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STATE OF VERMONT

PUBLIC SERVICE BOARD

Petition of Beaver Wood Energy Pownal, LLC )


for a Certificate of Public Good, pursuant to 30
V.S.A. § 248, to install and operate a Biomass
Energy Facility and an integrated wood pellet )
manufacturing facility located north of the old Docket No
)
Green Mountain Racetrack in Pownal, Vermont, )
to be known as the “Pownal Biomass Project” )

PRE-FILED TESTIMONY OF
MEDDlE PERRY

ON BEHALF OF
BEAVER WOOD ENERGY POWNAL, LLC

October 25, 2010

The purpose of the pre-filed testimony of Mr. Perry is to demonstrate that the propos
ed
Pownal Biomass Project will comply with certain provisions of 30 VS.A. 248
§
namely those pertaining to headwaters, waste disposal, floodways, streams, shoreli
(b) (5).
nes,
water supply for the Project, and burden on existing water supplies.
TABLE OF CONTENTS

1. Introduction
.1
2. Summary of Findings
4
3. Conclusion
12

EXHIBITS

Petitioner’s Exhibit MP-1 Resumé of Meddle Perry

Petitioner’s Exhibit MP-2 Groundwater Withdrawal Permit Application

Petitioner’s Exhibit MP-3 Underground Injection Control Permit Application

Petitioner’s Exhibit MP-4 Flood Zone Maps

Petitioner’s Exhibit MP-5 Hoosic River Process Water Intake: De Minimis

Petitioner’s Exhibit MP-6 Source Protection Plan: Potable Water Supply Well

Petitioner’s Exhibit MP-7 Two-Year Travel Analysis: Domestic Wastewater


STATE OF VERMONT
PUBLIC SERVICE BOARD

Petition of Beaver Wood Energy Pownal, LLC


for a Certificate of Public Good, pursuant to 30
V.S.A. § 248, to install and operate a Biomass
)
Energy Facility and an integrated wood pellet
) Docket No
manufacturing facility located north of the old
Green Mountain Racetrack in Pownal, Vermont, )
to be known as the “Project”

PRE-FILED TESTIMONY OF
MEDDlE PERRY

ON BEHALF OF
BEAVER WOOD ENERGY POWNAL, LLC

1 1. Introduction

2 Ql. Please state your name, business address and employment.

3 Al. My name is Arneddia t


’(
Meddie”) John Perry, and I am a senior hydrogeologist at

4 Vanasse Hangen Brustlin (VHB). My business address is 7056 U.S.


Route 7,
5 North Ferrisburgh, Vermont. My full resumé is provided as Petitioner’s
Exhibit
6 MR-i.

7 Q2. Please describe your educational background and professional experie


nce.
_____

Pownal Biomass Project, PSB Docket No.


Prefiled Testimony of Meddie Perry
October 25, 2010
Page 2 of 12

1 A2. My educational background includes a bachelor of science degree which


I
2 received in 1995 from St. Lawrence University in Canton, NY in the
fields of
3 environmental science and biology. I have taken additional coursework
in
4 hydrology and hydrogeology at the University of Vermont at the graduate
level,
5 as well as continuing education courses for hydrogeologists. I have been

6 employed as a consulting hydrogeologist in Vermont since 1996 and


in that
7 capacity I have managed dozens of hydrogeologic studies which have
evaluated
8 safe yields of underground water sources; the effects to aquifers and water

9 supplies caused by developments, water supply wells, and contamination


sources;
10 land-based disposal of wastewater and its impacts to groundwater and
surface
11 water quality; and have evaluated effects of water withdrawals to surface
water
12 hydrology. I have been certified by the National Groundwater Associ
ation as a
13 Certified Groundwater Professional (CGWP).

14
_____

Pownal Biomass Project, PSB Docket No.


Prefiled Testimony of Meddle Perry
October 25, 2010
Page 3 of 12

1 More specifically, projects which I have managed include successful explor


ation
2 for aquifers and drilling locations for high yielding bedrock and gravel
wells,
3 determinations of the safe yield of gravel and bedrock aquifers for public
supply
4 wells, delineations of wells’ capture zones, recharge areas, and wellhead

5 protection areas, evaluations of the impacts of high yielding wells on existin


g
6 water sources, and studies of the hydrology of surface waters as they relate
to
7 flooding, stormwater, and water withdrawals. My professional experience

8 encompasses data collection and field work as well as project design and

9 plaiming, data analysis and interpretation, reporting, and expert testimo


ny.
10 Q3. What is the purpose of your testimony?

