st. charles transportation and keys energy projects · filing environmental comments will not give...

Docket Nos.

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June 2015

Dominion Cove Point LNG, LP Docket No. CP15-22-000 Docket No. CP15-24-000

St. Charles Transportation and

Keys Energy Projects

Environmental Assessment

Washington, DC 20426

Office of Energy Projects

20150619-4008 FERC PDF (Unofficial) 06/19/2015

FEDERAL ENERGY REGULATORY COMMISSION WASHINGTON, D.C. 20426

OFFICE OF ENERGY PROJECTS

In Reply Refer To: OEP/DG2E/Gas 2 Dominion Cove Point LNG, LP Docket Nos. CP15-22-000 and CP15-24-000

TO THE PARTY ADDRESSED:

The staff of the Federal Energy Regulatory Commission (FERC or Commission) has prepared this environmental assessment (EA) for the St. Charles Transportation and Keys Energy Projects proposed by Dominion Cove Point LNG, LP (Dominion) in the above-referenced dockets. Dominion requests authorization to construct, install, own, operate, and maintain natural gas facilities in Virginia and Maryland to provide 132,000 and 107,000 dekatherms per day of firm natural gas transportation service, respectively. Because both projects are connected actions, we analyzed them jointly in one EA.

The EA assesses the potential environmental effects of the construction and operation of these projects in accordance with the requirements of the National Environmental Policy Act. The FERC staff concludes that approval of the proposed projects, with appropriate mitigating measures, would not constitute a major federal action significantly affecting the quality of the human environment.

Dominion’s St. Charles Transportation Project involves construction of a new 7,000 horsepower (hp) compressor; replacement of an existing filter-separator with one new filter-separator; installation of a new gas cooler; and installation of measurement upgrades, meter runs, and piping, fittings, and valves at its existing Pleasant Valley Compressor Station in Fairfax County, Virginia. The St. Charles Transportation Project would also involve construction and operation of two new 16-inch delivery taps on Dominion’s TL-522 and TL-532 pipelines to enable customer delivery in Charles County, Maryland. Dominion’s Keys Energy Project would involve installation of one new 6,000 hp compressor; installation of one new gas cooler; and rearrangement of interconnecting pipe to and from supply/discharge headers at its existing Pleasant Valley Compressor Station. The Keys Energy Project would also involve construction and operation of two new 16-inch delivery taps; construction of a new metering and regulating station; and construction of a dekatherm building in Charles County, Maryland.

The FERC staff mailed copies of the EA to federal, state, and local government representatives and agencies; elected officials; environmental and public


Docket Nos. CP15-22-000 and CP15-24-000

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interest groups; Native American tribes; potentially affected landowners within 0.5 mile of the above ground facilities; and other interested individuals and groups; newspapers and libraries in the project areas; and parties to this proceeding. Everyone on our environmental mailing list will receive a CD version of the EA. In addition, the EA is available for public viewing on the FERC’s website (www.ferc.gov) using the eLibrary link. A limited number of copies of the EA are available for distribution and public inspection at:

Federal Energy Regulatory Commission Public Reference Room

888 First Street NE, Room 2A Washington, DC 20426

(202) 502-8371 Any person wishing to comment on the EA may do so. Your comments should

focus on the potential environmental effects, reasonable alternatives, and measures to avoid or lessen environmental impacts. The more specific your comments, the more useful they will be. To ensure that the Commission has the opportunity to consider your comments prior to making its decision on this project, it is important that we receive your comments in Washington, DC on or before July 20, 2015.

For your convenience, there are three methods you can use to file your comments with the Commission. In all instances please reference the project docket numbers (CP15-22-000 and CP15-24-000) with your submission. The Commission encourages electronic filing of comments and has expert staff available to assist you at 202-502-8258 or [email protected].

(1) You can file your comments electronically using the eComment feature located on the Commission's website (www.ferc.gov) under the link to Documents and Filings. This is an easy method for submitting brief, text-only comments on a project;

(2) You can also file your comments electronically using the eFiling feature on

the Commission's website (www.ferc.gov) under the link to Documents and Filings. With eFiling, you can provide comments in a variety of formats by attaching them as a file with your submission. New eFiling users must first create an account by clicking on “eRegister.” You must select the type of filing you are making. If you are filing a comment on a particular project, please select “Comment on a Filing”; or


Docket Nos. CP15-22-000 and CP15-24-000

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(3) You can file a paper copy of your comments by mailing them to the following address:

Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street NE, Room 1A Washington, DC 20426

Any person seeking to become a party to the proceeding must file a motion to intervene pursuant to Rule 214 of the Commission's Rules of Practice and Procedures (18 CFR 385.214).1 Only intervenors have the right to seek rehearing of the Commission's decision. The Commission grants affected landowners and others with environmental concerns intervenor status upon showing good cause by stating that they have a clear and direct interest in this proceeding which no other party can adequately represent. Simply filing environmental comments will not give you intervenor status, but you do not need intervenor status to have your comments considered.

Additional information about the project is available from the Commission's Office

of External Affairs, at (866) 208-FERC, or on the FERC website (www.ferc.gov) using the eLibrary link. Click on the eLibrary link, click on “General Search,” and enter the docket numbers excluding the last three digits in the Docket Number field (i.e., CP15-22-000 and CP15-24-000). Be sure you have selected an appropriate date range. For assistance, please contact FERC Online Support at [email protected] or toll free at (866) 208-3676, or for TTY, contact (202) 502-8659. The eLibrary link also provides access to the texts of formal documents issued by the Commission, such as orders, notices, and rulemakings.

In addition, the Commission offers a free service called eSubscription which allows you to keep track of all formal issuances and submittals in specific dockets. This can reduce the amount of time you spend researching proceedings by automatically providing you with notification of these filings, document summaries, and direct links to the documents. Go to www.ferc.gov/docs-filing/esubscription.asp.

1 See the previous discussion on the methods for filing comments.


TABLE OF CONTENTS A. PROPOSED ACTION ............................................................................................................. 1

1.0 INTRODUCTION ............................................................................................................. 1 2.0 PURPOSE AND NEED .................................................................................................... 1 3.0 PROPOSED FACILITIES ............................................................................................... 2 4.0 NONJURISDICTIONAL FACILITIES ......................................................................... 3

4.1 Expansion of NOVEC Substation ................................................................................ 3 4.2 St. Charles Project M&R Station ................................................................................. 4 4.3 St. Charles Project M&R Station Access Road .......................................................... 4 4.4 St. Charles Project Generating Station ....................................................................... 4 4.5 St. Charles Project Lateral Pipeline ............................................................................ 5 4.6 Keys Energy Center Generating Station and Lateral Pipeline ................................. 5

5.0 PUBLIC REVIEW AND COMMENT ............................................................................ 5 6.0 PERMITS, APPROVALS, AND REGULATORY CONSULTATIONS .................... 7 7.0 CONSTRUCTION, OPERATION, AND MAINTENANCE ...................................... 10 8.0 LAND REQUIREMENTS .............................................................................................. 11

B. ENVIRONMENTAL ANALYSIS ........................................................................................ 12 1.0 GEOLOGY ...................................................................................................................... 12

1.1 Earthquakes ................................................................................................................. 13 1.2 Landslides ..................................................................................................................... 13

2.0 SOILS ............................................................................................................................... 13 3.0 WATER RESOURCES .................................................................................................. 14

3.1 Groundwater Resources .............................................................................................. 14 3.2 Surface Water .............................................................................................................. 15 3.3 Hydrostatic Testing ..................................................................................................... 15 3.4 Wetlands ....................................................................................................................... 15

4.0 VEGETATION, WILDLIFE, AND THREATENED AND ENDANGERED SPECIES ...................................................................................................................................... 17

4.1 Vegetation ..................................................................................................................... 17 4.2 Wildlife ......................................................................................................................... 18 4.3 Migratory Birds ........................................................................................................... 19 4.4 Special Status, Threatened, and Endangered Species .............................................. 20

5.0 CULTURAL RESOURCES ........................................................................................... 21 5.1 Consultations ................................................................................................................ 21 5.2 State Historic Preservation Officers .......................................................................... 21 5.3 Federally Recognized Indian Tribes .......................................................................... 21 5.4 Other Parties ................................................................................................................ 22 5.5 Survey Results .............................................................................................................. 22 5.6 Unanticipated Discovery Plan .................................................................................... 22 5.7 Compliance with the National Historic Preservation Act ........................................ 22

6.0 LAND USE, RECREATION, AND VISUAL RESOURCES ..................................... 23 6.1 Land Use ....................................................................................................................... 23 6.2 Recreation ..................................................................................................................... 24 6.3 Visual Resources .......................................................................................................... 25 6.4 Coastal Zone Management Areas .............................................................................. 25


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7.0 AIR QUALITY AND NOISE ......................................................................................... 26 7.1 Air Quality .................................................................................................................... 26 7.2 Noise .............................................................................................................................. 30

8.0 RELIABILITY AND SAFETY ...................................................................................... 35 C. CUMULATIVE IMPACTS .................................................................................................. 36

1.0 PLEASANT VALLEY COMPRESSOR STATION .................................................... 37 2.0 CPV MARYLAND INTERCONNECT ........................................................................ 37 3.0 KEYS ENERGY INTERCONNECT ............................................................................ 38 4.0 CUMULATIVE IMPACT ANALYSIS ......................................................................... 38

D. ALTERNATIVES .................................................................................................................. 44 1.0 INTRODUCTION ........................................................................................................... 44 2.0 NO ACTION ALTERNATIVE ...................................................................................... 44 3.0 SYSTEM ALTERNATIVES .......................................................................................... 44

3.1 Existing Systems .......................................................................................................... 45 3.2 Modified Systems ......................................................................................................... 45 3.3 Compressor Station Site Alternatives ........................................................................ 46

E. CONCLUSIONS AND RECOMENDATIONS .................................................................. 47 F. REFERENCES ....................................................................................................................... 51 G. LIST OF PREPARERS ......................................................................................................... 52 Appendix .......................................................................................................................................... 53 LIST OF TABLES Table 1 Permits, Approvals, and Consultations Applicable to the Projects Table 2 Acreage Affected by Construction and Operation of the Proposed Facilities Table 3 Estimated Operation Emissions (tons per year) Table 4 Estimated Construction Emissions (tons) Table 5 Estimated Sound Levels

APPENDICES Figure 1 St. Charles Transportation Project General Location Map Figure 2 Keys Energy Project General Location Map Figure 3 Pleasant Valley Compressor Station Project Area Figure 4 CPV Maryland Interconnect Project Area Figure 5 Keys Interconnect Project Area Figure 6 Wetland Delineation Map of Pleasant Valley Compressor Station


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ABBREVIATIONS AND ACRONYMS ACHP Advisory Council on Historic Preservation AQCR Air Quality Control Region ADP Allegheny Defense Project APE area of potential effects BMPs Best management practices CAA Clean Air Act of 1970 Certificate Certificate of Public Convenience and Necessity CAA Clean Air Act CEQ Council on Environmental Quality CFR Code of Federal Regulations CO carbon monoxide CO2 carbon dioxide CO2e carbon dioxide equivalents Commission Federal Energy Regulatory Commission CPV Competitive Power Ventures dB decibel dBA A-weighted decibel Dominion Dominion Cove Point LNG, LP DOT U.S. Department of Transportation EIA U.S. Energy Information Administration EA environmental assessment EI environmental inspector EIS environmental impact statement EPA U.S. Environmental Protection Agency E&SC Plan Erosion and Sediment Control Plan FERC Federal Energy Regulatory Commission FIDS Forest Interior Dwelling Species FWS U.S. Fish and Wildlife Service GHG greenhouse gas GWP global warming potential HAP hazardous air pollutants hp horsepower Leq equivalent sound level Ldn day-night sound level MDE Maryland Department of the Environment MDNR Maryland Department of Natural Resources MHT Maryland Historic Trust MNHP Maryland Natural Heritage Program PSC Maryland Public Service Commission MACT Maximum Achievable Control Technology MAOP maximum allowable operating pressure MW megawatt


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MBTA Migratory Bird Treaty Act M&R metering and regulating N2O nitrous oxide NAAQS National Ambient Air Quality Standards NEPA National Environmental Policy Act of 1969 NESHAP National Emissions Standards for Hazardous Air Pollutants NRCS U.S. Department of Agriculture National Resources Conservation Service NGA Natural Gas Act NO2 nitrogen dioxide NOx nitrogen oxides N2O nitrous oxide NSA Noise Sensitive Area

NOI Notice of Intent to Prepare an Environmental Assessment for the Proposed St. Charles Transportation and Keys Energy Projects, and Request for Comments on Environmental Issues

NOVEC Northern Virginia Electric Cooperative NRHP National Register of Historic Places Nos. numbers OEP Office of Energy Projects OTR Ozone Transport Region PEM palustrine emergent Pipeline Natural gas pipeline Plan Upland Erosion Control, Revegetation, and Maintenance Plan

PM2.5 particulate matter with an aerodynamic diameter less than or equal to 2.5 microns

PM10 particulate matter with an aerodynamic diameter less than or equal to 10 microns

Procedures Wetland and Waterbody Construction and Mitigation Procedures Secretary Secretary of the Commission SHPO State Historic Preservation Office SIP State Implementation Plan SWM stormwater management SO2 sulfur dioxide SPCC Plans Spill Prevention Containment and Countermeasure Plans tpy tons per year Transco Transcontinental Gas Pipeline Company UDP unanticipated discovery plans USACE United States Army Corps of Engineers USGS United State Geological Survey VCACS Virginia Department of Agriculture and Consumer Services VDCR Virginia Department of Conservation and Recreation VDEQ Virginia Department of Environmental Quality VDGIF Virginia Department of Game and Inland Fisheries VDHR Virginia Department of Historic Resources


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VOC volatile organic compound WUS Waters of the United States


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A. PROPOSED ACTION

1.0 INTRODUCTION

The staff of the Federal Energy Regulatory Commission (Commission or FERC) has prepared this environmental assessment (EA) to assess the environmental effects of the natural gas pipeline facilities proposed by Dominion. We1 prepared this EA in compliance with the requirements of the National Environmental Policy Act of 1969 (NEPA, Title 40 of the Code of Federal Regulations, Parts 1500-1508 [40 CFR 1500-1508]), and with the Commission’s implementing regulations under 18 CFR 380.

On December 3, 2014, Dominion filed applications with the Commission in Docket Nos. CP15-22-000 for the St. Charles Transportation Project and CP15-24-000 for the Keys Energy Project under section 7(c) of the Natural Gas Act (NGA) and part 157 of the Commission's regulations. Dominion seeks to construct and operate certain natural gas facilities in Maryland and Virginia. The St. Charles Transportation Project would deliver up to 132,000 dekatherms per day of firm natural gas transportation service to the proposed “St. Charles Energy Center” in Charles County, Maryland. The Keys Energy Project would deliver up to 107,000 dekatherms per day of firm natural gas transportation service to the proposed “Keys Energy Center” in Prince George’s County, Maryland. Because the Projects include new facilities at a common compressor station, we analyzed them jointly in one EA.

The EA is an important and integral part of the Commission's decision on whether to issue Dominion a Certificate of Public Convenience and Necessity (Certificate) to construct and operate the proposed facilities. Our principal purposes in preparing this EA are to:

identify and assess potential impacts on the natural and human environment that could result from implementation of the proposed action;

identify and recommend reasonable alternatives and specific mitigation measures, as necessary, to avoid or minimize project-related environmental impact; and

facilitate public involvement in the environmental review process.

2.0 PURPOSE AND NEED

The purpose of the St. Charles Transportation and Keys Energy Projects (Projects) is, at the request of the customer (Competitive Power Ventures [CPV] Maryland, LLC and Keys Energy Center, LLC [Keys Energy], respectively) to provide incremental firm transportation to proposed power plants in Charles and Prince George’s Counties, Maryland, respectively. Dominion states that the new facilities would efficiently generate electricity to more than 1.2 million homes in the respective regions. Currently, Dominion owns the Cove Point Liquefied Natural Gas (LNG) Terminal, 88-mile gas pipeline system (Cove Point Pipeline) connecting the Terminal to the Interstate pipeline grid, and two compressor stations – the Pleasant Valley Compressor Station in

1 “We,” “us,” and “our” refers to environmental staff of the Office of Energy Projects.


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Fairfax County, Virginia and the Loudoun Compressor Station located in Loudoun County, Virginia. The proposed actions would allow Dominion to provide incremental pipeline capacity for the new power plants (St. Charles Energy Center and Keys Energy Center).

Under Section 7 of the NGA, the Commission determines whether interstate natural gas transportation facilities are in the public convenience and necessity and, if so, grants a Certificate to construct and operate them. The Commission bases its decisions on technical competence, financing, rates, market demand, gas supply, environmental impact, long-term feasibility, and other issues concerning a proposed project.

3.0 PROPOSED FACILITIES

The Projects would involve the installation of new facilities and modification of existing facilities. A general location map for the St. Charles Transportation Project, figure 1, is located in the appendix. Dominion’s proposed St. Charles Transportation Project would consist of the following:

Pleasant Valley Compressor Station (Fairfax County, Virginia)

o Install one new 7,000 horsepower (hp) electric compressor at the existing compressor station;

o extend the existing compressor building;.

o replace the existing filter-separator with one new filter-separator;

o add one new gas cooler; and

o install miscellaneous piping and measurement upgrades, meter runs, fittings, and valves.

Competitive Power Ventures (CPV) Maryland Interconnect (Charles County, Maryland)

o Install two new 16-inch taps (one on Dominion’s existing TL-522 pipeline (TL-522) and one on Dominion’s existing TL-532 pipeline (TL-532)) for customer delivery.

