2017).

Later in the day on July 7, the Philadelphia Inquirer posted an update, Water-contamination complaints force Sunoco to suspend Chesco pipeline construction. “Sunoco Pipeline LP has suspended installation of its contentious Mariner East 2 underground pipeline near Exton after about a dozen Chester County households complained that the water from their private wells was interrupted or had become cloudy…. ‘Drilling has been suspended as we await test results, which will help determine whether the well problems are related to drilling and, if so, help us resolve the issues,’ Shields said…. Local officials suspect that nontoxic bentonite clay used as a lubricant during the horizontal-drilling process may have migrated into private wells. Bentonite drilling mud is the same material used in cat litter.”

Horizontal directional drilling, using the same bentonite drilling mud, is the process Dominion proposes for drilling under the Blue Ridge at Reed’s Gap.

FERC Blocks Rover Pipeline after Spills During HDD


On May 10, 2017, the Washington Post reported that FERC has curtailed work on the Rover pipeline in northern Ohio after Energy Transfer Partners (ETP) reported 18 leaks and the spilling of more than 2 million gallons of drilling fluid. No new horizontal directional drilling (HDD) may begin in 8 areas where drilling was planned, and the company was told to “double the number of environmental inspectors and to preserve documents the commission wants to examine as it investigates the spills.” ETP maintains that the spills, which they say are of non-toxic drilling mud, had been predicted in their permit application, but FERC said its staff has “serious concerns” regarding the magnitude of the largest spill, “its environmental impacts, the lack of clarity regarding the underlying reasons for its occurrence, and the possibility of future problems,” and that the spill was “several orders of magnitude greater than other documented inadvertent returns for the project.”

Drilling mud a foot or two deep is visible in a video of the wetlands area provided by the Ohio Environmental Protection Agency.

Horizontal directional drilling is the process Dominion proposes for drilling under the Blue Ridge at Reed’s Gap.