11 A3. The purpose of my testimony is to demonstrate that the Pownal Bioma


ss Project
12 (the “Project”) satisfies the requirements of 30 V.S.A.
§ 248(b)(5). Section
13 248(bX5) provides, in pertinent part, that a generation or transmission facility

14 should not have an undue adverse effect on water purity or the


natural
15 environment, with due consideration having been given to the criteria
specified in
16 10 V.S.A. § 1424a(d) (Outstanding Resource Waters) and 6086(a)(1)
§ through
17 (8) and (9)(K) (various Act 250 criteria). My testimony specifically covers

18 Headwaters [ 6086(a)(1)(A)J, Waste Disposal


[ 6086(a)(l)(B)], Floodways [
19 6086(a)(1)(D)J, Streams [ 6086(a)(1)(E)J. Shorelines
[ 6086(a)(1)(F)], Water
20 Supply for the Project [ 6086(a)(2)], and Burden on Existing Water
Supplies [
21 6086(a)(3)J.
_____

Pownal Biomass Project, P58 Docket No.


Prefiled Testimony of Meddie Perry
October 25, 2010
Page 4 of 12

1 My colleague, Adam Crary, a professional wetland scientist, provides testimo


ny
2 related to Streams [ 6086(a)(1)(E)1, Wetlands [ 6086(a)(1)(G)j, Rare and
3 Irreplaceable Natural Areas [ 6086(a)(8)J, and Necessary Wildlife Habitat and
4 Endangered Species [ 6086 (a)(8)(A)1.
5

6 Q4. Have you testified previously before the Board?

7 A4. Yes. Previously I have testified regarding an application for a Certifi


cate of
8 Public Good for Bolton Valley Water and Sewer. Additionally, I have
testified in
9 my capacity as a hydrogeologist for numerous Act 250 hearings betwee
n 1997
10 and 2010 concerning criteria regarding Waste Disposal
[ 6086(a)(1)(B)].
11 Floodways [ 6086(a)(1)(D)], Streams [ 6086(a)(1)(E)1, Water Supply for the
12 Project [ 6086(a)(2)1. arid Burden on Existing Water Supplies [ 6086(a)(3)].
13

14 2. Summary of F’indin2s

15 Q5. Based upon your evaluation and analyses, does the Project comply with
Section
16 248?

17 A5. Yes. The project complies with the Headwaters criterion


[ 6086(a)(1)(A)J
18 because the site is not in a headwaters location. It complies with the \Vaste

19 Disposal criterion [ 6086(a)(1)(B)], with respect to the disposal of process


20 wastewater, because an on-site soil-based wastewater infiltration system
has been
21 designed that meets the requirements of the Vermont Underground
Injection
22 Control Rule (Chapter 13 of the Environmental Protection Rules), and
a permit
_____

Pownal Biomass Project, PSB Docket No.


Prefiled Testimony of Meddie Perry
October 25, 2010
Page 5 of 12

1 application is pending. With respect to domestic sewage, it complies with


DEC
2 regulations including the maintenance of adequate separation distances to existin
g
3 water supplies. Engineers from Bruno Associates and from Beaver Wood
Energy
4 Pownal, LLC will testify regarding other wastes from the Project. The
Project
5 meets the Floodways criterion [ 6086(a)(1)(D)1 because the above-grade
6 development is being proposed for locations that are outside the
regulatory
7 floodway, and outside the Fluvial Erosion Hazard (FEll) area; and becaus
e the
8 Project conforms to the Vermont ANK’s Technical Guidance for Determ
ining
9 Floodway Limits Pursuant to Act 250 Criterion 1(D) (October 9, 2009).
The
10 Project complies with the Streams criterion 6086(a)(1)(E)j because
11 withdrawals of water from the 1-loosic River will maintain natural flow
conditions
12 downstream, the intake has been designed to avoid fish impingement, and
because
13 the withdrawal is being permitted by the Vermont DEC as a de
minimis
14 withdrawal due to its very small size in relation to the River at the site. The