A general location map for the Keys Energy Project, figure 2, is located in the appendix. Dominion’s proposed Keys Energy Project would consist of the following:

Pleasant Valley Compressor Station (Fairfax County, Virginia)

o Install one new 6,000 hp electric compressor and one new gas cooler at the existing compressor station; and

o add necessary interconnecting pipe work to and from supply/discharge headers.

Keys Energy Interconnect (Charles County, Maryland)

o Install two new 16-inch taps (one on TL-522 and one on TL-532) for customer delivery;


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o construct one metering and regulating (M&R) station that would feed gas from the new taps to the Keys Energy lateral line2; and

o construct one building that would house electronic flow control equipment.

4.0 NONJURISDICTIONAL FACILITIES

Nonjurisdictional facilities are those facilities that are related to the Projects for the purpose of delivering, receiving, or using the proposed natural gas volumes, and include facilities to be built and owned by other companies, that are not subject to the FERC jurisdiction. Nonjurisdictional facilities may include laterals or other pipeline-related facilities that may be constructed to allow Project interconnections for the receipt or delivery of the Projects natural gas volumes or electric distribution systems that may be constructed to provide electricity or other services to the Projects’ facilities. Nonjurisdictional facilities associated with the Projects are:

expansion of the Northern Virginia Electric Cooperative (NOVEC) substation at the Pleasant Valley Compressor Station in Fairfax County, Virginia (see figure 3 in appendix);

construction of an M&R Station by CPV Maryland adjacent to the CPV Maryland Interconnect in Charles County, Maryland (see figure 4 in appendix);

construction of an access road by CPV Maryland to the M&R Station from Piney Church Road in Charles County, Maryland;

construction of the St. Charles Energy Center generating station by CPV Maryland approximately one mile from the Cove Point pipeline in Charles County, Maryland;

construction of a 1.1-mile lateral pipeline by CPV Maryland from the M&R Station to the generating station in Charles County, Maryland; and

construction of Keys Energy Center generating station in Prince George’s County, Maryland and one 8-mile-long lateral pipeline from the generating station to the M&R station at the Keys Energy Interconnect in Charles County, Maryland (see figure 5 in appendix).

4.1 Expansion of NOVEC Substation

The existing NOVEC substation at the Pleasant Valley Compressor Station would be expanded to support the proposed additional compression. The area of substation expansion is approximately 0.9 acre. The expansion of the substation at the Pleasant Valley Compressor Station would be constructed, owned, and operated by NOVEC. The permits required for the construction of the expansion of the substation at the Pleasant Valley Compressor Station include an electrical permit, a grading permit, and site plan approval at the local and state level. Construction of the expansion of the substation at the Pleasant Valley Compressor Station is expected to overlap in time with the construction of the additional compression at the Pleasant Valley Compressor Station.

2 The lateral line would be constructed, owned, and operated by Keys Energy. The M&R

will be owned and operated by Dominion.


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4.2 St. Charles Project M&R Station

CPV Maryland is planning to construct an M&R Station adjacent to the CPV Maryland Interconnect. The M&R Station would be located on a 3.6-acre parcel of land owned by CPV Maryland. The M&R Station would be constructed and owned by CPV Maryland but operated by Dominion. CPV Maryland is responsible for obtaining all the necessary permits and approvals for the M&R Station, which are obtained at the local and state level. Construction of the M&R Station would be completed prior to the construction of the taps at the CPV Maryland Interconnect.

4.3 St. Charles Project M&R Station Access Road

CPV Maryland is planning to construct an access road to the M&R Station from Piney Church Road. The access road would be 12-feet-wide and a portion of the road to the M&R Station would be asphalt, while the portion that wraps around the M&R Station toward the CPV Maryland Interconnect would be gravel. Dominion would use the road constructed by CPV Maryland to access the CPV Maryland Interconnect. Construction of the access road would be completed prior to the construction of the taps at the CPV Maryland Interconnect and the M&R Station, and would require a road permit at the local level.

4.4 St. Charles Project Generating Station

CPV Maryland is constructing a 725-megawatt (MW) combined cycle natural gas-fired generating station, the St. Charles Energy Center, in Charles County, Maryland approximately one mile from the Cove Point Pipeline. The generating station will be located approximately 4 miles south of the center of Waldorf and 2.5 miles south of the center of the community of St. Charles on a portion of a pre-existing 76-acre industrial site (Piney Reach Park). The new facility will provide electric power to the Maryland power grid. Construction of the generating station began in December 2014.

CPV Maryland obtained a Certificate of Public Convenience and Necessity from the Maryland Public Service Commission (PSC). As part of this licensing process, applicants must address a full range of environmental, engineering, socioeconomic, planning, and cost issues. The Power Plant Siting Act of 1971, augmented by the Electric Utility Industry Restructuring Act of 1999, provides for a consolidated review of Certificate of Public Convenience and Necessity applications in Maryland. The Power Plant Research Program is responsible for managing that review and bringing to the PSC a consolidated set of licensing recommendations.

The Maryland PSC and Power Plant Research Program processes within the state regulatory framework allowed a comprehensive review of the St. Charles Energy Center and related lateral pipeline. During its review, the Maryland agencies evaluated potential impacts of the facility on environmental resources, including air, surface and ground water, terrestrial resources, and cultural and historic resources, including assessing overall site suitability. Because this has been reviewed and approved appropriately at the state level, these facilities are not subject to FERC’s review


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4.5 St. Charles Project Lateral Pipeline

CPV Maryland is authorized to construct a 1.1-mile-long lateral pipeline from the M&R Station adjacent to the CPV Maryland Interconnect to its new St. Charles generating station. Construction of the lateral pipeline is to begin in the summer of 2015. CPV Maryland is in the process of obtaining all necessary federal, state, and local permits for the facilities described above.

4.6 Keys Energy Center Generating Station and Lateral Pipeline

Keys Energy is planning to construct a 735 MW combined cycle natural gas-fired generating station, the Keys Energy Center, in Prince George’s County, Maryland, approximately 8 miles from the Keys Energy Interconnect. The generating station has not yet been would be located approximately 1.25 miles east of Brandywine on a 170-acre site (formerly used for a sand and gravel mining operation). The new facility would provide power to the Maryland power grid. Construction of the generating station is expected to begin during the last quarter of 2015.

Keys Energy is also planning to construct an 8-mile-long lateral pipeline from the M&R station at the Keys Energy Interconnect to the Keys Energy Center generating station. Construction of the lateral pipeline is expected to begin construction during late summer and continue through December 2015. Keys Energy would construct, own, operate, and maintain the lateral pipeline. Both the Keys Energy Center generating station and the lateral pipeline are subject to the same Maryland authorizations and permitting requirements identified above for the St. Charles generating station facilities.

In November 27, 2013, FERC issued an Order that determined that the Keys Energy lateral pipeline is nonjurisdictional (FERC Filing No. 20131127-3027 under Docket No. CP13-522). Keys Energy is in the process of obtaining all other necessary federal, state, and local permits.

We received a comment that all related projects should be considered in the same environmental document. The nonjurisdictional facilities described above were considered by the Commission staff in the cumulative impacts section of this EA (see section C).

5.0 PUBLIC REVIEW AND COMMENT

On January 5, 2015, the Commission issued a Notice of Intent to Prepare an Environmental Assessment for the Proposed St. Charles Transportation and Keys Energy Projects and Request for Comments on Environmental Issues (NOI). The NOI was mailed to federal, state, and local government representatives and agencies; elected officials; Native American tribes; environmental and public interest groups; newspapers and libraries in the project area; and parties to this proceeding. We also notified potentially affected landowners about the project on April 27, 2015. We received two comments in response to the NOI. The Allegheny Defense Project (ADP) expressed concern about segmentation and the need for a programmatic environmental impact statement (EIS); the need to prepare an environmental impact statement (EIS) in lieu of an EA; extraction of Marcellus shale natural gas; and the necessity to address the nonjurisdictional facilities associated with the Projects in the same environmental document.

The Virginia Department of Environmental Quality (VDEQ) stated a concern that although no state-listed plants, insects, or State Natural Area Preserves would be impacted by the proposed


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Projects, the Elklick Woodlands State Natural Area Preserve is located approximately 500 feet southeast of the existing Pleasant Valley Compressor Station where additional compression is proposed. VDEQ also pointed out that the projects are within 2 miles of a documented occurrence of the wood turtle (Glyptemys insculpta), a Virginia state-listed animal, and Cub Run, a “Threatened and Endangered Species Water” designated by the Virginia Department of Game and Inland Fisheries (VDGIF). VDEQ comments are addressed in section B of this EA.

ADP requested that an EIS, rather than an EA, be prepared to assess the impact of the Projects. The Commission’s regulations under 18 CFR 306(b) state that “If the Commission believes that a proposed action…may not be a major federal action significantly affecting the quality of the human environment, an EA, rather than an EIS, will be prepared first. Depending on the outcome of the EA, an EIS may or may not be prepared.” In preparing this EA, we are fulfilling our obligation under NEPA to consider and disclose the environmental impacts of the Projects. As noted above, this EA addresses the impacts that could occur on a wide range of resources should the Projects be approved and constructed. Based on our analysis, the extent and content of comments received during the scoping period, and considering that the project facilities would be largely collocated with existing facilities, we conclude in section E that the impacts associated with these Projects can be sufficiently mitigated to support a finding of no significant impact and, thus, an EA is warranted.

Regarding ADP’s allegations of improper segmentation and that a programmatic EIS that considers the cumulative impacts of all FERC projects be prepared, the Council of Environmental Quality (CEQ) regulations state that major federal actions for which an EIS may be required include “programs, such as a group of concerted actions to implement a specific policy or plan; systematic and connected agency decisions allocating agency resources to implement a specific program…” The Projects proposed by Dominion in its applications for a Certificate are not part of any such program do not meet this definition for broad proposals. Other natural gas infrastructure and gas development in the Marcellus and Utica shale region are unknown until the time that an application is filed with FERC. Thus, there is no requirement for preparation of a programmatic EIS.

Regarding ADP’s suggestion that the environmental document should address the indirect impacts of “development activities in the Marcellus and Utica shale formations” (induced shale development), there is not a sufficient causal link between the proposed project and additional development of shale resources to warrant analysis of such development as an impact of the proposed Projects. In addition, impacts that may result from additional shale gas development are not “reasonable foreseeable” as defined by the CEQ regulations. The ongoing development of the Marcellus shale, which is regulated by the states, continues to drive demand for takeaway interstate pipeline transmission facilities. Many production facilities have already been permitted and/or constructed in the region, creating a network through which natural gas may flow along various pathways to local users or the interstate pipeline system, including Dominion’s system. However, we can only speculate about the specific details, including the timing, location, and number of additional production wells that may or may not be drilled. Dominion would receive any additional production through its interconnection with other natural gas pipelines. These interconnecting pipeline systems span multiple states with shale, as well as conventional, gas formations. We cannot estimate how much of the Projects volumes would come from current/existing shale gas production and how much, if any, would be new production “attributable” to the Projects.


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6.0 PERMITS, APPROVALS, AND REGULATORY CONSULTATIONS

Dominion would obtain all necessary permits, licenses, clearances, and approvals related to construction and operation of the St. Charles Transportation and Keys Energy Projects, respectively. The company would provide all relevant permits and approvals to the contractor, who would be required to adhere to applicable requirements. Table 1 displays the major anticipated federal and state permits for Dominion’s Projects.

Table 1 Permits, Approvals, and Consultations Applicable to the Projects

Permitting/Approval Agency

Permit, Approval, or Consultation

Actual or Anticipated Filing Date

Actual or Anticipated Receipt Date

Federal Federal Energy Regulatory Commission

Certificate of Public Convenience and Necessity

December 3, 2014 Requested July 2015

Army Corps of Engineers (Maryland)

Section 404/Section 10 Permit

Provided additional information as follow-up to call with Maryland Department of the Environment March 2, 2015 (only for St. Charles Transportation)

Estimated late July/early August 2015

U.S. Fish & Wildlife Service (Maryland)

Endangered Species Act, Section 7 Consultation; Fish and Wildlife Coordination Act Consultation; Migratory Bird Treaty Act Consultation; Bald and Golden Eagle Protection Act Consultation

November 2014 April 30, 2015 (online project review process submitted with consultation package is response; no additional comments)

U.S. Fish & Wildlife Service (Virginia)

Endangered Species Act, Section 7 Consultation; Fish and Wildlife Coordination Act Consultation; Migratory Bird Treaty Act Consultation; Bald and Golden Eagle Protection Act Consultation

November 14, 2014 December 24, 2014 provided “no comment” email

State - Virginia Virginia Department of Environmental Quality

Coastal Zone Management Consistency Certification

Response to clarification request February 13, 2015 for St. Charles Transportation Project, December 10, 2014 for Keys Energy Project

Request for clarification February 13, 2015 for St. Charles Tranportation, November 21, 2014 for Keys Energy Project. Anticipated Spring 2015


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Virginia Department of Game and Inland Fisheries

Fish and Wildlife Coordination Act Review

November 14, 2014 Estimated Spring 2015

Virginia Department of Conservation and Recreation

Fish and Wildlife Coordination Act

November 19, 2014 Estimated Spring 2015

Virginia Department of Agriculture and Consumer Services

Fish and Wildlife Coordination Act

November 14, 2014 December 8, 2014

Virginia Department of Historic Resources

National Historic Preservation Act, Section 106 Consultation

November 14, 2014 December 17, 2014

State – Maryland Maryland Department of the Environment

401 Water Quality Certification

December 1, 2014 Provided additional information as follow-up to call with Maryland Department of the Environment (MDE) March 2, 2015

Estimated May - August 2015

Maryland Department of the Environment

Nontidal Wetlands Permit

December 1, 2014 Provided additional information as follow-up to call with MDE March 2, 2015



Waterways Construction Permit

December 1, 2014 Provided additional information as follow-up to call with MDE March 2, 2015



Permit for Stormwater Discharge Associated with Construction Activities

Estimated Spring 2015 Estimated June - July 2015


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Coastal Zone Management Consistency Certification

December 1, 2015 Provided additional information as follow-up to call with March 2, 2015

Estimated late July/early August 2015

Maryland Department of Natural Resources

Maryland Natural Heritage Program Consultation

November 14, 2014

March 31, 2015 email concurring that the Maryland Department of Natural Resources (MDNR) has no further concerns

Maryland Historical Trust

National Historic Preservation Act, Section 106 Consultation

November 14, 2014 Consultation complete December 3, 2014

County - Fairfax Fairfax County Department of Public Works and Environmental Services

Site, Stormwater Management Agreement, Erosion and Sediment Control, and Grading Plan Approval, Land Disturbance Permit, and Stormwater Management Agreement

Estimated Spring 2015 Estimated August - September 2015

County – Charles County Charles County Planning Commission

Site Plan Approval Estimated Spring 2015 Estimated June - July 2015

Charles County Department of Planning and Growth Management

Stormwater Management Plan Approval



Erosion and Sediment Control Plan Approval



Grading Plan Approval



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Development Services Permit


7.0 CONSTRUCTION, OPERATION, AND MAINTENANCE

Dominion would construct, operate, and maintain the proposed Projects in compliance with all applicable federal and state permit requirements, regulations, and environmental guidelines. The key relevant federal regulations are those of the U.S. Department of Transportation (DOT) under 49 CFR 192 - Transportation of Natural and Other Gas by Pipeline: Minimum Federal Safety Standards. These regulations ensure adequate protection for the public and prevent natural gas facility accidents and failures.

Dominion anticipates that construction of the St. Charles Transportation Project would begin in September 2015 with an in-service date of June 1, 2016. Dominion plans to begin construction of the Keys Energy Project in January 2016, with an in-service date of March 1, 2017. Dominion adopted FERC staff’s Upland Erosion Control, Revegetation, and Maintenance Plan (Plan), and Wetland and Waterbody Construction and Mitigation Procedures (Procedures) with minor modifications (see Section 2.3 Water Resources – Wetlands)3. The Plan and modified Procedures is referred to as Dominion’s Plan and Procedures throughout this document. Dominion would also provide an Erosion and Sediment Control (E&SC) Plan and a Spill Prevention Containment and Countermeasures (SPCC) Plans to minimize sediment outside of the project area and ensure proper handling of lubricants, fuel, or other potentially toxic materials and prevent spills, respectively, prior to construction. These plans would be developed and implemented in compliance with the FERC, Virginia Department of Environmental Quality (VDEQ) (for facilities at the Pleasant Valley Compressor Station in Virginia) and the Maryland Department of the Environment (MDE) (for facilities in Maryland). Dominion would implement best management practices (BMPs) that conform to the FERC’s Plan and Procedures (with the exceptions noted above), VDEQ’s 1992, Third Edition, Virginia Erosion and Sediment Control Handbook (for the Pleasant Valley Compressor Station in Virginia), and the MDE’s 2011 Maryland Standards and Specifications for Soil Erosion and Sediment Control (for portions of the Projects in Maryland).

During construction, Dominion would clear and grade the sites for the aboveground facilities. Erosion control devices would be installed as needed to prevent erosion and offsite impacts in accordance with Dominion’s E&SC Plan and Plan, and applicable state permit requirements. Access to the aboveground facilities would be provided by extension/modification of existing access roads. After construction, all temporary workspaces would be revegetated in

3 The Plan and Procedures includes best management practices for pipeline facility

construction to minimize resource impacts. Copies of the Plan and Procedures may be accessed on our website (http://www.ferc.gov/industries/gas/enviro/guidelines.asp).


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accordance with Dominion’s E&SC Plan and Dominion’s Plan. In addition, where no fence is currently present, fencing would be placed around aboveground facilities, for security purposes.