15 Project complies with the Shorelines criterion


[ 6086(a)(1)(F)J, because the
16 development is not on a shoreline, and the Project will retain the Hoosic
River
17 shoreline in natural condition. The Project complies with the Water Supply for
18 the Project criterion [ 6086(a)(2)J, because adequate quantities and quality of
19 water are available from the River and from an on-site well to meet
process and
20 potable water needs. Permit applications for a Groundwater Withdrawal
Permit
21 and a Non-Transient Non-Community Public Water System Source
and
22 Construction Permit are pending with the Vermont DEC. Finally, the Project
_____

Pownal Biomass Project, PSB Docket No.


Prefiled Testimony of Meddie Perry
October 25, 2010
Page 6 of 12

1 complies with the Burden on Existing Water Supplies criterion


[ 6086(a)(3)},
2 because the withdrawal of water for the Project will not adversely affect
any
3 existing water source. As noted, a permit application for a Groundwater

4 Withdrawal Permit is pending with the Vermont DEC.

5 Q6 What work have you conducted with respect to the Project?

6 A6 My staff and I have conducted site inspections, research, and testing regarding
the
7 hydrology of the groundwater and the Hoosic River. Regarding Fleadw
aters [
8 6086(a)(1)(A)J, we have conducted a reconnaissance of the site and the
surface
9 waters, delineated drainage areas and evaluated flow data. Regarding Waste
10 Disposal [ 6086(a)(1)(B)1, we have tested the soi]s, groundwater, and river at the
11 site and worked with Bruno Associates on the design of the process
water
12 infiltration system. Concerning Floodways [ 6086(a)(1)(D)1, we have analyzed
13 FEMA studies, floodplain mapping, and hydraulic modeling at the site.
We have
14 performed independent hydraulic modeling of the Hoosic River based
on accurate
15 surveyed topography of the site and River cross sections prepared
by Bruno
16 Associates and we have verified the delineation of the FEMA floodp
lain and
17 floodwater elevations at the site. We also have performed geomorphic studies
of
18 the River and evaluated the fluvial erosion hazard zone. Regarding Stream
s [*
19 6086(a)(1)(E)], we have performed statistical analysis of long term flow
data for
20 the Hoosic River, determined water withdrawal rates that are acceptable
in
21 accordance with Vermont DEC policy, and calculated the effects of the
proposed
22 water withdrawal to the hydraulic characteristics of the Hoosic River.
Concerning
_____

Pownal Biomass Project, PSB Docket No.


Prefiled Testimony of Meddie Perry
October 25, 2010
Page7 of 12

1 Shorelines I 6086(a)(1)(F)j, we have performed a reconnaissance of the site and


2 researched historical impacts to the shoreline at the site. Concerning Water
3 Supply for the Project [ 6086(a)(2)], we have evaluated well pumping test data,
4 researched the geology of the site, tested groundwater flow charac
teristics and
5 water quality, investigated potential contaminant sources and develo
ped a source
6 protection plan. Finally, concerning Burden on Existing Water
Supplies [
7 6086(a)(3)1, we have reviewed permits, construction and testing records
for area
8 water supplies, delineated the Project well’s area of influen
ce, analyzed the
9 location and flow of groundwater, and developed a conceptual model of

10 groundwater at the site.

11 Q7 Is the Project located in a headwater and, if so, will it reduce the quality
of ground
12 or surface water?

13 A7 The Project site is not located within a headwaters area as defined


by 10 V.S.A. §
14 6086(a)(1)(A), because it is not located on lands draining 20 square
miles or less
15 [10 V.S.A. § 6086(a)(1)(. ), Criterion ii). The watershed of the Hoosic River,
16 which flows immediately adjacent to the site, measures 210 square
miles at this
17 location. Furthermore, the Project site is not located within lands
characterized by
18 steep slopes, shallow soils, above 1.500 feet in elevation, in a waters
hed of a
19 public water supply as designated by ANR, or in an area supplying
significant
20 amounts of recharge water to aquifers. To the contrary, the Projec
t site is flat,
21 soils are deep, the land is at an elevation of approximately 540
to 550 feet, and
22 low amounts of recharge to aquifers occurs at the site due to low
permeability soil
_____

Pownal Biomass Project, PSB Docket No.


Prefiled Testimony of Meddie Perry
October 25, 2010
PageR of 12

1 materials. Refer to Petitioner’s Exhibit MJP-2, the Groundwater Withdrawal

2 Permit Application, which presents an extensive study of


these and other
3 characteristics of the site.

4 Q8 Will the Project meet any applicable health and Department


of Environmental
5 Conservation regulations regarding the disposal of any generated
waste?
6 A8 Yes. My testimony is specifically directed at the disposal of process
wastewater
7 and domestic sewage; other witnesses will describe other facets
of waste
8 management. The infiltration system that has been designed to return proces
s
9 water to the groundwater at the site complies with the Vermont
Underground
10 Injection Control Rule and the Vermont Groundwater Protection
Rule and
11 Strategy. The subsurface infiltration of process water will maintain
potable water
12 in the groundwater aquifer at the site, will not affect any existing
underground
13 sources of drinking water or any aquifers with the potential for use
as drinking
14 water sources, and will maintain existing water quality in the Hoosic
River. The
15 Project will not involve the injection of toxic or harmful substan
ces into
16 groundwater or wells. An Underground Injection Control (UIC)
permit has been
17 applied for and a permit is expected to be issued. Refer to Petitio
ner’s Exhibit
18 MJP-3 for the complete UIC application and narrative report. I have
performed a
19 hydrogeologic study of the proposed domestic sewage leachfi
eld, which has
20 determined that it is located beyond a two-year travel distance
in groundwater
21 from all drinking water wells, and thus complies with Vermont DEC
regulations
22 for waste disposal. See Petitioner’s Exhibit MJP-7.
_____

Pownal Biomass Project, PSB Docket No.


Prefiled Testimony of Meddie Perry
October 25, 2010
Page 9 of 12

1 Q9 Is the Project located within a floodway, floodway fringe, or fluvial


erosion
2 hazard zone? If so, does the Project comply with the Vermont
ANR’s Technical
3 Guidance for Determining Floodway Limits Pursuant to Act 250
Criterion 1(D)
4 (October 9, 2009)?

5 A9 Portions of the site are located within the floodway, floodway


fringe, and fluvial
6 erosion hazard zone. However, no above-grade development is
proposed within
7 the floodway and fluvial erosion hazard zone. Petitioner’s Exhibit
MJP-4 depicts
8 the flood hazard zones as they relate to the Project. Engineers from Bruno
9 Associates will testify regarding the design of the Project components
within the
10 floodway fringe so that they have been floodproofcd to comply with
FEMA and
11 Vermont guidelines. I have met with the Vermont ANR’s floodplain
coordinator
12 and reviewed the flood hazard zone boundaries and the design of the
Project, and
13 expect that the DEC will concur that the Project complies with
the ANR’s
14 Technical Guidance for Determining Floodway Limits. The Project will not
15 restrict or divert the flow of flood waters, or endanger the health,
safety and
16 welfare of the public or of riparian owners during flooding; and will
not increase
17 the peak discharge of the river or stream within or downstream from
the area of
18 development; nor will it endanger the health, safety, or welfare
of the public or
19 riparian owners during flooding. The Project is located within Powna
l’s Flood
20 Hazard Overlay District. The requirements for development
in this district,
21 defined by the floodplain and floodway regulations for the Nation
al Flood
22 Insurance Program, are similar to state standards. The Project
will comply with
_____

Pownal Biomass Project, PSB Docket No.


Prefiled Testimony of Meddie Perry
October 25, 2010
Page 10 of 12

1 these requirements by adhering to the floodproofing requirements, as discus


sed in
2 testimony from Bruno Associates.