Dominion would use at least one full-time environmental inspector (EI) during construction of the Projects. The EI would be on site during construction activities to ensure compliance with the construction procedures contained in Dominion’s E&SC Plan and Dominion’s Plan and Procedures. The EI’s responsibilities include:

ensuring compliance with applicable federal, state, and local environmental permits;

ordering corrective actions for acts that violate the environmental conditions of the Commission’s Certificate, or any other authorizing document;

ensuring compliance with site-specific construction and restoration plans or other mitigation measures and landowner agreements; and

maintaining construction status reports.

Dominion would conduct environmental training sessions in advance of construction to ensure that all individuals working on the Projects are familiar with the environmental mitigation measures appropriate to their jobs and the EI’s authority.

8.0 LAND REQUIREMENTS

Construction of Dominion’s St. Charles Transportation Project would temporarily impact 22.6 acres of land during construction, and of this, 2.1 acres would be permanently affected by operation of the proposed facilities. Project activities at the Pleasant Valley Compressor Station for both Projects overlap and are within the same vicinity (see figure 3), so impact calculations of the Projects footprint are analyzed together throughout this document. The activities within the Pleasant Valley Compressor Station would occur entirely within the footprint of the existing compressor station. The CPV Maryland Interconnect would occur entirely within Dominion’s existing right-of-way. The Keys Energy Project would impact 28.5 acres of land during construction, and of this, 2.3 acres would be permanently affected by operation of the proposed facilities. The Keys Energy Interconnect would be constructed on an existing agricultural field.

Table 2 indicates the amount of impact that would occur at each site. Construction activity at the Pleasant Valley Compressor Station would include 22 acres of temporary and of this, 1.1 acres of permanent impacts. Activities at the CPV Maryland Interconnect would include 0.6 acre of temporary and of this, 0.96 acre of permanent impacts (at this location, Dominion would not build the M&R station but would own and operate it, which makes the permanent impacts higher than the temporary). Activities at the Keys Energy Interconnect would include 6.5 acres of temporary and of this, 1.2 acres of permanent impacts.


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Table 2 Acreage Affected by Construction and Operation of the Proposed Facilities

Land Affected by

Constructionb (acres) Land Affected by Operation (acres)

Facility County,

State Open Landa

Forest/Wood land

Commercial/ Industrial/ Disturbed

Open Land

Forest/Wood-

land

Commercial/ Industrial/ Disturbed

Pleasant Valley

Compressor Station

Fairfax, Virginia

9.1 6.7 6.2 0.4 0.03 0.7

CPV Maryland

Interconnect

Charles, Maryland

0.4 0.2 0 0.06 0.3 0

Keys Energy Interconnect

Charles, Maryland

6.5 0 0 1.2 0 0

TOTAL 16.0 6.9 6.2 1.7 0.3 0.7 aOpen land includes mowed and maintained agricultural fields, maintained utility right-of-way, wetlands, and old field/shrub lands. bTemporary impacts include both construction and operational impacts.

B. ENVIRONMENTAL ANALYSIS

1.0 GEOLOGY

The proposed Pleasant Valley Compressor Station upgrades would be located within the footprint of the existing compressor station, which is within the Northern Piedmont Physiographic Province in Fairfax County, Virginia. The province is characterized by gently rolling topography with deep weathered bedrock and a small number of solid outcrops. The elevation of the Province is 200- to 300-feet above sea level in the east and gradually increases to 800- to 900-feet above sea level towards the western edge of the Piedmont Province. The bedrock of the Piedmont Province is comprised of igneous and metamorphic rocks that range from the Proterozoic to Paleozoic era. The depth to bedrock at the Pleasant Valley Compressor Station site is anticipated to be 6 to 65 feet below ground surface; however, Dominion would not utilize blasting during construction of the Projects (William and Mary, Department of Geology, n.d.).

The proposed CPV Maryland Interconnect site is located in the Western Shore Uplands region within the Coastal Plain Physiographic Province in Charles County, Maryland. The province encompasses the Western and Eastern Shores of Maryland and is underlain by a wedge of unconsolidated sediments including gravel, sand, silt, and clay. The CPV Maryland Interconnect has a maximum elevation of 190 feet and a minimum elevation of 187 feet. In places the terrain is moderately to thoroughly dissected, and erosion has produced numerous hillocks. Elsewhere, sands and gravels of Pliocene age underlie a relatively flat upland surface in which stream incision has formed steep-sided valleys (Reger and Cleaves, 2008).

The proposed Keys Energy Interconnect site is in the Western Shore Uplands region within the Coastal Plain. The Keys Energy Interconnect is relatively flat and has a consistent elevation of approximately 200 feet. The surficial geology is described as gravel and sand, commonly orange-


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brown, locally limonite-cemented; minor silt and red, white, or gray clay; lower gravel member and upper loam member in Southern Maryland. The Western Shore Uplands is a flat to rolling upland surface underlain by mostly unconsolidated sediments of Cretaceous to Holocene age. In places the terrain in the Province is moderately to thoroughly dissected, and erosion has produced numerous hillocks. Elsewhere, sands and gravels of Pliocene age underlie a relatively flat upland surface in which stream incision has formed steep-sided valleys (Reger and Cleaves, 2008).

Based on the limited ground disturbance at the Pleasant Valley Compressor Station, CPV Maryland Interconnect, and Keys Energy Interconnect sites, the proposed facilities would result in minimal impact on geologic resources. Dominion’s adherence to the measures contained in its E&SC Plan, and its Plan and Procedures, would ensure that all disturbed areas at these sites are adequately restored following construction.

1.1 Earthquakes

Historical earthquake records for Fairfax and Charles Counties show no active or inactive faults near Pleasant Valley Compressor Station, CPV Maryland Interconnect, and Keys Energy Interconnect sites (USGS, 2011). According to the U.S. Geological Survey (USGS) seismic hazard mapping website, it is unlikely that a “major” earthquake would occur in northern Virginia and southern Maryland in the next 20-50 years of a magnitude that would cause severe or even mildly severe structural damage. Based on the unlikelihood of a major earthquake in the vicinity of the proposed Projects, the potential for soil liquefaction is low.

1.2 Landslides

According to the USGS, which uses data from Radbruch-Hall et al. (1982), Fairfax and Charles Counties have low landslide susceptibility (USGS, 2012). The low slopes and types of soils found within the Pleasant Valley Compressor Station, CPV Maryland Interconnect, and Keys Energy Interconnect sites minimize the landslide exposure. Based on the low likelihood of a landslide at the Projects, we conclude that there is a low likelihood of landslide hazards impacting the proposed facilities.

No blasting is anticipated during construction of the St. Charles Transportation or Keys Energy Projects. If blasting is required, Dominion would be required to file a blasting plan with the Commission prior to conducting such operations.

We find that Dominion’s adherence to their proposed construction, operation, and mitigation procedures would ensure that the geologic hazards would not significantly impact the proposed facilities.

2.0 SOILS

The Pleasant Valley Compressor Station area includes Albano, Ashburn, Catlett, Kelly, Penn, and Sycoline soil series. The Albano and Kelly series are deep, poorly drained with slopes ranging from zero to 10 percent. The Ashburn, Penn, and Sycoline series are moderately deep and well-drained, ranging from zero to 60 percent slopes. The Catlett series is shallow and well drained, and found on upland ridge tops and side slopes ranging from two to 50. The compressor station project area is located between State Route 621 and State Route 609 in Centreville, Virginia. About 22 acres would be required for construction, and about 1.1 acres would be


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permanently maintained for operation. Based on adherence to measures contained in Dominion’s E&SC Plan and its Plan and Procedures, impacts on soils at the Pleasant Valley Compressor Station would be adequately minimized.

According to the U.S. Department of Agriculture’s National Resources Conservation Service (NRCS), soils at the CPV Maryland Interconnect and Keys Energy Interconnect site include the Lenni, Quindocqua, and Woodstown series. The Lenni series is very deep and poorly drained, with slopes from zero to five percent. The Quindocqua series is very deep and poorly drained, found on interfluves and drainageways of the Coastal Plain, with slopes ranging from zero to two percent. The Woodstown series is very deep, moderately well drained, sandy marine and old alluvial sediments, with slopes ranging from zero to 30 percent.

Soils at the CPV Maryland Interconnect and Keys Energy Interconnect sites would be permanently converted by construction and operation of the aboveground facilities. During construction of the CPV Maryland Interconnect, approximately 0.6 acre of open and forested lands would be impacted, with operation requiring 0.4 acre. The soil type of the Keys Energy Interconnect is prime farmland, if irrigated. During construction, 6.5 acres could be impacted, with 1.2 acres required for permanent operation of the taps and M&R station. Areas that are not permanently impacted during construction and operation would be returned to pre-construction conditions. Dominion would utilize Maryland Department of the Environment’s (MDE) 2011 Maryland Standards and Specifications for Soil Erosion and Sediment Control to create stormwater management (SWM) for minimizing erosion and controlling sediment runoff during construction. We conclude that adherence to Dominion’s E&SC Plan, which contain measures consistent with Dominion’s Plan and Procedures, as well as Dominion’s SWM, would limit impacts on soils in the project areas.

3.0 WATER RESOURCES

3.1 Groundwater Resources

There are no state-designated primary or U.S. Environmental Protection Agency (EPA) sole source aquifers in the vicinity of Dominion’s project areas. There is one private well located at the Pleasant Valley Compressor Station, which is used for drinking, cooling, fire protection, and testing. No water wells or springs are present within 150 feet of the construction areas at the CPV Maryland and Keys Energy Interconnect sites. No other private wells are present within 200 feet, municipal or community water supply wells within 400 feet, or groundwater wells within a one mile radius of any project activities at Dominion’s project areas. Accidental spills of fuels, lubricants, and other petroleum products could occur during construction activities. Dominion agrees to prohibit refueling activities and storage of hazardous liquids within the area of the private well at the Pleasant Valley Compressor Station. In addition, Dominion would prepare an SPCC Plan prior to the start of construction. These plans include spill avoidance measures as well as measures to contain and cleanup materials in the event of a release. Based on the nature of the construction activities and Dominion’s proposed construction procedures and mitigation measures, we conclude that the Projects are not likely to have a significant impact on groundwater resources.


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3.2 Surface Water

No surface waters within or adjacent to any of the three project sites are listed as impaired (VDEQ and VDCR, 2014, and MDE, 2014), and no sensitive surface waters are present at any of the three Project sites. Two intermittent stream channels are located within the Pleasant Valley Compressor Station, but would not be impacted by construction. Both are considered blue-line streams, waters of the U.S. (WUS), Relatively Permanent Waters, and are numbered 12 and 13 (see figure 6). WUS 12 is an unnamed tributary of Bull Run on the northwestern portion of the site, and does not contain vegetation. WUS 13, on the southeastern portion of the site, is within a forested area. It conveys flow to the south for approximately 393 feet before contributing to an existing wetland on-site. Dominion would not impact these waterbodies during construction and would implement its E&SC Plan and SWM to protect adjacent resources. No streams or waterbodies are present at the CPV Maryland Interconnect and Keys Energy Interconnect. We conclude that Dominion’s implementation of its E&SC Plan, SWM, and SPCC Plan would adequately minimize impacts on waterbodies and surface waters.

3.3 Hydrostatic Testing

Dominion would hydrostatically test all pipelines in accordance with DOT pipeline safety regulations. Hydrostatic testing involves filling the pipeline facilities with water and pressurizing the pipeline facilities above their maximum allowable operating pressure (MAOP). The pressure in the facilities is then monitored for several hours. If a drop in pressure is recorded, then the pipeline facilities would be examined to determine if any leaks have occurred. Dominion would truck in approximately 156,500 gallons total for all three sites of hydrostatic test.

Dominion would haul and dispose the water used for hydrostatic testing to an off-site public sewage treatment center. For the reasons discussed above, we conclude that the hydrostatic testing of the Projects would not have a significant impact on water resources.

3.4 Wetlands

Field surveys identified two wetlands within the Pleasant Valley Compressor Station property. However, these wetlands would be avoided during construction. Dominion would implement measures that are consistent with Dominion’s Plan and Procedures, and these BMPS would be installed immediately after initial disturbance of the soil and maintained throughout construction to ensure sedimentation does not affect the wetland.

The VDEQ submitted a comment expressing concern about the constituents of the fill that would occur to this wetland, later stating they are satisfied with the description Dominion provided in Resource Report 3. The Fairfax County Department of Planning and Zoning (who submitted their comment through the VDEQ) indicated that they have concerns about the Projects’ proposed equipment fueling and spoil storage in nontidal wetlands.

One wetland is identified as being impacted by the CPV Maryland Interconnect Project site. This palustrine emergent (PEM) wetland extends outside of the site into adjacent forested land and across the existing right-of-way to the west. The acreage amount of impact during construction is 0.3 acre, of which 0.02 acre would be impacted during operation of the facility. This wetland contains woolgrass (Scirpus cyperinus), soft rush (Juncus effusus), and various carex species (Carex spp.).


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Where wetlands are present and upland areas are limited, Dominion proposes to limit land disturbance at the CPV Maryland Interconnect during construction to 0.3 acre of wetlands within its existing right-of-way. In this location, Dominion states that no work areas are available directly adjacent or in close proximity to the proposed tap site to allow refueling and storage of spoil at least 100 feet from a wetland. Consistent with Section 1.A of the Procedures, Dominion proposed the following site-specific exceptions for the CPV Maryland Interconnect:

Equipment would be fueled on-site, at the tap site location and within the wetland area, as there is no reasonable alternative (Section IV.A.1.d); and

Spoil would be stored on-site, at the tap site location and within the wetland area, as upland areas are limited at this location (Section VI.B.1.a).

Dominion would take the following precautions to reduce the risk of spills or accidental

exposure of fuels and spoil on wetlands: all employees responsible for refueling equipment would be properly trained and would

know the procedure for reporting spills; all equipment would be maintained in good operating order and inspected on a regular

basis; fuel trucks transporting fuel to on-site equipment would travel only on approved access

roads; adequate spill response materials would be kept on-site to enable a rapid cleanup

should a spill occur; if fuel is stored on-site, secondary containment would be provided; and wetland boundaries would be marked with flagging, and silt fencing and/or hay bales

would be used to physically separate spoil piles from the wetland.

Our review indicates that the location of the wetlands at the CPV Maryland Interconnect site would make refueling and spoil storage outside of the wetland difficult. Therefore, we find the precautionary measures proposed by Dominion adequate to minimize impacts on wetlands. Mitigation for impacts on this wetland would occur via the U.S. Army Corps of Engineers (USACE) per Section 404 and MDE, per Section 401 of the Clean Water Act. Dominion would provide a copy of the USACE/permit and 401 Certification to FERC prior to construction.

Dominion’s Procedures prohibit locating aboveground facilities in any wetland (Section

VI.A.6). Therefore, we recommend: Before construction, Dominion should file with the Secretary of the Commission

(Secretary) a revised plot plan for the CPV Maryland Interconnect for review and approval of the Director of the Office of Energy Projects (OEP) to avoid direct wetland impacts; or provide documentation from the USACE and MDE that its permit allows its placement in the wetland.

No wetlands were identified at the Keys Energy Interconnect site.

In conclusion, Dominion would prepare an SPCC Plan which contains measures to minimize the potential for releases of fuels or hazardous materials and the measures to be taken in the event of a release. Given Dominion’s commitment to the measures identified in Dominion’s


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Plan and Procedures, and adherence to other relevant permits and our above recommendation, impacts on wetlands during construction and operation would be limited and minimized.

4.0 VEGETATION, WILDLIFE, AND THREATENED AND ENDANGERED SPECIES

4.1 Vegetation

The Pleasant Valley Compressor Station is located within the Elklick Diabase Flatwoods Conservation Site. Conservation sites are built around and designate geographic areas where one or more rare plant, animal or natural communities are known to occur and may require additional review for potential conservation action. The Elklick Diabase Flatwoods Conservation Site has been ranked as a site of very high significance (B2). Species of concern are Torrey’s mountain mint (Pycnanthemum torrei), grove sandwort (Moehringia lateriflora), and purple milkweed (Asclepias purpurascens). Additionally, habitat types of concern within the Elklick Diabase Flatwoods Conservation Site include Piedmont Upland Depression Swamp, Northern Hardpan Basic Oak-Hickory Forest, and Northern Piedmont Mafic Barren.

The forest at the Pleasant Valley Compressor Station is an oak-hickory forest, including dominant species of northern red oak, white oak, and mockernut hickory. The understory includes eastern red cedar, post oak, highbush blueberry and saplings of the dominant canopy species. The invasive species Nepalese browntop and Chinese bush-clover are present in the understory in some areas. The ground cover is sparse. The wooded portion of the Pleasant Valley Compressor Station study area include many of the canopy species that are represented by the northern hardpan basic oak-hickory forest contained within the Elklick Diabase Flatwoods Conservation Site. Dominion consulted with the VDCR and Virginia Department of Agriculture and Consumer Services (VDACS) in 2013 during the consultations for the Cove Point Liquefaction Project (Docket No. CP13-113), which included the same footprint within the Pleasant Valley Compressor Station, regarding the potential presence of the Northern Hardpan Basic Oak-Hickory Forest. The VDCR confirmed that the forest community at the Pleasant Valley Compressor Station site represents an acidic oak-hickory forest and, as such, the Projects would not affect significant forest communities of concern (VDCR, 2013).

The Pleasant Valley Compressor Station Project would be completed within the existing footprint of the Pleasant Valley Compressor Station, so no habitats of concern would be impacted. Approximately 6.7 acres of forest-covered upland, 6.3 acres of mowed/maintained land, and 2.8 acres of old field/pioneer-covered land may be temporarily impacted during construction. No plant species of concern were observed during surveys on the compressor station site. Piedmont upland depression swamp and northern piedmont mafic barren, both elements included within the Elklick Diabase Flatwoods Conservation Site (500 feet to the southeast of the project site), are not present at the site. The Pleasant Valley Compressor Station property also contains old field/pioneer habitat. Impacts on the forested uplands could be considered long term, as the time to revegetate forested lands can take 10-20 years. No permanent impacts would occur to the mowed or old field habitat.