3 Q1O Will the Project maintain the natural condition of streams?

4 AiD Yes. My colleague Adam Crary will testify regarding the delineation of
streams
5 and their buffers, and the Project’s design insofar as it does not encroach
on the
6 stream buffers. My testimony pertains to the proposed water withdrawal from
the
7 Hoosic River, which will maintain natural conditions of depth and velocit
y of
8 flow downstream. The proposed withdrawal of process water will be conduc
ted
9 at such a low rate, relative to the natural drought flow in the Hoosic River,
that it
10 will not have a measurable impact to the river. The withdrawal is being
permitted
11 in accordance with the Vermont ANR’s de nijuirnis policy, which recognizes
that
12 certain withdrawals are so small relative to the stream that their effects
will be
13 negligible. Refer to Petitioner’s Exhibit MJP-5.

14 QIl Is the Project located on a shoreline?

15 All No. The Project parcel is not on a shoreline of a lake, pond, reservoir or river,
as
16 defined in 10 V.S.A. § 6001(17). The Project development will not take place
17 along the shoreline of the Hoosic River, which will be maintained in a natural

18 condition. Historic site activities have encroached upon the shoreline,


including
19 the paving of a large parking lot for the former Green Mountain Race Track,
and
20 the creation of a levee along the top of the riverbank. As part of the propos
ed
21 Beaver Wood Project, these manmade features would be removed and
the
_____

Pownal Biomass Project, PSB Docket No.


Prefiled Testimony of Meddle Perry
October 25, 2010
Page 11 of 12

1 shoreline would be restored to a more natural condition than it


has been subjected
2 to for the past 50 years.

3 Q12 Is sufficient water available for the reasonably foreseeable needs of


the Project?
4 A12 Yes. My testimony pertains to the availability of sufficient water
in the
5 groundwater aquifers and in the Hoosic River for the potable and
process water
6 needs of the Project. Engineers from Bruno Associates will describe
the design of
7 the potable and process water systems. and the permitting of the
public Non-
8 Transient Non-Community potable water system. Petitioner’s Exhibit MJP-2
9 describes in detail the quantities of water needed for process water,
the statistical
10 analysis of Hoosic River streamfiows, and the fact that up to 1.458
gallons per
11 minute (gpm) may be withdrawn from the River as a de ininim
is withdrawal
12 whereas only 465 gpm would be needed to meet process water
demand on the
13 peak usage days. This exhibit also describes the availability of sufficient

14 quantities of groundwater in the existing on-site well that has


been subjected to
15 hydrologic testing. In relation to the 465 gprn peak process water
needs, and the
16 1.1 gpm of potable needs, the well has a safe yield of approximately 626
gpm and
17 can provide sufficient water for the foreseeable needs of the Projec
t. A source
18 protection plan has been prepared for the management of potenti
a1 contaminant
19 sources, in order to maintain the excellent water quality
in the well. See
20 Petitioner’s Exhibit MJP-6.

21 Q13 Will the Project cause an unreasonable burden on an existing water


supply?
_____

Pownal Biomass Project, PSB Docket No.


Prefiled Testimony of Meddie Perry
October 25, 2010
Page 12 of 12

1 A13 No. The use of water for Project will not affect the groundwater
levels or the
2 amount or quality of water supplying any existing well or water
source. See
3 Petitioner’s Exhibit MJP-2 for a thorough discussion of the potent
ial impacts to
4 existing water supplies.

5 3. Initial Project Work for 2010 and 2011

6 Q14 With respect to the criteria that you have testified about, will
the initial phase of
7 work proposed for 2010 and 2011 affect the Headwaters, Waste
Disposal,
8 Floodways. Streams, Shorelines, Water Supply for the Project, and
Burden on
9 Existing Water Supplies?

10 A14 No, the initial phases of work will not have any impact to these criteria
. The
11 initial phase, like the entire Project, will not be in a headwaters nor
on a shoreline.
12 The initial phase of work will not involve the construction of the
process
13 wastewater leachfield nor the domestic sewage Ieachfield, so there
is not any
14 activity that involves criterion lB. The initial work will not be
conducted in a
15 floodway and will not involve withdrawal of water from a stream
. No water
16 supply will be needed for the initial phase of work, which will
involve laying
17 some portions of water lines but will not connect any water sources to
any users
18 of water.