The CPV Maryland Interconnect is located within an existing right-of-way and is characterized as emergent habitat with mowed maintained areas scattered within the right-of-way. This habitat type is maintained by occasional mowing. Deciduous and coniferous trees dominate the edge of the right-of-way. Invasive species such as bush clover, Nepalese browntop, common


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reed, multiflora rose, and arrow-leaf tearthumb were identified at the CPV Maryland Interconnect. Approximately 0.3 acre of emergent wetlands, 0.1 acre of mowed/maintained land, and 0.2 acre of forest covered upland may be temporarily impacted during construction of the CPV Maryland Interconnect. Approximately 0.02 acre of emergent wetlands, 0.04 acre of mowed/maintained covered upland and 0.3 acre of forest-covered upland would be permanently converted to developed land by operation of the facilities.

The Keys Energy Interconnect site is an agricultural field planted with soybeans, bordered by herbaceous vegetation, a few trees, and maintained areas. This habitat type is maintained by agricultural practices including mowing and herbicide application. The majority of the site, including the entire central area, is planted in soybeans. The maintained areas surrounding the site are dominated by common ragweed, fescue species, and crabgrass. There are few deciduous and coniferous trees along the edge of the site that include Eastern red cedar, sweetgum, and black locust. Approximately 6.5 acres of agricultural field and 0.04 acre of weeds/wild plants would be temporarily impacted during construction. Of this, 1.2 acres of agricultural field and 0.02 acre of weeds/wild plants would be maintained for operation of the facilities, and the remaining areas would be maintained as open land.

Implementation of Dominion’s Plan and Procedures would promote revegetation at project areas following construction. Additionally, at the Pleasant Valley Compressor Station under the Cove Point Liquefaction Project, Dominion is required to implement an Invasive Species Management Plan during and post-construction. No sensitive vegetation types or habitats of concern would be impacted by either of the Projects. Dominion would revegetate all temporary construction areas in accordance with its E&SC Plan after construction is complete. Therefore, the Projects would not result in any significant impacts on vegetation.

4.2 Wildlife

The proposed project areas consist of mixed coniferous forests, old field/pioneer, mowed/maintained grass, agricultural fields, emergent forested/shrub wetland, and a vegetated stormwater management pond. Common wildlife species inhabiting these areas include red fox, groundhogs, mice, voles, shrews, rabbits, snakes, and birds.

As stated in Section A.5.0, the VDEQ indicated that activities proposed at the Pleasant Valley Compressor Station are within 2 miles of a documented occurrence of the wood turtle (Glyptemys insculpta), a Virginia state-listed animal, and Cub Run, a “Threatened and Endangered Species Water” designated by the VDGIF. However, Dominion would not impact waterbodies in the vicinity of the Pleasant Valley Compressor Station (discussed in Section 3.2) during construction and would implement its E&SC Plan and SWM to protect adjacent resources. Due to the distance, lack of impact to any waterbodies, and lack of documented occurrences within the Project area, no impacts would occur to this aquatic species as a result of the Projects.

Potential impacts on wildlife include habitat loss and construction-related ground disturbance and noise. Some less mobile individuals could be inadvertently injured or killed by construction equipment. However, more mobile species such as birds and mammals would relocate to other suitable nearby habitat once construction activities begin. The temporary disturbance of local habitat would not have a population-level impact on wildlife because the amount of habitat disturbed represents a small portion of the available habitat throughout the


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project areas. Therefore, we conclude that the Projects would not have a significant impact on wildlife.

4.3 Migratory Birds

Migratory birds are species that nest in the United States and Canada during the summer and then migrate to and from the tropical regions of Mexico, Central and South America, and the Caribbean for the non-breeding season. Migratory birds are protected under the Migratory Bird Treaty Act ([MBTA]-16 U.S. Code 703-711) and Bald and Golden Eagles are additionally protected under the Bald and Golden Eagle Act (16 U.S. Code 668-668d). The MBTA, as amended, prohibits the taking, killing, possession, transportation, and importation of migratory birds, their eggs, parts, and nests. Executive Order 13186 (66 FR 3853) was enacted in 2001 to, among other things, ensure that environmental analyses of federal actions evaluate the impacts of actions on migratory birds. Executive Order 13186 directs federal agencies to identify where unintentional take is likely to have a measurable negative effect on migratory bird populations and avoid or minimize adverse impacts on migratory birds through enhanced collaboration with the U.S. Fish and Wildlife Service (FWS). The environmental analysis should further emphasize species of concern, priority habitats, key risk factors, and that particular focus should be given to population-level impacts.

The Projects would involve construction of new facilities and expansion of existing facilities, which necessitate clearing of vegetation at locations as previously described. Some areas of vegetation removal would be temporarily/permanently lost including areas of Forest Interior Dwelling Species (FIDS) habitat within the Maryland project areas (Maryland Department of Natural Resources [MDNR], May 2001). Bird species such as barred owl, whip-poor-will, and cerulean, Kentucky, and worm-eating warblers and wood thrush would lose potential breeding habitat as would other migratory bird species that use the same habitat. Remaining habitat could be affected by an increase in edge exposure that would increase predation of eggs and nestlings as well as increasing the potential for nest parasitism by brown-headed cowbirds (Molothrus ater). Clearing of vegetation can also result in colonization or expansion of invasive plant species altering remaining habitat. Tree and vegetation removal can result in the direct loss of nests, eggs, and nestlings if clearing occurs within the nesting season.

The Projects would be co-located with pre-existing industrial facilities to further minimize habitat disturbance on migratory birds by avoiding, to the extent practicable, the amount of ground disturbance, forest clearing, and impacts on surface waters and wetlands. For example, at the Pleasant Valley Compressor Station, the new facilities are sited within the existing compressor station site, avoiding additional disturbance to adjacent forest, streams, and wetlands. Similarly, the CPV Maryland Interconnect site was selected because it is located within an existing, maintained Dominion right-of-way. In addition, Dominion’s proposed vegetation clearing schedule would not overlap the bird nesting season.

Executive Order 13186 also requires the federal agency to identify where unintentional "take" (i.e., the unintended death, harm, or harassment) is likely to have a measurable negative effect on migratory bird populations. Adult birds relocating to avoid construction is an impact of limited duration that would not result in a substantial or long-term change in migration patterns through the area nor constitute a population-level impact.


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Construction of the proposed Projects would not significantly affect migratory bird species within the project areas. The FWS Virginia Field Office provided concurrence to this effect on December 24, 2014. The amount of proposed removal of suitable migratory bird habitat within the proposed Maryland project areas is minimal (0.3 acre of forested land would be required for operation of the CPV Maryland Interconnect). The Chesapeake Bay Field Office of the FWS did not provide comments on migratory birds in their November 14, 2007 correspondence related to the Projects.

4.4 Special Status, Threatened, and Endangered Species

Federal agencies are required under section 7 of the Endangered Species Act, as amended, to ensure that any actions authorized, funded, or carried out by the agency would not jeopardize the continued existence of a federally listed endangered or threatened species, or result in the destruction or adverse modification of the designated critical habitat of a federally listed species. As the lead federal agency authorizing the Projects, the FERC is required to consult with the FWS and/or the National Oceanic and Atmospheric Administration Fisheries to determine whether federally listed endangered or threatened species or designated critical habitat are found in the vicinity of the Projects, and to evaluate the proposed action’s potential effects on those species or critical habitats.

The federally threatened small-whorled pagonia (Isotria medeoloides) and western pearly

everlasting (Anaphalis margaritacea, status S14) occur within Fairfax County, Virginia. The Maryland threatened bamboo vine (Smilax pseudochina) could also occur. Multiple habitat suitability and blooming period surveys were performed by botanists within the project footprint of the Pleasant Valley Compressor Station for these and other rare plant species that could occur there. The habitat was not suitable within the project areas to support rare plant species.

Dominion contacted the VDGIF, VDCR, VDACS (who submits through VDCR),

Maryland Natural Heritage Program (MNHP), MDE, and MDNR regarding its Projects. Dominion conducted habitat surveys at all three project areas and found no potential suitable habitat for special status or federally listed species present at the site.

Dominion, acting as the Projects’ non-federal representative of the FERC, initiated

informal consultation with the FWS in November 2014. The Virginia Field Office issued a “no comment” email on December 24, 2014. On November 14, 2007, the Chesapeake Bay Field Office issued a letter stating no federally proposed or listed endangered or threatened species are known to exist within the project impact areas. Therefore, the project is not likely to adversely affect these species. The FWS Virginia Field Office concurred with this determination on August 15, 2013.

We also conclude that Dominion’s Projects would have no affect on state-listed or special

status species.

4 Within the state of Virginia, critically imperiled and at very high risk of extirpation from

the state due to extreme rarity (often 5 or fewer populations), very steep declines, or other factors.


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5.0 CULTURAL RESOURCES

Section 106 of the National Historic Preservation Act (NHPA), as amended, requires the Commission to take into account the effects of its undertakings (including the issuance of Certificates) on properties listed or eligible for listing on the National Register of Historic Places (NRHP), and to afford the Advisory Council on Historic Preservation (ACHP) an opportunity to comment on the undertaking. Dominion provided us with information, analyses, and recommendations necessary to complete the process of complying with Section 106, as allowed by the ACHP’s implementing regulations at 36 CFR Part 800.2(a)(3), and outlined in our Guidelines for Reporting on Cultural Resources Investigations for Pipeline Projects (OEP Cultural Resources Guidelines, December 2002, as specified in 18 CFR Part 380.12(f)). 5.1 Consultations

We sent copies of our NOI for the Projects to a wide range of stakeholders, including the ACHP, U.S. Department of the Interior National Park Service, Maryland Historic Trust (MHT), Virginia Department of Historic Resources (VDHR), and federally recognized Indian tribes (tribes) that may have an interest in the project area. The NOI contained a paragraph about Section 106 of the NHPA, and stated that we use the NOI to initiate consultations with the State Historic Preservation Officer (SHPO)5, and to solicit their views and those of other government agencies, interested tribes, and the public on the Projects’ potential effects on historic properties.

5.2 State Historic Preservation Officers

For the St. Charles Transportation Project, Dominion submitted letters dated November 14, 2014, to the Maryland and Virginia SHPOs, to inform them of the project and provide recommendations. The Maryland SHPO provided comments on December 3, 2014 stating that there were no historic properties in the area of potential effects (APE). The Virginia SHPO responded in a letter dated December 17, 2014, stating that adverse effects were unlikely on historic properties.

For the Keys Energy Project, Dominion submitted letters dated November 14, 2014, to the

Maryland and Virginia SHPOs, to inform them of the project and provide recommendations. The Virginia SHPO responded in a letter dated December 17, 2014, stating that adverse effects were unlikely on historic properties. The Maryland SHPO provided comments on February 6, 2015, stating that there were no historic properties in the APE.

5.3 Federally Recognized Indian Tribes

Dominion filed documentation of contacting five tribes regarding the Projects in letters dated November14, 2014. These tribes were the Delaware Nation, Delaware Tribe of Indians, Eastern Shawnee Tribe of Oklahoma, the Shawnee Tribe of Oklahoma, and the Tuscarora Nation. The Delaware Nation provided comments in a letter dated December 12, 2014, and stated they would like to be contacted in the event of an unanticipated discovery.

5 The SHPO is represented by the VDHR in Virginia and by the MHT in Maryland.


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5.4 Other Parties

Dominion contacted other potential interested parties in letters dated November 14, 2014. These parties consisted of the Patawomeck Indians of Virginia, Maryland Commission on Indian Affairs, Piscataway/Conoy Confederacy and Subtribes, Cedarville Band of Piscataway Indians, and Piscataway Indian Nation. No responses have been filed by Dominion.

5.5 Survey Results

The APE consists of areas of ground disturbance for the proposed pipeline trench, associated temporary workspaces (temporary construction right-of-way and additional temporary workspace), proposed compressor stations, access roads, and M&R stations. The APE for historic architectural resources includes the construction footprint of the aboveground facilities, as well as where the Projects may lie within view of an aboveground cultural resource.

For the St. Charles Transportation Project, the APE was previously investigated in 2003 and 2013 in Virginia. No cultural resources were identified. FERC and the Virginia SHPO agreed there were no effects on historic properties within or adjacent to the Pleasant Valley Compressor Station. In Maryland, most of the project area was investigated in 2004 (Phase I Cultural Resources Survey for Cove Point Expansion TL-532 Pipeline Project – Calvert, Prince George’s and Charles Counties Maryland) and no cultural resources were encountered.

For the Keys Energy Project, the survey consisted of reviewing about 6.9 acres in

Maryland. No cultural resources were identified.

5.6 Unanticipated Discovery Plan

Dominion included unanticipated discovery plans for Maryland and Virginia as Appendix 4D attached to the Environmental Reports included with its applications to the FERC. Dominion has not filed the comments of the Virginia or Maryland SHPO on the unanticipated discovery plans; however, the FERC staff found the plans acceptable.

5.7 Compliance with the National Historic Preservation Act

Dominion consulted with the Virginia and Maryland SHPO regarding the potential effects to cultural resources. The Virginia and Maryland SHPO did not object to the APE and concurred that there would be no adverse effects on historic properties.

No traditional cultural properties or properties of religious or cultural importance to Indian

tribes have been identified by Dominion, its consultants, the SHPOs, or tribes contacted by the applicant and its consultants. The FERC staff and the Virginia and Maryland SHPO agree that the Projects would have no adverse effects on historic properties.


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6.0 LAND USE, RECREATION, AND VISUAL RESOURCES

6.1 Land Use

Construction of the Projects would disturb about 29.5 acres of land during construction and 2.7 acres for operation. These Projects would affect forested, open and industrial land use types. A summary of the impacts on land use are outlined in table 2 on page 12.

If the Projects are approved they would result in the conversion of 0.3 acres of forested lands and 1.7 acres of open lands, including 0.02 acre of wetland, to industrial land use. The existing land use in these areas would be precluded by the operation of the facilities (i.e., forest land would permanently convert to industrial land). Construction of the CPV Maryland Interconnect would occur within Dominion’s existing 75-foot-wide right-of-way.

Dominion would use existing public roads to access the project workspaces. An access road to the CPV Maryland Interconnect is currently under construction, and CPV Maryland, LLC received appropriate permits. Dominion leases/owns all of the land that would be affected by the Projects.

The Pleasant Valley Compressor Station project upgrades are expected to create 60 construction jobs, while the CPV Maryland Interconnect would create 15 from September 2015 through April 2016 for the St. Charles Transportation Project. The Pleasant Valley Compressor Station upgrades would create 60 jobs from January 2016 through March 2017, while the Keys Energy Interconnect would create 15 from January 2016 through July 2016, for the Keys Energy Project. Operation of the facilities would not create any new full-time jobs. The number of temporary jobs from construction would not cause significant socioeconomic impacts in Fairfax or Charles Counties; and unemployment, housing, and community service impacts would be unlikely. Changes in regional income would depend on the actual compensation, but would be proportional to the number of jobs generated.

During construction, Dominion anticipates employing local workers at each project area. The non-local laborers could represent a temporary increase in the percent of the total population in the project areas; however, the potentially vacant rental units available in the project areas would offer enough housing for non-local workers. While construction traffic may increase during the construction period as a result of Projects being constructed in the same location at the same time, there would be no long-term impacts on traffic, transportation, or public services.

There are no residences within 50 feet of the project vicinities. Two residential subdivisions are being developed near the Pleasant Valley Compressor Station. The proposed Foxmont and Hunters Pond developments are located within 0.3 miles of the Pleasant Valley Compressor Station property line. Based on the most recent available aerial imagery, none of the properties have been developed to date; however, the closest parcel of the Foxmont and Hunters Pond developments is the Homeowners Association Parcel A, located approximately 0.05 mile southeast of the Pleasant Valley Compressor Station property line. The closest proposed lot is Lot 13 located approximately 0.2 mile from the Pleasant Valley Compressor Station property line.

The CPV Maryland Interconnect and Keys Energy Interconnect are located within the development district of Charles County. The CPV Maryland Interconnect is located at the border


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of the St. Charles Community development. According to the St. Charles Companies Master Plan (2014), there are plans to add new community facilities within a mile of the site in the future, but no additional residences or facilities are planned to be added within 0.25 mile of the CPV Maryland Interconnect. There are no known planned developments to the east of the CPV Maryland Interconnect. No plans for residential or industrial development within 0.25 miles of the Keys Energy Interconnect were identified.

The CPV Maryland Interconnect is located within the development district of Charles County, Maryland. Properties to the west of the site are zoned as planned unit development, and properties to the east of the site are zoned as low density suburban residential. During the 2010 Maryland Department of Planning Land Use Survey, agricultural lands were observed within a half mile south of the site. No conservation or agricultural easements are found within the vicinity.

The Keys Energy Interconnect is located within 2 miles of Cedarville State Forest. There are no federal or county parks in the vicinity of the site. The site is located in a zoned rural legacy area according to the Maryland Department of Planning, Charles County, 2010. State-owned resource lands and 5-year Maryland Agricultural Land Preservation Districts are in the vicinity of the site also, but are not crossed.

6.2 Recreation

The closest public lands to the Pleasant Valley Compressor Station were identified as the forested properties to the north and south of the property boundary. The Pleasant Valley Compressor Station is located within the Elklick Diabase Flatwoods Conservation Site, approximately 500 feet northwest of the Elklick Woodlands Natural Area Preserve. The Fairfax County Park Authority has developed a natural resource management plan for the Preserve, which includes a management objective for the existing pipeline right-of-way. This objective specifies that Fairfax County Park Authority would “establish communication with Dominion land managers to establish areas of common interest and to coordinate, plan, and monitor land management practices on the rights-of-way to benefit both Elklick Woodlands and the right-of-way.”