19 4. Couclusion

20 Q6. Does this conclude your testimony?

21 A6. Yes.
STATE OF VERMONT

PUBLIC SERVICE BOARD

Petition of Beaver Wood Energy Pownal, LLC )


for a Certificate of Public Good, pursuant to 30 )
V.S.A. § 248, to install and operate a Biomass )
Energy Facility and an integrated wood pellet
manufacturing facility located north of the old D OC k e N 0.
)
Green Mountain Racetrack in Pownal, Vermont, )
to be known as the “Pownal Biomass Project” )

PREFILED TESTIMONY OF
MEDDlE PERRY

Exhibit BWEP —MP- 1

Resumé
“Meddle”
(Ameddia) J.
Perry, CGWP
Senior Hydrogeologist June 2006 to Present, VHB, No. Ferrisburqh, VT
-
0o;t Manager
Project Manager for projects focusing on applied hydrology and hydrogeology. Responsible
for all aspects of project management and scientific procedures. Areas of specialization
include groundwater source development and aquifer mapping; hydrogeologic evaluation of Mr. Perry is a senior
wastewater disposal sites; water quality evaluations; stormwater management; surface water
hydrology including floDd and drought analysis. hydroelectric generation, floodplain hudroneolonist in VHB’s
delineation, analysis of snowmaking and domestic supply withdrawals; hazardous materials North Ferrisburgh, VT
investigations and compliance evaluations; and providing expert testimony.
office, where he
Hydrogeologist, Senior Kydrogeologist 1996 to 2006, Heindel and Noyes, Burlington, VT
-
manages projects
Managed projects involving the creation, testing, and management of public and private
drinking water systems; the design, monitoring, and operation of wastewater systems serving involving applied
homeowners to large resorts and institutions; investigations of pollution and environmental hydrology and
hazards and rernediation of groundwater contamination; and studies of surface water flow,
water quality, and aquatic biology. Duties included data collection, analysis, reporting, hydroglo y
presentation, testimony, project and staff management, and Phase I and II site assessments.
Management of watershed science division of consulting firm.

Water Supply Development & Kydrogeologic Studies


• Sited dozens of high yielding bedrock supply wells using aquifer mapping,
fracture trace analysis, and field geophysical studies, for municipal and private
development clients in Vermont and New Hampshire.
• Sited and designed gravel and gravel-packed water supply wells using geologic
mapping and test borings.
• Conducted over 80 aquifer tests for evaluation of bedrock and gravel
groundwater wells, including analysis of long term aquifer yield, well
interference, contamination transport, surface water interconnection, and
recharge area delineation.
• Designed water system improvements and managed construction projects,
including an upgrade to a municipal system involving the installation of four
new wells, reservoir upgrades, water treatment, and controls to correct water
quality and storage deficiencies; an upgrade of a municipal system involving
connection of a new bedrock well and water treatment to eliminate surface water
contamination problems; and new system construction involving installation of
source well, storage, water line, and tire protection.
• Wrote source protection plans for dozens of public water systems to identify and
manage risks of contamination to groundwater- and surface water-based
drinking water sources.
• Analyzed the impacts of several rock quarries on groundwater levels and water
availability in residential wells in Vermont; projects have included geophysical
testing, fracture mapping. measurement of groundwater flow and gradient, well
installation and aquifer pumping tests, and long term monitoring of
groundwater level and well yield.
• Conducted a town-wide aquifer and groundwater recharge area mapping
project to facilitate land use planning.

VHB
Wastewater Management “Meddle” (Ameddia) J.
• Conducted numerous hydrogeologic evaluations for land-based wastewater
Perry, CGWP
disposal systems ranging from residential-scale to over 300,000 gallons per day
capacity, including testing of soil, groundwater level and flow, permeability, and CoctwLeo, p.2
hydrogeologic capacity.
• Design, permitting, and inspection of wastewater treatment and disposal
systems including collection systems, sand filters, and mound and in ground
leachfields.
• Studied potential impacts of large wastewater disposal systems (>6500 gal/day)
to lakes and streams, involving analysis of groundwater and surface water
chemistry, wastewater treatment, streani.flows, and instream biology.