The Elklick Woodlands Natural Area Preserve is a 226-acre conservation area located 500 feet southeast of the Pleasant Valley Compressor Station, in the Park Authority’s Elklick Preserve, which is part of the Sully Woodlands Assemblage. The Elklick Woodlands Natural Area Preserve is protected with a conservation easement held by the Northern Virginia Conservation Trust.

The CPV Maryland Interconnect is located within a mile of two county parks: White Plains Regional Park and the Robert D. Stethem Memorial Sports Complex. There are no federal or state parks in the vicinity of the site. There are two resource protective zones in the vicinity of the site: A forested area approximately 500 feet to the southeast of the CPV Maryland Interconnect, and Saint Paul’s Lake, which is approximately half a mile north of the site.

The Keys Energy Interconnect is located within 2 miles of Cedarville State Forest. There are no federal or county parks in the vicinity of the site. The site is located in a zoned rural legacy area (Maryland Department of Planning, Charles County, 2010).


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Because of the existing infrastructure and limited scope of the construction and operation of facilities at the project sites, minimal impacts are expected on recreational activities in the project areas.

6.3 Visual Resources

The aboveground facilities (compressor building, fencing, and aboveground piping) associated with the Projects would result in a permanent change in the visual appearance of the project areas and result in long-term impacts on visual resources. The magnitude of these impacts depends on factors such as the existing landscape, the remoteness of the location, and the number of viewpoints from which the facility could be seen.

Construction of additional facilities at these sites would result in temporary visual impacts including increased numbers of company personnel, presence/storage of additional equipment and materials, removal of vegetative and woody cover, and disturbance of soils. These impacts would generally cease following the completion of construction and successful restoration.

All of the aboveground facilities would be located adjacent to existing natural gas facilities. These facilities currently have an existing visual impact on the surrounding areas depending on the direction and viewpoint from which it is seen. By locating the proposed facilities next to existing structures, the visual impact would generally be minimized and no new areas would be subject to visual impacts. To further minimize potential impacts, Dominion would maintain the existing forested buffer along the Pleasant Valley Compressor Station property boundary and minimize nighttime lighting outside of fenced areas. To further minimize impacts on the visual quality at the Keys Energy Interconnect, Dominion would add landscaping and vegetative screening of the Project facilities, as needed.

Based on the proximity of existing industrial infrastructure and limited scope, we conclude that the Projects would not have a significant impact on land use, recreational activities, or visual resources.

6.4 Coastal Zone Management Areas

The Pleasant Valley Compressor Station is located within Fairfax County, which is part of the Coastal Zone of Virginia. Federal Coastal Zone Consistency requirements are overseen in Virginia by the VDEQ. A Virginia Coastal Zone Consistency Certification for the Projects was filed with FERC on March 3, 2015.

The CPV Maryland Interconnect and Keys Energy Interconnect are located within Charles County, which is part of the Coastal Zone of Maryland and the Chesapeake Bay watershed, but is not within the Chesapeake Bay Critical Area. The MDNR is the lead agency of the Maryland Coastal Zone Management Program. The federal consistency requirements are carried out by the Coastal Zone Consistency Division in the Wetlands and Waterways Program of the Water Management Administration in the MDE (Maryland Coastal Program, 2004). In Maryland, the Coastal Zone Consistency Certification is included as part of the Joint Permit Application to the USACE and MDE. Dominion has submitted the application for a Coastal Zone Consistency Determination as part of the Joint Permit Application to the USACE. To ensure that the Commission’s responsibilities are met under the Coastal Zone Management Act, we recommend that:


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Prior to construction, Dominion should file the documentation of concurrence from the MDNR that the project facilities are consistent with the Maryland Coastal Zone Management Program.

7.0 AIR QUALITY AND NOISE

7.1 Air Quality

Air quality in Charles County, Maryland and Fairfax County, Virginia would be affected by construction of the Projects. During construction of the Projects, short-term emissions would be generated by operation of equipment, land disturbance, and increased traffic from worker and delivery vehicles. Operation of the Pleasant Valley Compressor Station, CPV Maryland Interconnect, and Keys Energy Interconnect would result in minimal long-term air emissions.

Charles County, Maryland and Fairfax County, Virginia are characterized by a temperate climate. The areas experience average annual precipitation between 39 and 43 inches and monthly average daily temperatures range from about 22 °F in January to 88 °F in July.

Ambient air quality is protected by federal and state regulations. Under the Clean Air Act (CAA) and its amendments, the EPA has established National Ambient Air Quality Standards (NAAQS) for carbon monoxide (CO), lead, nitrogen dioxide (NO2), ozone, particulate matter less than 10 microns (PM10), particulate matter less than 2.5 microns (PM2.5), and sulfur dioxide (SO2). These standards incorporate short-term (hourly or daily) levels and long-term (annual) levels to address acute and chronic exposures to the pollutants, as appropriate. The NAAQS include primary standards, which are designed to protect human health, including the health of sensitive subpopulations such as children and those with chronic respiratory problems. The NAAQS also include secondary standards designed to protect public welfare, including economic interests, visibility, vegetation, animal species, and other concerns not related to human health. Individual states may set air quality standards that are at least as stringent as the NAAQS. Maryland and Virginia have adopted all of the NAAQS.

Air quality control regions (AQCRs) are areas established for air quality planning purposes in which implementation plans describe how ambient air quality standards would be achieved and maintained. AQCRs were established by the EPA and local agencies, in accordance with section 107 of the CAA, as a means to implement the CAA and comply with the NAAQS through State Implementation Plans (SIPs). The AQCRs are intra- and interstate regions such as large metropolitan areas where improvement of the air quality in one portion of the AQCR requires emission reductions throughout the AQCR. Each AQCR, or portion thereof, is designated based on compliance with the NAAQS. AQCR designations fall under three main categories as follows: “attainment” (areas in compliance with the NAAQS); “nonattainment” (areas not in compliance with the NAAQS); or “unclassifiable.” Unclassifiable areas are treated as attainment areas for the purpose of permitting a stationary source of pollution. Areas that have been designated nonattainment but have since demonstrated compliance with the ambient air quality standard(s) are designated maintenance for that pollutant. Maintenance areas may be subject to more stringent regulatory requirements to ensure continued attainment of the NAAQS pollutant.

The proposed Maryland project facilities are also within the Northeast Ozone Transport Region (OTR). This OTR (42 USC §7511c) includes 11 northeastern states in which ozone transports from one or more states and contributes to a violation of the ozone NAAQS in one or


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more other states. States in this region are required to submit a SIP, stationary sources are subject to more stringent permitting requirements, and various regulatory thresholds are lower for the pollutants that form ozone, even if they meet the ozone NAAQS.

The EPA and state and local agencies have established a network of ambient air quality monitoring stations to measure and track the background concentrations of criteria pollutants across the U.S. This data is then used by regulatory agencies to compare the air quality of an area to the NAAQS. Charles County, Maryland and Fairfax County, Virginia are in attainment for PM10, PM2.5 (24-hour standard), NO2, CO, and lead. However, both counties are within the Washington, DC AQCR and are designated nonattainment for ozone and maintenance for PM2.5

(annual standard).

Greenhouse gases (GHGs) occur in the atmosphere both naturally and as a result of human activities, such as the burning of fossil fuels. These gases are the integral components of the atmosphere’s greenhouse effect that warms the earth’s surface and moderates day/night temperature variation. In general, the most abundant GHGs are water vapor, carbon dioxide (CO2), methane, nitrous oxide (N2O), and ozone. The EPA has expanded its definition of air pollution to include six well-mixed GHGs, finding that the presence of the following GHGs in at the atmosphere endangers public health and public welfare currently and in the future: CO2, methane, N2O, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride.

The Projects would contribute GHG emissions. The principle GHGs that would be emitted by the Projects facilities are CO2 and methane. Emissions of GHGs are quantified and regulated in units of carbon dioxide equivalents (CO2e). The CO2e unit of measure takes into account the global warming potential (GWP) of each GHG. The GWP is a ratio relative to CO2 that is based on the properties of the GHG’s ability to absorb solar radiation as well as the residence time within the atmosphere. Thus, CO2 has a GWP of 1, methane has a GWP of 25, and N2O has a GWP of 298. Consistent with EPA’s definition of air pollution to include GHGs, emissions of GHG pollutants associated with the construction and operation of the Projects and are shown in tables 3 and 4 (presented as CO2e emissions). Impacts from GHG emissions (climate change) are discussed in more detail under the Cumulative Impacts section of this EA.

7.1.1 Permitting/Regulatory Requirements

The CAA, as amended in 1977 and 1990, is the basic federal statute governing air pollution. The provisions of the CAA that are potentially relevant to the Projects are discussed further below.

7.1.1.1 Stationary Source Air Permitting

Equipment at the Pleasant Valley Compressor Station would include electric-driven compressors, gas coolers and replacing a filter/separator. Therefore, the only new emission sources for the Projects would be as a result of fugitive emissions or blow-downs at the Pleasant Valley Compressor Station, CPV Maryland Interconnect, and Keys Energy Interconnect, releasing natural gas. Table 3 presents the new operating air emissions at these facilities, associated with each project. The proposed emissions at these facilities do not trigger any federal or state stationary source air permitting requirements.


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Table 3 Estimated Operation Emissions (tons per year)

Facilities NOxa CO SO2 VOCb PM10

PM2.5

GHG (CO2e)

Pleasant Valley Compressor Station (St. Charles Transportation

Project)

N/A N/A N/A 1.08 N/A N/A 973.4

Pleasant Valley Compressor Station (Keys Energy Project)

N/A N/A N/A 1.08 N/A N/A 973.4

Total Pleasant Valley Compressor Station

N/A N/A N/A 2.16 N/A N/A 1,946.8

Total CPV Maryland Interconnect N/A N/A N/A 0.43 N/A N/A 390.5 Total Keys Energy Interconnect N/A N/A N/A 0.43 N/A N/A 390.5

a NOX - Nitrogen oxides

bVOC - Volatile organic compound

7.1.1.2 National Emission Standards for Hazardous Air Pollutants (NESHAP)

The NESHAPs, also known as the Maximum Achievable Control Technology (MACT) standards, regulate the emissions of hazardous air pollutants (HAPs) from existing and new sources. The 1990 CAA Amendments established a list of 189 HAPs. The NESHAPs, regulates HAP emissions specific source types located at major or area sources of HAPs. The existing Pleasant Valley Compressor Station is not a major source for HAPs, because HAP emissions are below 10 tons per year (tpy) of any single HAP and 25 tpy of all HAPs in aggregate. The Pleasant Valley Compressor Station would remain a minor source of HAPs after the Projects. Similarly, the CPV Maryland Interconnect and Keys Energy Interconnect would not be major sources of HAPs.

7.1.1.3 General Conformity

The EPA promulgated the General Conformity Rule to ensure that emissions from projects that require federal action are consistent with an approved SIP. Under the General Conformity Rule, the federal government cannot engage, support or provide financial assistance for licensing or permitting, or approve an activity not conforming to an approved CAA implementation plan.

Any project that requires federal action must evaluate the applicability of the General Conformity Rule for those emission-generating activities resulting from the project and are located in an area that is designated as nonattainment or a maintenance area. A General Conformity Determination must be completed by the lead federal agency if a federal action is likely to result in direct and indirect emissions (e.g. construction and operation) that would exceed the General Conformity applicability threshold levels of the pollutant(s) for which an air basin is in nonattainment or maintenance.

In compliance with the General Conformity Regulations, activities or actions should not, through additional air pollutant emissions:


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Cause or contribute to new violations of the NAAQS in any area; increase the frequency or severity of any existing violation of any NAAQS; or delay timely attainment of any NAAQS or interim emission reductions.

As noted earlier, the Projects would be located in a nonattainment and maintenance area. Nitrogen oxides (NOx) and volatile organic compounds (VOCs) are precursors to the formation of ozone and are thus treated as nonattainment pollutants. Any Projects activities resulting in 100 tpy of NOx or 50 tpy of VOC emissions must undergo a General Conformity Determination. Because SO2 and NOx are precursors to PM2.5, any emission increase of 100 tpy or more of PM2.5, SO2, or NOx would also trigger the need for a General Conformity Determination.

We reviewed the criteria pollutant emissions expected to be generated during construction and operation of the Projects, for comparison to the General Conformity thresholds. The results are summarized in table 3 and 4, on a per year basis. As shown, the General Conformity Applicability thresholds would not be exceeded in any nonattainment or maintenance area. Therefore, a General Conformity Determination is not required.

Table 4 Estimated Construction Emissions (tons)

Facilities NOx CO SO2 VOC

PM10

PM2.5

GHG (CO2e)

2015 Construction Pleasant Valley Compressor Station 2.54 0.34 0.004 0.24 3.59 0.51 913

CPV Maryland Interconnect 0.51 0.12 0.001 0.04 1.18 0.14 165 Keys Energy Interconnect N/A N/A N/A N/A N/A N/A N/A

Total for 2015 3.05 0.46 0.005 0.28 4.77 0.65 1,078 2016 Construction

Pleasant Valley Compressor Station 8.92 1.53 0.015 0.86 14.62 1.78 3,140 CPV Maryland Interconnect N/A N/A N/A N/A N/A N/A N/A

Keys Energy Interconnect 0.25 0.06 <0.001 0.02 0.60 0.07 83 Total for 2016 9.17 1.59 0.015 0.88 15.22 1.85 3,222

2017 Construction Pleasant Valley Compressor Station 2.01 0.34 0.003 0.20 3.21 0.40 715

CPV Maryland Interconnect N/A N/A N/A N/A N/A N/A N/A Keys Energy Interconnect 0.25 0.06 <0.001 0.02 0.60 0.07 83

Total for 2017 2.26 0.40 0.003 0.22 3.81 0.47 798 Total All Sites and Years 14.48 2.45 0.023 1.38 23.8 2.97 5,099

7.1.2 Impacts and Mitigation

The Projects would produce air pollutant emissions primarily from construction. Construction at the Pleasant Valley Compressor Station would occur over a 9-month period for the St. Charles Transportation Project (beginning in the third quarter of 2015) and over a 16-month period for the Keys Energy Project (beginning in the first quarter of 2016). Construction of these two projects at the Pleasant Valley Compressor Station would overlap for part of the time. Construction at the CPV Maryland Interconnect (beginning in September 2015) and Keys Energy Interconnect (beginning in January 2016) would each occur over a 6-month period. The air quality


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impacts of project construction are considered short-term. Following construction, air quality would revert back to previous conditions.

7.1.2.1 Construction Impacts and Mitigation

Construction of the Project would result in short-term increases in emissions of some pollutants from the use of fossil fuel-fired equipment and the generation of fugitive dust due to earthmoving activities. Some temporary indirect emissions, attributable to construction workers commuting to and from work sites during construction and from on-road and off-road construction vehicle traffic, could also occur. Large earth-moving equipment and other mobile equipment are sources of combustion-related emissions, including criteria pollutants (i.e., NOx, CO, VOC, SO2, and PM10). Construction emissions are presented in table 4 for both Projects, broken down per calendar year. These emissions present the combined emissions for each facility of construction equipment combustion, on-road vehicle travel, off-road vehicle travel, and earthmoving fugitives. Detailed emissions for each activity are provided in Dominion's Resource Report 9 to its application and supplemental filings.

Construction related emission estimates were based on a typical construction equipment list, hours of operation, and vehicle miles traveled by the construction equipment and supporting vehicles for each area of the Projects. These emission-generating activities would include earthmoving, construction equipment exhaust, on-road vehicle traffic, and off-road vehicle traffic. Dominion conservatively utilized emission factors from EPA's AP-42, along with EPA's NONROAD2008a and MOVES2014 emission modeling softwares.

Although each year and total Projects emissions would be small and would result in short-term impacts, emissions may be further mitigated by implementation of state regulations. Virginia's regulations include provisions for open burning activities and fugitive dust during construction. Similarly, Maryland's regulations include provisions for open burning and mobile source emissions. Implementation of the measures identified in Virginia and Maryland's regulations would further reduce emissions (particularly for NOx, VOC, and particulate matter).

7.1.2.2 Operational Impacts and Mitigation

Because the proposed turbines at the Pleasant Valley Compressor Station are electrically generated, the Projects do not include the installation of any new stationary point sources of air pollutants. Long-term operating emissions of the Projects may result from fugitive emissions or blow-downs at the Pleasant Valley Compressor Station, CPV Maryland Interconnect, and Keys Energy Interconnect, releasing natural gas. Emission estimates from each facility, per year of operation, are presented in table 3. Emissions from operating these facilities would result in minimal long-term air quality impacts.

7.2 Noise

Construction and operation of the Projects would affect the local noise environment in the project area. The ambient sound level of a region, which is defined by the total noise generated within the specific environment, is usually comprised of sounds emanating from both natural and artificial sources. At any location, both the magnitude and frequency of environmental noise may vary considerably over the course of the day and throughout the week, in part due to changing weather conditions and the impacts of seasonal vegetative cover.


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Two measurements used by some federal agencies to relate the time-varying quality of environmental noise to its known effects on people are the equivalent sound level (Leq) and the day-night sound level (Ldn). The Leq is an A-weighted sound level containing the same sound energy as the instantaneous sound levels measured over a specific time period. Noise levels are perceived differently, depending on length of exposure and time of day. The Ldn takes into account the duration and time the noise is encountered. Specifically, in the calculation of the Ldn, late night to early morning (10:00 p.m. to 7:00 a.m.) noise exposures are penalized +10 decibels (dB), to account for people’s greater sensitivity to sound during the nighttime hours. The A-weighted scale (dBA) is used because human hearing is less sensitive to low and high frequencies than mid-range frequencies. For an essentially steady sound source that operates continuously over a 24-hour period and controls the environmental sound level, the Ldn is approximately 6.4 dB above the measured Leq.

In 1974, the EPA published its Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety. This document provides information for state and local governments to use in developing their own ambient noise standards. The EPA has indicated that an Ldn of 55 dBA protects the public from indoor and outdoor activity interference. We have adopted this criterion and use it to evaluate the potential noise impacts from the proposed Projects at noise sensitive areas (NSAs), such as residences, schools, or hospitals. Due to the 10 dBA nighttime penalty added prior to calculation of the Ldn, for a facility to meet the Ldn 55 dBA limit, it must be designed such that actual constant noise levels on a 24-hour basis do not exceed 48.6 dBA Leq at any NSA. Also, in general, a person’s threshold of perception for a perceivable change in loudness on the A-weighted sound level is about 3 dBA, whereas a 5 dBA change is clearly noticeable, and a 10 dBA change is perceived as either twice or half the loud.

Maryland noise regulations require that the sound level at residential property lines should not exceed 65 dBA during the day (7:00 a.m. to 10:00 p.m.) or 55 dBA at night (10:00 p.m. to 7:00 a.m.). For “periodic noise,” which is defined as “a noise possessing a repetitive on-and-off characteristic with a rapid rise to maximum and a short decay not exceeding two seconds,” the allowable levels under Maryland noise regulations are 60 dBA during the day and 50 dBA at night. The FERC criterion of 55 dBA Ldn is generally more stringent for residents than the Maryland State noise requirements. However, in the unusual situation of a house set back on a very large parcel of land, the FERC sound limit could be satisfied at the house and the Maryland noise limit exceeded at the property line. Upon review of the site, existing NSAs, and noise levels for the Projects, this unusual condition does not exist. For construction, the noise standard in Maryland is 90 dBA during daytime hours.

Fairfax County, Virginia noise regulations establish specific prohibited activities as well as maximum permissible sound pressure levels based on land use at the noise source property line or the receiving area. The Fairfax County noise ordinance specifically prohibits operating construction eqipment outdoors between the hours of 9:00 p.m. and 7:00 a.m. the following day, except that no such activity shall commence prior to 9:00 a.m. on Sundays and federal holidays. The operation of power equipment between the hours of 7:00 a.m. and 9:00 p.m. the same day is permitted as long as it does not constitute a noise disturbance. The noise ordinance also limits operational sound pressure levels to 55 dBA in residential areas, 60 dBA in commercial areas, and 72 dBA in industrial areas.


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7.2.1 Existing Noise Conditions

The existing Pleasant Valley Compressor Station currently is comprised of two 3,000 hp electric motor driven reciprocating compressor units. Dominion proposes to add one 7,000 hp electric motor driven reciprocating compressor unit to the existing compressor building as part of the St. Charles Transportation Project. Dominion has also already been authorized, in the previously approved Cove Point Liquefaction Project, to add two 17,400 hp and one 27,700 hp electric driven centrifugal compressor units in a new building, and to add two 100 Mega-volt ampere substation transformers at the Pleasant Valley Compressor Station. In the new compressor building, Dominion also proposes to add one 6,000 hp electric motor driven reciprocating compressor unit as part of the Keys Energy Project.

In February 2013, Dominion conducted noise surveys at the Pleasant Valley Compressor Station property lines and nearest NSAs. Dominion identified 10 NSAs surrounding the compressor station. The nearest residences are 1,750 feet southwest of the station (referred to as NSA-P6). The existing noise levels at each NSA are presented in table 5.

In March, 2015, Dominion also conducted sound survey measurements at the CPV Maryland Interconnect and Keys Energy Interconnect sites. Dominion identified nine NSAs surrounding the CPV Maryland Interconnect site and six NSAs surrounding the Keys Energy Interconnect site. The nearest residence to the CPV Maryland Interconnect site is 450 feet north-northwest (referred to as NSA-CPV6). The nearest residence to the Keys Energy Interconnect site is 350 feet northwest (referred to as NSA-KE6). The existing noise levels at each NSA for each interconnect site are also presented in table 5.

7.2.2 Impacts and Mitigation

7.2.2.1 Construction Noise Impacts and Mitigation

Construction of the facilities would involve operation of general construction equipment and noise would be generated during the installation of the Projects components. Measures to mitigate construction noise would include compliance with federal regulations limiting noise from trucks, proper maintenance of equipment, and ensuring that sound muffling devices provided by the manufacturer are kept in good working condition. Noise levels would increase in the immediate vicinity of the construction activities; however, the noise would be localized and short-term. Nighttime noise levels are not expected to increase during construction because construction activities would g e n e r a l l y be limited to daylight hours.

Construction noise would be highly variable because the types of equipment in use at a construction site changes with the construction phase and the types of activities. Noise from construction activities may be noticeable at nearby NSAs; however, construction equipment would be operated on an as-needed basis during the short-term construction period. Further, Dominion would generally limit construction activities to occur during daytime hours. Because the construction activities for the Pleasant Valley Compressor Station would be limited to daytime hours, the noise would comply with the Fairfax County noise regulation (which allows noise from construction as long as it is within the allowable daytime hours).


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Table 5 Estimated Sound Levels

NSA Distance/ Direction

Existing (Ldn)

St. Charles Project (Ldn)

Keys Energy Project (Ldn)

Cove Point Liquefaction

Project (Ldn)

Total Combined

(Ldn)

Total Increase (dBA)

Pleasant Valley Compressor Station P1 5,000 ft NE 45.9 22.4 22.4 30.4 46.1 0.2 P2 4,000 ft ENE 46.2 25.4 25.4 32.4 46.4 0.2 P3 4,600 ft ESE 44.3 24.4 23.4 30.4 44.5 0.2 P4 4,700 ft SSW 43.6 24.4 22.4 30.4 43.9 0.3 P5 4,400 ft SW 46.0 25.4 23.4 30.4 46.2 0.2 P6 1,750 ft SW 41.8 35.4 33.4 41.4 45.4 3.6 P7 3,400 ft WSW 45.2 27.4 27.4 34.4 45.7 0.5 P8 3,400 ft W 46.5 27.4 27.4 35.4 46.9 0.4 P9 4,100 ft WNW 43.5 25.5 24.4 32.4 43.9 0.4 P10 3,800 ft NW 45.7 26.4 26.4 33.4 46.0 0.3

CPV Maryland Interconnect CPV1 1,200 ft SSE 47.0 26.4 N/A N/A 47.0 <0.1 CPV2 600 ft SSE 52.7 33.4 N/A N/A 52.8 0.1 CPV3 1,200 ft SSW 53.6 26.4 N/A N/A 53.6 <0.1 CPV4 1,100 ft SW 52.2 27.4 N/A N/A 52.2 <0.1 CPV5 550 ft W 52.3 34.4 N/A N/A 52.4 0.1 CPV6 450 ft NNW 50.8 36.4 N/A N/A 51.0 0.2 CPV7 500 ft N 47.6 35.4 N/A N/A 47.9 0.3 CPV8 900 ft NNE 48.4 29.4 N/A N/A 48.5 0.1 CPV9 1,400 ft NNE 49.0 24.4 N/A N/A 49.0 <0.1

Keys Energy Interconnect KE1 450 ft ENE 43.2 N/A 41.4 N/A 45.4 2.2 KE2 800 ft ESE 46.1 N/A 36.4 N/A 46.5 0.4 KE3 550 ft SSE 43.8 N/A 41.4 N/A 45.8 2.0 KE4 700 ft S 45.1 N/A 38.4 N/A 45.9 0.8 KE5 500 ft SSW 45.2 N/A 41.4 N/A 46.7 1.5 KE6 350 ft NW 46.2 N/A 43.4 N/A 48.0 1.8

7.2.2.2 Operational Noise Impacts and Mitigation

Noise would generally be produced on a continuous basis at the Pleasant Valley Compressor Station by the compressor units and associated equipment. A noise analysis for the Pleasant Valley Compressor Station was completed using sound level data for the specific equipment planned for the facility and calculations for the noise attenuation over distance. The results of the noise analysis are summarized in table 5 for the impacts at the nearest NSAs, for compliance with the FERC 55 dBA Ldn noise criterion.

The noise analysis accounts for several noise control measures, including insulation of an acoustically treated compressor building, mufflers, and equipment specific maximum noise levels. As shown in table 5, the noise levels from the modified Pleasant Valley Compressor Station from all three projects combined, including noise mitigation, would be below 55 dBA Ldn at the nearest NSAs. We also reviewed the projected noise levels at the property lines to analyze impacts for


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comparison with the Fairfax County noise ordinance. Projected noise levels from the three combined projects, along with the existing noise levels, would continue to remain below the 55 dBA Fairfax county noise ordinance at residential property boundaries.

Additionally, the estimated noise increase at the nearby NSAs from the Pleasant Valley Compressor Station would range from 0.2 to 0.5 dBA, at all NSAs (except NSA-P6), which is below the 3 dBA threshold of noticeable difference for humans. NSA-P6 would experience a 3.6 dBA increase, which is at the threshold of a noticeable difference for humans, but well below a clearly noticeable change. To further ensure that the actual noise levels resulting from operation of the modified Pleasant Valley Compressor Station are not significant, we recommend that:

Dominion should file noise surveys with the Secretary no later than 60 days after placing each project's modification to Pleasant Valley Compressor Station in service. If a full load condition noise survey is not possible, Dominion should provide an interim survey at the maximum possible horsepower load and provide the full load survey within 6 months. If the noise attributable to the operation of all of the equipment at the compressor station, under interim or full horsepower load conditions, exceeds an Ldn of 55 dBA at any nearby NSAs, Dominion should file a report on what changes are needed and should install the additional noise controls to meet the level within 1 year of the in-service date. Dominion should confirm compliance with the above requirement by filing a second noise survey with the Secretary no later than 60 days after it installs the additional noise controls.

In addition to normal operational noise, there may also be sources of noise due to maintenance or emergency operation. Specifically, emergencies and maintenance activities involve blow downs (depressurizing/emptying station equipment to remove natural gas). Based on information from Dominion, the blow downs at the Pleasant Valley Compressor Station are typically infrequent and may be silenced or unsilenced. Annual testing of the emergency shutdown system would be required and may include unsilenced blow downs. Dominion typically attempts to provide advanced notice to nearby residents at least 2 hours before unsilenced blowdown activity begins. Other activations of the emergency shutdown system due to an emergency are very infrequent (on average less than once per year).

Silenced blow down events are more frequent for scheduled maintenance of the compressor equipment. These scheduled events may occur multiple times per year. Dominion’s blow down silencers would reduce the gas velocity of the exiting gas and muffle the resulting noise to 60 dBA at 50 feet.

A noise analysis was also completed for the CPV Maryland and Keys Energy Interconnects using sound level data for the specific equipment proposed for the facility and calculations for the noise attenuation over distance. The results of the noise analysis are also summarized in table 5 for the impacts at the nearest NSAs, for compliance with the FERC 55 dBA Ldn noise criterion. The noise analysis accounts for several noise control measures, including piping insulation and equipment specific maximum noise levels. As shown in table 5, the noise levels from the interconnects, including noise mitigation, would be below 55 dBA Ldn at the nearest NSAs.


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Additionally, the estimated noise increase at the nearby NSAs would range from less than 0.1 to 0.3 dBA from the CPV Maryland Interconnect site, and 0.4 to 2.2 dBA from the Keys Energy Interconnect, which is below the 3 dBA threshold of noticeable difference for humans. To further ensure that the actual noise levels resulting from operation of the interconnect sites are not significant, we recommend that:

Dominion file noise surveys with the Secretary no later than 60 days after placing the CPV Maryland and Keys Energy Interconnect in-service. If the noise attributable to operation of either interconnect site exceeds an Ldn of 55 dBA at any nearby NSAs, Dominion should file a report on what changes are needed and should install the additional noise controls to meet the level within 1 year of the in-service date. Dominion should confirm compliance with the above requirement by filing a second noise survey with the Secretary no later than 60 days after it installs the additional noise controls.

8.0 RELIABILITY AND SAFETY

A natural gas compressor station or aboveground interconnect site involves some risk to the public in the event of an accident and subsequent release of gas. The greatest hazard is a fire or explosion following a leak, or rupture at the facility. Methane, the primary component of natural gas, is colorless, odorless, and tasteless. It is not toxic, but is classified as a simple asphyxiate, possessing a slight inhalation hazard. If breathed in high concentration, oxygen deficiency can result in serious injury or death.

The modifications to the Pleasant Valley Compressor Station and the new CPV Maryland and Keys Energy Interconnects must be designed, constructed, operated, and maintained in accordance with the DOT Minimum Federal Safety Standards in 49 CFR Part 192. The regulations are intended to ensure adequate protection for the public and to prevent facility accidents and failures, including emergency shutdowns and safety equipment. The DOT’s Pipeline and Hazardous Materials Safety Administration ensures that people and the environment are protected from the risk of pipeline incidents. This work is shared with state agency partners and others at the federal, state, and local level.

The DOT provides for a state agency to assume all aspects of the safety program for intrastate facilities by adopting and enforcing the federal standards. DOT federal inspectors perform inspections and enforce the pipeline safety regulations for interstate gas pipeline facilities in Maryland and Virginia.

The DOT also defines area classifications, based on population density in the vicinity of the pipeline facility, and specifies more rigorous safety requirements for populated areas. The class location unit is an area that extends 220 yards on either side of the centerline of any continuous 1-mile length of pipeline. The four area classifications are defined below:

Class 1 Location with 10 or fewer buildings intended for human occupancy.

Class 2 Location with more than 10 but less than 46 buildings intended for human occupancy.


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Class 3 Location with 46 or more buildings intended for human occupancy or where the pipeline lies within 100 yards of any building, or small well-defined outside area occupied by 20 or more people on at least 5 days a week for 10 weeks in any 12-month period.

Class 4 Location where buildings with four or more stories aboveground are prevalent.

Class locations representing more populated areas require higher safety factors in pipeline design, testing, and operation. The Pleasant Valley Compressor Station is located in a Class 1 area. The CPV Maryland and Keys Energy Interconnects would be located in a Class 3 and Class 2 location, respectively.

Part 192 also requires a pipeline operator to establish a written emergency plan that includes procedures to minimize the hazards in an emergency. Additionally, the operator must establish a continuing education program to enable the public, government officials, and others to recognize an emergency at the facility and report it to appropriate public officials. Dominion would provide the appropriate training to local emergency service personnel before the facilities are placed in service.

The construction and operation of the modified Pleasant Valley Compressor Station and new CPV Maryland and Keys Energy Interconnects would represent a minimum increase in risk to the nearby public and we are confident that with implementation of the required design criteria for the design of these facilities, that they would be constructed and operated safely.

C. CUMULATIVE IMPACTS

Cumulative impacts associated with each project would be the result of multiple projects’ impacts on the resources located near the project areas. Although the individual impact of the separate projects might be minor, the additive or synergistic effects from multiple projects could be significant. Cumulative impact is the incremental impact on the environment of multiple projects occurring within the same timeframe and vicinity as the proposed action. When evaluating cumulative impacts, we consider past, present, and reasonably-foreseeable future projects within the area affected by the proposed project. For this analysis, we considered the county for each project as the main region of influence in which impacts have the potential to be cumulative, extending our review as necessary to the watershed and airshed encompassing the Projects. We also considered one other Dominion Project in Virginia and Maryland (Dominion Cove Point Liquefaction Project).

For these proposed Projects, a variety of active and pending industrial development projects could contribute to potentially significant cumulative impacts. The construction and operation of the related nonjurisdictional facilities, as previously described, are considered in this scope. Natural gas production facilities in the Marcellus shale regions in Pennsylvania, New York, and West Virginia, including hydraulic fracturing, are outside of the geographic scope of the Projects. Therefore, the general cumulative impact of these facilities on environmental resources was not considered.


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1.0 PLEASANT VALLEY COMPRESSOR STATION

On September 29, 2014, the FERC authorized Dominion Cove Point LNG, LP to construct and operate certain facilities at the Pleasant Valley Compressor Station and the Pleasant Valley Suction/Discharge Pipelines to deliver gas to Dominion’s Cove Point LNG Terminal located in Calvert County, Maryland. Construction of the Cove Point Liquefaction Project facilities authorized at the Pleasant Valley Compressor Station has not yet begun. The Cove Point Liquefaction Project facilities in Fairfax County, Virginia includes the installation of additional equipment and facilities including three new electric-driven compressor units totaling up to approximately 62,500 hp at the Pleasant Valley Compressor Station, installation of a new 36-inch-diameter suction line from the Pleasant Valley Compressor Station to a new tap, installation of 36-inch-diameter suction pipeline from the Pleasant Valley Compressor Station to the existing Pleasant Valley M&R, and upgrading the existing 16-inch-diameter discharge pipeline extending from the Pleasant Valley Compressor Station to the existing Pleasant Valley M&R with a new 36-inch-diameter pipeline, and installation of a sound barrier.

A search of Fairfax County’s Comprehensive Plan mapping tool indicates that several other projects are proposed in the vicinity of the Pleasant Valley Compressor Station, including a new arterial on a new location, a metro rail station, a new high school, and a parking lot. The proposed arterial is located approximately one-half mile away from the compressor station, the high school is approximately 3 miles away, and the metro rail station and parking lot are approximately 4 miles away.

The Projects and the Virginia facilities associated with the Cove Point Liquefaction Project would all include new facilities and modification of existing facilities at the Pleasant Valley Compressor Station. The construction of the three projects would overlap in time to minimize construction and resource impacts. Since the construction of the proposed Projects would overlap in time and use the same construction footprint as the authorized Virginia facilities of the Cove Point Liquefaction Project, the proposed Projects would not have any significant additional impacts beyond those already analyzed and authorized.

The areas in Charles County Maryland proposed for both Projects and the construction activities located at and near the Cove Point LNG Terminal are all located approximately 67 miles from the Pleasant Valley Compressor Station.

2.0 CPV MARYLAND INTERCONNECT

CPV Maryland is planning to construct an M&R Station adjacent to the CPV Maryland Interconnect that would be located on a 3.6 acre parcel of land. The M&R Station would be constructed and owned by CPV Maryland but operated by Dominion. CPV Maryland is responsible for obtaining all the necessary permits and approvals for the M&R Station and access road. CPV Maryland is also planning to construct a 1.1 mile long lateral pipeline from the M&R Station to the St. Charles Energy Center generating station.

The generating station would be located approximately 4 miles south of the center of Waldorf and 2.5 miles south of the center of the community of St. Charles on a portion of a pre-existing 76-acre industrial site (Piney Reach Park). Construction of the CPV Maryland M&R Station, lateral pipeline, and generating station are expected to occur prior to the construction of the taps at the CPV Maryland Interconnect.


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3.0 KEYS ENERGY INTERCONNECT

Proposed projects in the vicinity of the Keys Energy Interconnect include the Keys Energy Center lateral pipeline and generating station in Charles County and Prince George’s County, Maryland; the CPV Maryland M&R station, lateral pipeline and generating station in Charles County, Maryland; and the CPV Maryland Interconnect.

The Keys Energy Center generating station will be located approximately 1.25 miles east of Brandywine on a 170-acre site (formerly used for a sand and gravel mining operation) and approximately 8 miles from the Keys Energy Interconnect. Construction of the Keys Energy Center lateral pipeline and generating station are expected to occur during the second half of 2015. All of the construction would overlap in time.

The CPV Maryland M&R Station, lateral pipeline, and generating station, as well as the CPV Maryland Interconnect, would be located in Charles County, Maryland approximately 6 miles from the Keys Energy Interconnect and 9 miles from the Keys Energy Center (Prince George’s County, Maryland). Construction of the CPV Maryland M&R Station, lateral pipeline, and generating station are expected to overlap in time as the construction of the taps at the Keys Energy Interconnect.

4.0 CUMULATIVE IMPACT ANALYSIS

The following discussion will analyze the cumulative impacts on the following resources: geology and soils; waterbodies; vegetation and wildlife; land use and visual resources; and air quality and noise.

4.1 Geology and Soils

Impacts on geology and soils could lead to poor revegetation potential and indirectly affect wildlife and aquatic resources as a result of poor vegetative cover and increased erosion and sedimentation.

Construction of the independent and unrelated Virginia facilities portion of the Cove Point Liquefaction, St. Charles Transportation, and Keys Energy Projects, as well as the nonjurisdictional NOVEC substation expansion at the Pleasant Valley Compressor Station would overlap in time. Dominion anticipates beginning construction of the St. Charles Transportation Project at the Pleasant Valley Compressor Station in September 2015, the Virginia Facilities of the Cove Point Liquefaction Project and the Keys Energy Project in January 2016. The construction of these projects at the same location and within the same timeframe would result in cumulative impacts on the geology and soils on-site, such as increased compaction and/or erosion and sedimentation. However, all construction activity would occur within the existing facility footprint in previously disturbed areas, already modified for industrial use. Construction of the additional compression under the Cove Point Liquefaction Project would impact about 22 acres within the 37-acre property owned by Dominion. Construction of the additional compression proposed under the St. Charles Transportation and Keys Energy Projects would occur within these 22 acres; therefore, there would be no additional cumulative impact on geology and soils with the construction of these Projects.


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To minimize potential impacts on geology and soils during construction of these Projects, Dominion would comply with the erosion control, revegetation, and restoration provisions of Dominion’s Plan and Procedures, as well as site-specific E&SC plans and stormwater management plans developed in cooperation and approved by Fairfax County, Virginia. Collectively, we conclude the project facilities proposed at the existing Pleasant Valley Compressor Station would have minimal impact on existing geologic resources.

The Projects at the Pleasant Valley Compressor Station could potentially be constructed during the same time period as the construction of the arterial, metro rail station, high school, and parking lot projects proposed in Fairfax County, Virginia. The construction of these projects collectively could cumulatively impact geology and soils in the area. As discussed above, Dominion would implement site-specific E&SC and stormwater management plans to mitigate impacts on geology and soils so that the incremental impact of the Projects at the compressor station are minor when added to the impacts of the other proposed projects.

Similarly, construction of the St. Charles generating station (M&R Station, and lateral pipeline), concurrently with the Keys Energy Project (including the Keys Energy Interconnect and M&R Station proposed by Dominion, as well as the generating station proposed by Keys Energy) concurrently with the construction of the CPV Maryland Interconnect could also result in increased cumulative impacts on geology and soils. However, the soil stabilization, revegetation, and restoration requirements included in Dominion’s Plan and Procedures would prevent or minimize any impacts. While there is the potential for cumulative impacts on geology and soils since the various projects would be in close proximity to each other and constructed concurrently, any cumulative impact on these resources would be minimized by the implementation of erosion control and restoration measures during the construction and restoration of the Projects. Consequently, any potential cumulative impacts on geological resources and soils would be temporary and minor.

4.2 Waterbodies

There are three intermittent streams; a single water supply well; and two wetlands, which total about 0.2 acre, at the Pleasant Valley Compressor Station and suction/discharge pipelines. At the CPV Maryland Interconnect there is a single wetland of approximately 1.3 acres, of which 0.3 acre would be temporarily and 0.02 acre would be permanently impacted. At the Keys Energy Interconnect there are no wetlands. There are no water quality issues at either location. The construction of the projects, both authorized and proposed, at the Pleasant Valley Compressor Station in Fairfax County, Virginia and the construction of the proposed St. Charles Transportation and Keys Energy Projects in Charles County, Maryland could cumulatively impact surface waterbodies and wetlands. Impacts could include an increase in sediment loading to surface waterbodies and wetlands, and an increase in internal sediment loading due to channel/floodplain instability as a result of a change in erosion and/or deposition patterns. The level of impact of the proposed Projects on surface waterbodies would depend on precipitation events, sediment loads, stream area/velocity, channel integrity, and bed material.

The Virginia Facilities of the Cove Point Liquefaction Project would temporarily impact 0.07 acre of wetlands during construction of the suction/discharge pipelines. No operational (permanent) impacts on wetlands from the Virginia facilities of the Cove Point Liquefaction Project would occur. There would be no direct impacts on wetlands at the Pleasant Valley


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Compressor Station as a result of the construction or operation of the St. Charles Transportation or Keys Energy Projects. The St. Charles Transportation Project would affect one wetland at the CPV Maryland Interconnect during construction and operation. Construction at the CPV Maryland Interconnect may temporarily impact up to 0.3 acre of wetlands, and operation of the taps may permanently impact 0.02 acre of wetlands. The construction and operation of the Keys Energy taps and M&R Station would not impact any wetlands.

While there is the potential for cumulative impacts on streams and wetlands from construction of the projects collectively due to any increased sediment loading, the geographic extent and duration of disturbances caused by construction of the Projects would be minimal and further minimized by the implementation of measures contained in Dominion’s Plan and Procedures and site specific E&SC plans and stormwater management plans. As a result, the cumulative effects of these projects on surface waterbodies and wetlands are expected to be minor.

The Projects at the Pleasant Valley Compressor Station could potentially be constructed during the same time period as the construction of the arterial, metro rail station, high school, and parking lot projects proposed in Fairfax County, Virginia. The construction of these projects collectively could cumulatively impact waterbodies and wetlands in the area. As discussed above, Dominion would implement site-specific E&SC and stormwater management plans to mitigate impacts on aquatic resources so that the incremental impact of the projects at the compressor station are minor when added to the impacts of the other proposed projects.

4.3 Vegetation and Wildlife

The Pleasant Valley Compressor Station is located in close proximity to the 1,680 acre Elklick Diabase Flatwoods Conservation Site, a site of high significance due to the potential for species of concern to occur including Torrey’s mountain-mint, grove sandwort, and purple milkweed. The Elklick Diabase Flatwoods Conservation Site also is considered important because of the potential presence of sensitive natural habitats. These species and habitats were not observed at the Pleasant Valley Compressor Station during recent surveys. The CPV Maryland Interconnect location is predominately wetlands, and the Keys Energy Interconnect location is open land. Wildlife at both locations includes red fox, groundhogs, mice, voles, shrews, squirrels, skunks, raccoons, opossums, snakes, frogs, turtles, and birds. No rare, threatened, or endangered species were observed at the Pleasant Valley Compressor Station or at either project location in Charles County, Maryland.

Construction activities, including clearing, grading, and excavation may result in the following: removal of vegetation; alteration of wildlife habitat; displacement of wildlife; and other potential secondary effects such as increased population stress, predation, and the establishment of invasive plant species. These effects would be greatest where the Projects are constructed within the same timeframe and in close proximity to each other. Implementation of measures contained in Dominion’s Plan and Procedures would promote revegetation at project areas following construction. Additionally, at the Pleasant Valley Compressor Station facilities approved under the Cove Point Liquefaction Project, Dominion is required to implement an Invasive Species Management Plan during and post-construction. Because construction activities for the Projects would occur in the same areas as the Cove Point Liquefaction Project facilities at the Pleasant Valley Compressor Station, the potential for the


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establishment of invasive plant species would be prevented. As noted, there are no sensitive species likely to be adversely affected. At the CPV Maryland and Keys Energy Interconnects, the cumulative impacts of the Projects would be negligible. Therefore, the cumulative impact of these projects on vegetation and wildlife are expected to be minor.

The projects at the Pleasant Valley Compressor Station could potentially be constructed during the same time period as the construction of the arterial, metro rail station, high school, and parking lot projects proposed in Fairfax County, Virginia. The construction of these projects collectively could cumulatively impact vegetation and wildlife resources in the area. As discussed above, Dominion would revegetate project areas following construction and implement an Invasive Species Management Plan to mitigate impacts on vegetation and wildlife so that the incremental impact of the projects at the compressor station are minor when added to the impacts of the other proposed projects.

4.4 Land Use and Visual Resources

Construction activities for the Projects at the existing Pleasant Valley Compressor Station would all be within the existing facility footprint and within the same 22-acre area. Construction activities at the CPV Maryland Interconnect would be within an existing Dominion right-of-way, and construction of the Keys Energy Interconnect would occur on open land adjacent to Dominion’s right-of-way. Construction of project facilities at these locations is consistent with the existing industrial uses. The CPV Maryland St. Charles Energy Center would disturb additional acres of land affecting some undeveloped land and an existing industrial site. The Keys Energy Center would disturb additional acres of land affecting some undeveloped land and a former sand and gravel mining site

The visual character of the existing landscape for the Projects is defined by historic and current land uses such as agricultural, recreation, conservation, and industrial development. The visual qualities of the landscape are further influenced by existing linear installations such as highways, railroads, pipelines, and electrical transmission and distribution lines. Within this context, aboveground facilities would have the most visual impact, while pipelines would be visually consistent with the existing landscape character and would contribute only incrementally to overall visual conditions, particularly after completion of reclamation and the reestablishment of vegetation.

The cumulative impact of these Projects on land use and aesthetics is expected to be minor. To minimize potential impacts, Dominion would maintain the existing forested buffer along the Pleasant Valley Compressor Station property boundary and minimize nighttime lighting outside of fenced areas. To minimize impacts on the visual quality at the Keys Energy Interconnect, Dominion would add landscaping and vegetative screening of the project facilities, as needed.

The Projects at the Pleasant Valley Compressor Station could potentially be constructed during the same time period as the construction of the arterial, metro rail station, high school, and parking lot projects proposed in Fairfax County, Virginia. The construction of these additional projects within the same time frame and within the same geographic area could cumulatively impact land use and aesthetics. As discussed above, Dominion would maintain forested buffers, and minimize nighttime lighting to mitigate impacts on land use and aesthetics so that the incremental impact of the Projects at the compressor station are minor when added to the impacts of the other proposed projects.


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4.5 Socioeconomics

The Projects are located in sparsely populated areas, so impacts on nearby residences during construction and operation of the Projects is anticipated to be insignificant. Construction of each of the projects would generate temporary construction jobs. The local supply of construction workers needed for these projects may be derived from workers employed in the area, which would provide a direct economic benefit to those individuals and the communities in which they reside. The non-local laborers could represent a temporary increase in the percent of the total population in the project areas; however, the potentially vacant rental units available in the project areas would offer enough housing for non-local workers. While construction traffic may increase during the construction period as a result of various projects being constructed in the same location at the same time, there would be no long-term impacts on traffic, transportation, or public services.

The Projects at the Pleasant Valley Compressor Station could potentially be constructed during the same time period as the construction of the arterial, metro rail station, high school, and parking lot projects proposed in Fairfax County, Virginia. The construction of these additional projects within the same time frame and within the same geographic area could cumulatively impact nearby residences, the local supply of construction workers, traffic, transportation, and public services. The incremental impact of the Projects at the compressor station to these resources is minor when added to the impacts of the other proposed projects.

4.6 Cultural Resources

No cultural resources have been identified at the Pleasant Valley Compressor Station in Fairfax County, Virginia or at any of the project locations in Charles County, Maryland. There would be no impact on cultural resources at any of the authorized or proposed projects. Dominion has prepared an Unanticipated Discovery Plan, which guides how unanticipated discoveries of cultural resources would be handled. Additionally, the currently proposed Projects discussed above that are defined as federal actions would include mitigation measures designed to avoid or minimize potential direct impacts on cultural resources. Non-federal actions would comply with any mitigation measures required by the affected states.

The Projects at the Pleasant Valley Compressor Station could potentially be constructed during the same time period as the construction of the arterial, metro rail station, high school, and parking lot projects also proposed in Fairfax County, Virginia. The construction of these additional projects within the same time frame and within the same geographic area could cumulatively impact the area’s cultural resources. The impact of the Projects at the compressor station to cultural resources would be limited to impacts on any unanticipated discoveries, which would be mitigated by the implementation of an Unanticipated Discoveries Plan. There are no existing cultural resources at the Pleasant Valley Compressor Station that would be impacted by the Projects; therefore, the incremental impacts of Projects at the compressor station are minor when added to the impacts of the other proposed projects.

4.7 Air Quality and Noise

Because the Pleasant Valley Compressor Station modifications would include electric motor driven compressors, the facility would not contribute significant additional air emissions during operation. Construction of modified Pleasant Valley Compressor Station for the St. Charles Transportation Project, Keys Energy Project, and Cove Point Liquefaction Project would


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contribute short-term, localized impacts on air quality beginning in the third quarter of 2015, and overlapping in construction for all three projects. The projects and other identified county projects would involve the use of heavy equipment that would generate emissions of air contaminants, fugitive dust, and noise. Several of the other identified county projects would not overlap in construction timing (e.g. the metro rail station completed construction and began operating in mid-2014 and the new high school is not expected to receive funding until year 2021). Further, the other identified county projects (new arterial, metro rail station, new high school, and parking lot) are more than ½ mile away and would not result in cumulative air quality or noise construction impacts given the localized nature of construction emissions and noise.

Section B.7.1 identifies the combined St. Charles Transportation and Keys Energy Projects construction emissions at the compressor station for each calendar year. The modifications to the Pleasant Valley Compressor Station for the Cove Point Liquefaction Project would occur in 2016 and 2017. The combined emissions from all three projects for each calendar year would be below the general conformity thresholds (used for any one individual project). Further, Dominion would implement a fugitive dust control plan, and adherence to Virginia’s open burning and fugitive dust regulations would further reduce emissions at the site. The combined emissions would contribute to short-term, localized air impacts and air quality would revert back to previous conditions following construction.

While the generating stations would contribute long-term operating air emissions to the region, the CPV Maryland and Keys Energy Interconnects would emit minimal emissions and would not significantly affect cumulative air quality during operation. Construction of these facilities would also contribute insignificant combined emissions in Charles County resulting in short-term, minor, localized impacts on air quality beginning in September 2015. Construction of these facilities may overlap in time and area with the CPV Maryland Meter and Regulating Station and lateral pipeline, and the Keys Energy lateral pipeline. Construction of CPV Maryland and Keys Energy Interconnects would not contribute significantly to air quality impacts and combined emissions with the other CPV Maryland and Keys Energy Interconnect facilities may contribute to short-term, localized air impacts. However, air quality would revert back to previous conditions following construction.

As identified above, noise impacts from construction of the modified Pleasant Valley Compressor Station, under the three Dominion projects, would not overlap with other county planned projects. The modified compressor station would result in localized noise impacts. Section B.7.2 includes a combined noise analysis for all three Projects and the existing background noise levels in the area. Further, we have recommended that Dominion perform a noise survey following completion of each project to demonstrate that the entire compressor station does not exceed our 55 dBA Ldn noise criterion. Therefore, noise impacts from operation of all modifications to the Pleasant Valley Compressor Station would not be significant.

The new interconnects would result in localized noise impacts and would be located over one mile away from the generating stations. Because of the localized nature of operating noise from the interconnects, there would be no cumulative noise impacts with the generating stations. Section B.7.2 includes a combined noise analysis for each interconnect and the existing background noise levels in the area. Further, we have recommended that Dominion perform a noise survey following completion of each interconnect to demonstrate that the facilities do not


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exceed our 55 dBA Ldn noise criterion. Therefore, noise impacts from operation of the CPV Maryland and Keys Energy Interconnects would not be significant.

4.8 Conclusion

We identified recently completed, ongoing, and planned projects in the project area that met the critieria for inclusion in the cumulative impacts analysis. Cumulative impacts on air quality and noise are possible, but the impacts are expected to be limited to the time of the Projects construction. In addition, implementation of BMPs, engineering controls, resource protection, and Dominion’s proposed mitigation including its Plan, Procedures, and E&SC Plan would minimize environmental impacts for the Projects. This would mean that when the impacts of the Projects are added to the impacts from other identified projects, the cumulative impacts would be minimal.

D. ALTERNATIVES

1.0 INTRODUCTION

In accordance with NEPA and Commission policy, we identified and evaluated alternatives to the Projects to determine whether they would be reasonable and environmentally preferable to the proposed action. These alternatives include the no action alternative, system alternatives, and compressor station site alternatives. The criteria used for selecting potentially environmentally preferable alternatives are: the ability to meet the Projects objectives; technical and economic feasibility and practicality; and significant environmental advantage over the proposed Projects.

2.0 NO ACTION ALTERNATIVE

The no-action alternative would consist of not constructing the Projects and continuing with the status quo. No action would limit use of the Pleasant Valley Compressor Station and the TL-522 and TL-532 pipelines to the compression and transmission of existing natural gas supplies only. Although no action would eliminate or delay any potential environmental impacts of the Projects, the objectives of the Projects would not be met, to provide additional natural gas supplies to CPV Maryland and Keys Energy.

Under the no-action alternative, other natural gas transmission companies could propose to construct new facilities to provide additional natural gas supplies to CPV Maryland and Keys Energy. As described below, such actions would likely result in impacts similar to or greater than those associated with the Projects, and might not meet the Project’s objectives within the proposed timeframes. Therefore, the no-action alternative is not practical and provides no advantage over the proposed Projects.

3.0 SYSTEM ALTERNATIVES

The purpose of identifying and evaluating system alternatives is to determine whether the environmental impacts associated with the construction and operation of the proposed Project could be avoided or reduced by using existing, modified, or other proposed facilities rather than constructing new facilities. System alternatives are alternatives that are able to meet the objectives of the Projects, but use a different facility (existing or proposed), or are able to otherwise use existing infrastructure to eliminate the need for the proposed facility. However, a viable system alternative must be technically and economically feasible and practicable, and must satisfy


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interconnect requirements and the anticipated in-service date to fulfill commitments made to the Projects customers.

3.1 Existing Systems

The only existing interstate natural gas pipelines in the vicinity of the proposed CPV Maryland and Keys Energy generating stations are DCP’s TL-522 and TL-532 pipelines, which are located approximately one mile from St. Charles Energy Center and 8 miles from the Keys Energy Center. No other pipeline system could supply the proposed power stations with the necessary natural gas supplies without additional significant environmental impact. More specifically, for another facility, such as the Columbia Gas Transmission pipeline or the Transcontinental Gas Pipeline Company (Transco) pipeline to meet the natural gas demand of the proposed power stations, approximately 39 to 40 miles of new pipeline connections would need to be constructed to deliver the gas. Consequently, any system alternative involving transportation by a pipeline and/or facility other than the facilities proposed for the Projects would likely require additional pipeline construction and result in greater environmental impacts, and/or would not meet the Projects purpose and customers’ need for supply diversity.

3.2 Modified Systems

To increase the throughput capacity of a natural gas pipeline, a pipeline operator can “loop” the existing pipeline, or add compression, or use a combination of compression and looping. As natural gas travels down the pipeline, pressure within the pipe declines with distance. Compressor stations are used to restore pressure and increase pipeline capacity beyond that of the pipe alone. The term looping refers to placing additional segments of pipeline parallel and connected to the existing pipeline. These segments act to reduce the rate of pressure drop in the pipe due to friction, and thereby increase the throughput capacity of the pipeline. Compressor stations can also be added to restore pipeline pressures more frequently along the pipeline, again thereby increasing the throughput capacity of the pipeline.

Looping modifications could be made to Dominion’s TL-522 and TL-532 pipelines to reduce the need for additional compression at the Pleasant Valley Compressor Station. However, compression is needed due to the fact that the pipeline delivering gas into Dominion’s system is not expected to deliver it at a pressure sufficient to: 1) enter into Dominion’s main pipeline system or 2) meet the contractual delivery pressure for the Projects. Therefore, pipeline looping by itself is not a viable alternative.

Based on hydraulic modeling of its system to determine alternate facilities that could be used to perform the additional transportation service needs, alternate facilities required approximately 2,750 hp of compression at Dominion’s existing Pleasant Valley Compressor Station and approximately 41 miles of 16-inch-diameter pipeline from the compressor station to the St. Charles Interconnect and 3,550 hp of compression at Pleasant Valley Compressor Station and approximately 46 miles of 16-inch-diameter pipeline from the compressor station to the interconnect with the Keys Energy Interconnect. The 16-inch-diameter pipeline loop would parallel Dominion’s existing TL-522 and TL-532 pipelines. Building this length of pipeline loop would have greater environmental impact than the proposed Projects. Specifically, constructing approximately 41 miles of new pipeline loop would likely impact over 350 acres of land for the St. Charles Transportation Project, and 46 miles of new pipeline loop would likely impact over 400 acres of land for the Keys Energy Project, assuming a 75-foot-wide construction right-of-way is


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used. Based on the greater amount of environmental impact these alternatives would require, these alternatives are not considered a viable option.

3.3 Compressor Station Site Alternatives

Dominion could either add compression at a new greenfield station or at an existing station – its Loudoun Compressor Station and/or Pleasant Valley Compressor Station. A new greenfield compressor station would require land acquisition and the conversion of existing agricultural, forest, and/or open land to industrial use. Assuming approximately 15 to 25 acres for a new greenfield station site and parking, and 20 acres for temporary construction activities, a minimum of approximately 35 acres of land would be needed to construct and operate a new greenfield station site. In addition, using previously undeveloped land for a compressor station would require construction of a pipeline interconnect, which would result in additional environmental impacts above and beyond those of the greenfield compressor station. For these reasons, a new greenfield compressor station would not be the preferred alternative.

The Loudoun Compressor Station is located at one end of the TL-522 pipeline approximately 13 miles to the northwest of the Pleasant Valley Compressor Station. We considered adding compression at this station instead of at the proposed Pleasant Valley Compressor Station. However, the Projects are designed to recover gas at Transco’s interconnect at Pleasant Valley Compressor Station. The Projects’ hp would be used to compress additional gas from Transco (a lower pressure system) into Dominion (a higher pressure system). Since the proposal requires the minimal amount of facilities to transport gas to Dominion’s customers, we did not consider the use of the Loudoun Compressor Station further.


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E. CONCLUSIONS AND RECOMENDATIONS

Based on the analysis in this EA, we have determined that if Dominion constructs and operates the proposed facilities in accordance with their applications and supplements and the staff's recommended mitigation measures, approval of these proposals would not constitute a major federal action significantly affecting the quality of the human environment. We recommend that the Commission's Order contain a finding of no significant impact and include the mitigation measures listed below as conditions to any Certificate the Commission may issue.

1. Dominion shall follow the construction procedures and mitigation measures described in their applications and supplements (including responses to staff data requests) and as identified in the EA, unless modified by the Order. Dominion must:

a. request any modification to these procedures, measures, or conditions in a filing with the Secretary;

b. justify each modification relative to site-specific conditions; c. explain how that modification provides an equal or greater level of environmental

protection than the original measure; and d. receive approval in writing from the Director of OEP before using that

modification.

2. The Director of OEP has delegated authority to take whatever steps are necessary to ensure the protection of all environmental resources during construction and operation of the Projects. This authority shall allow:

a. the modification of conditions of the Order; and b. the design and implementation of any additional measures deemed necessary

(including stop-work authority) to assure continued compliance with the intent of the environmental conditions as well as the avoidance or mitigation of adverse environmental impact resulting from project construction and operation.

3. Prior to any construction, Dominion shall each file an affirmative statement with the Secretary, certified by a senior company official, that all company personnel, EIs, and contractor personnel will be informed of the EI’s authority and have been or will be trained on the implementation of the environmental mitigation measures appropriate to their jobs before becoming involved with construction and restoration activities.

4. The authorized facility locations shall be as shown in the EA, as supplemented by filed alignment sheets. As soon as they are available, and before the start of construction, Dominion shall file with the Secretary any revised detailed survey alignment maps/sheets at a scale not smaller than 1:6,000 with station positions for all facilities approved by the Order. All requests for modifications of environmental conditions of the Order or site-specific clearances must be written and must reference locations designated on these alignment maps/sheets. Dominion’s exercise of eminent domain authority granted under NGA section 7(h) in any condemnation proceedings related to the Order must be consistent with these authorized


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facilities and locations. Dominion’s right of eminent domain granted under NGA section 7(h) does not authorize them to increase the size of their natural gas facilities to accommodate future needs or to acquire a right-of-way for a pipeline to transport a commodity other than natural gas.

5. Dominion shall each file with the Secretary detailed alignment maps and aerial photographs at a scale not smaller than 1: 6,000 identifying all facility relocations, and staging areas, pipe storage yards, new access roads, and other areas that would be used or disturbed and have not been previously identified in filings with the Secretary. Approval for each of these areas must be explicitly requested in writing. For each area, the request must include a description of the existing land use/cover type, documentation of landowner approval, whether any cultural resources or federally listed threatened or endangered species would be affected, and whether any other environmentally sensitive areas are within or abutting the area. All areas shall be clearly identified on the maps/aerial photographs. Each area must be approved in writing by the Director of OEP before construction in or near that area. This requirement does not apply to extra workspace allowed by Dominion’s Plan and/or minor field realignments per landowner needs and requirements which do not affect other landowners or sensitive environmental areas such as wetlands. Examples of alterations requiring approval include all facility location changes resulting from: a. implementation of cultural resources mitigation measures; b. implementation of endangered, threatened, or special concern species mitigation

measures; c. recommendations by state regulatory authorities; and d. agreements with individual landowners that affect other landowners or could affect

sensitive environmental areas.

6. Within 60 days of the acceptance of the Certificate and before construction begins, Dominion shall file an Implementation Plan for the respective Projects with the Secretary for review and written approval by the Director of OEP. Dominion must file revisions to their plan as schedules change. The plan shall identify: a. how the company will implement the construction procedures and mitigation

measures described in its applications and supplements (including responses to staff data requests), identified in the EA, and required by the Order;

b. how the company will incorporate these requirements into the contract bid documents, construction contracts (especially penalty clauses and specifications), and construction drawings so that the mitigation required at each site is clear to onsite construction and inspection personnel;

c. the number of EIs assigned, and how the company will ensure that sufficient personnel are available to implement the environmental mitigation;

d. company personnel, including EIs and contractors, who will receive copies of the appropriate material;


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e. the location and dates of the environmental compliance training and instructions the company will give to all personnel involved with construction and restoration (initial and refresher training as the Projects progresses and personnel change);

f. the company personnel (if known) and specific portion of the company’s organization having responsibility for compliance;

g. the procedures (including use of contract penalties) the company will follow if noncompliance occurs; and

h. for each discrete facility, a Gantt or PERT chart (or similar project scheduling diagram), and dates for:

(1) the completion of all required surveys and reports; (2) the environmental compliance training of onsite personnel; (3) the start of construction; and (4) the start and completion of restoration.

7. Beginning with the filing of its Implementation Plan, Dominion shall file updated status reports for the Projects with the Secretary on a monthly basis until all construction and restoration activities are complete. On request, these status reports will also be provided to other federal and state agencies with permitting responsibilities. Status reports shall include: a. an update on efforts to obtain the necessary federal authorizations; b. the construction status of the Projects, work planned for the following reporting

period, and any schedule changes for stream crossings or work in other environmentally-sensitive areas;

c. a listing of all problems encountered and each instance of noncompliance observed by the EI(s) during the reporting period (both for the conditions imposed by the Commission and any environmental conditions/permit requirements imposed by other federal, state, or local agencies);

d. a description of the corrective actions implemented in response to all instances of noncompliance, and their cost;

e. the effectiveness of all corrective actions implemented; f. a description of any landowner/resident complaints which may relate to compliance

with the requirements of the Order, and the measures taken to satisfy their concerns; and

g. copies of any correspondence received by the company from other federal, state, or local permitting agencies concerning instances of noncompliance, and National Fuel’s or TGP’s response.

8. Prior to receiving written authorization from the Director of OEP to commence construction of its respective project facilities, Dominion shall file with the Secretary documentation that it has received all applicable authorizations required under federal law (or evidence of waiver thereof).

9. Dominion must receive written authorization from the Director of OEP before placing its Projects into service. Such authorization will only be granted following a determination that rehabilitation and restoration of the areas affected by the Projects are proceeding satisfactorily.


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10. Within 30 days of placing their respective authorized facilities in service, Dominion shall file an affirmative statement with the Secretary, certified by a senior company official: a. that the facilities have been constructed in compliance with all applicable

conditions, and that continuing activities will be consistent with all applicable conditions; or

b. identifying which of the Certificate conditions Dominion has complied with or will comply with. This statement shall also identify any areas affected by the project where compliance measures were not properly implemented, if not previously identified in filed status reports, and the reason for noncompliance.

11. Before construction, Dominion shall file with the Secretary of the Commission (Secretary) a revised plot plan for the CPV Maryland Interconnect for review and approval of the Director of the Office of Energy Projects (OEP) to avoid direct wetland impacts; or provide documentation from the USACE and MDE that its permit allows its placement in the wetland.

12. Prior to construction, Dominion shall file the documentation of concurrence from the MDE that the project facilities are consistent with and the Maryland Coastal Zone Management Program.

13. Dominion shall file noise surveys with the Secretary no later than 60 days after placing each project's modification to Pleasant Valley Compressor Station in service. If a full load condition noise survey is not possible, Dominion shall provide an interim survey at the maximum possible horsepower load and provide the full load survey within 6 months. If the noise attributable to the operation of all of the equipment at the compressor station, under interim or full horsepower load conditions, exceeds an Ldn of 55 dBA at any nearby NSAs, Dominion shall file a report on what changes are needed and shall install the additional noise controls to meet the level within 1 year of the in-service date. Dominion shall confirm compliance with the above requirement by filing a second noise survey with the Secretary no later than 60 days after it installs the additional noise controls.

14. Dominion shall file noise surveys with the Secretary no later than 60 days after

placing the CPV Maryland and Keys Energy Interconnect in-service. If the noise attributable to operation of either interconnect site exceeds an Ldn of 55 dBA at any nearby NSAs, Dominion shall file a report on what changes are needed and shall install the additional noise controls to meet the level within 1 year of the in-service date. Dominion shall confirm compliance with the above requirement by filing a second noise survey with the Secretary no later than 60 days after it installs the additional noise controls.


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F. REFERENCES

U.S. Energy Information Administration. 2014. Annual Energy Outlook. April 2014. http://www.eia.doe.gov/oiaf/aeo/index.html. Accessed November 6, 2014. Maryland Department of the Environment. 2014. Maryland’s Draft 2014 Integrated Report of

Surface Water Quality. Baltimore, Maryland. Maryland Department of Natural Resources. May 2001. A Guide to the Conservation of Forest Interior Dwelling Birds in the Chesapeake Bay Critical Area. Website:

http://www.dnr.state.md.us/criticalarea/pdfs/tweetyjune_2000.pdf. Accessed June 2014. Maryland Department of Planning. 2010. Land Use/Land Cover. One Maryland One Map. Website: http://www.mdp.state.md.us/OurWork/landUseIMap.shtml. Accessed June 10, 2014. Radbruch-Hall, D.H., R.B. Colton, W.E. Davies, Ivo Lucchitta, B.A. Skipp, and D.J. Varnes.

1982. Landslide Overview Map of the Conterminous United States, Geological Survey Professional Paper 1183. U.S. Geological Survey, Washington.

Reger, J.P., Cleaves, E.T. 2008. Explanatory Text for the Physiographic Map of Maryland. State

of Maryland, Maryland Department of Natural Resources, and Maryland Geological Survey.

USGS. 2011. EHP Quaternary Faults. Geologic Hazards Science Center.

http://geohazards.usgs.gov/qfaults/map.php. Accessed June 2014. USGS. 2012. National Atlas Map Maker, Geology, Landslide Incidence and Susceptibility.

http://www.nationalatlas.gov/mapmaker. Accessed June 2014. Virginia Department of Environmental Quality and Virginia Department of Conservation and

Recreation. 2014. Virginia 305(b)/303(d) Water Quality Integrated Report to Congress and the EPA Administrator for the Period January 1, 2005 to December 31, 2010. Richmond, Virginia. January 2014.

Virginia Department of Conservation and Recreation. 2013. Email from S. Rene Hypes, Project

Review Coordinator, Division of Natural Heritage dated October 30, 2013 to Jennifer C. Broush. Filed as accession number 20131118-5085 under FERC Docket no. CP13-113.

William and Mary Department of Geology. N.d. Piedmont Province, The Geology of Virginia.

http://web.wm.edu/geology/virginia/provinces/piedmont/piedmont.html. Accessed June 2012.


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G. LIST OF PREPARERS

Nancy Fox-Fernandez – Project Manager: Project Description, Water Resources and Wetlands, Vegetation, Wildlife, Special Status Species, Geology and Soils, Land Use, Alternatives, Cumulative Impacts.

M.S., Natural Resources: Wildlife, 2006, Humboldt State University B.A., Psychology, 1993, Skidmore College

Suter, Magdalene – Air Quality and Noise, Reliability and Safety B.S., Environmental Systems Engineering, 2004, The Pennsylvania State University Howard, Eric – Cultural Resources M.A., Anthropology, 1997, University of Tennessee B.A., Anthropology, 1992, University of Tennessee


Appendix

Figures


Figure 1

St. Charles Transportation General Location Map


Figure 2

Keys Energy Project General Location Map


Figure 3 Pleasant Valley Compressor Station Project Area


Figure 4

CPV Maryland Interconnect Project Area


Figure 5 Keys Energy Interconnect Project Area


Figure 6 Wetland Delineation Map of Pleasant Valley Compressor Station


Document Content(s)

EA_CP15-22_24_final.PDF...............................................1-68