Environmental Investigations
• Performed Phase I Environmental Site Assessments for sites including gasoline
stations, a manufacturer of prefabricated homes, ski areas, and
telecommunications facilities.
• Investigated groundwater contamination, including petroleum. PCB,
perchiorate, and chlorinated solvent contamination in unconsolidated and
bedrock environments in Vermont and New Hampshire. Managed
contaminated soil and groundwater.
• Managed a long-term evaluation of the environmental impacts of storage of
treated mineral tailings, including characterization of tailings and environmental
fate of contaminants; evaluation of bedrock groundwater hydrogeology and
geochemistry, potential interaction with surface water and drinking water
supplies.

Surface Water Investigations


• Designed stormwater management systems and performed hydraulic analyses
of runoff and stormwater flow, Projects have included residential
developments, industrial sites, commercial properties, and educational
institutions.
• Delineated floodplains and revised FEMA floodplains based on detaiLed studies
of sites in Bennington, Vermont.
• Analyzed stxeamflow, water use needs, and withdrawal for snowmaking at
several ski resorts in Vermont and New York. Designed and pennitted new and
upgraded snowmaking systems and performed compliance monitoring for
existing systems.

Education 6.5. rnagna cum laude, Environmental Science & Biology, St.
Lawrence University, Cantor. NY. 1995

Feld Teotiniques for Soil Evaluation, New England Center for


Wastewater Training (1997)

Ongoing Graduate and Continuing Education Coursework (1998-


present)

Prolessional OSHA 40-hour Hazardous Waste Operations and Emergency


Registrations Response Course, Feb. 1997

Certified Ground Water Professional (CGWP) #3106689

Professional Member, National Groundwater Association


Affiliations

1/FIB
STATE OF VERMONT

PUBLIC SERVICE BOARD

Petition of Beaver Wood Energy Pownal, LLC


for a Certificate of Public Good, pursuant to 30
V.S.A. § 248, to install and operate a Biomass
Energy Facility and an integrated wood pellet
manufacturing facility located north of the old Docket No
Green Mountain Racetrack in Pownal, Vermont, )
to be known as the “Pownal Biomass Project”

PREFILED TESTIMONY OF
MEDDlE PERRY

Exhibit BWEP -MP- 2

Groundwater Withdrawal Permit Application


C

I’
a
Tnasse i-Iangen Brush/n, Inc.
Transportation j Land Development Environmental Services

October 22, 2010

Ref: 5740703

Mr. Dennis Nealon


Hydrogeologist Water Resources Section

Water Supply Division


Vermont Department of Environmental Conservation
103 South Main Street, The Old Pantry Building
Waterbury, Vermont 05671-0403

Re; Beaver Wood Energy Pownal, LLC


Groundwater Withdrawal Permit Application

Dear Dennis:

Enclosed please find a Groundwater Withdrawal Permit Application for the proposed use of the existing
gravel-packed well as a source of process water for the planned Beaver Wood biomass energy facility in
Pownal. A narrative report is attached presenting all the information specified on the application form.
A
check for the $1,500 application fee also is attached.

This submittal has been prepared in accordance with 10 VSA, ch. 48, subchapter 6 as amended by Act
199.
Because the administrative rules for groundwater withdrawal permitting are currently in draft form, this
permit application has been developed in accordance with the statute, and the draft administrative rules
have been followed as a guidance in instances where the statutory language is not specific.

Please do not hesitate to contact me with any questions or comments you may have.

Sincerely,
VANASSE HANGEN BRUSTLIN, INC.

Senior . drogeologist

MJP/ cpc
Enclosure

cc: Karen Burrington, Pownal Town Clerk


Pownal Selectboard
Pownal Conservation Corn.rnission
Bennington County Regional Commission
Tom Emero, Beaver Wood Energy Pownal, LLC
Bill Bousquet, Beaver Wood Energy Pownal, LLC
Hans Huessv, Kenlan, Schwiebert & Facey P.C.
1056 US Route 7
\\Vtda\ projects \5?407 03 SWE Pownal Permilnng\reports\GW_witbdrawat_application\cover utie, dot Post Office Box 120
North Ferrisburgh, VT 05473
802.425.7788 FAX 802.425.7799
mm’.vhbcorn
_

r ENVIRONMENTAL CONSERVATION
Water Supply Division
APPLICATION

GROUNDWATER WITHDRAWAL PERMIT

APPLICATION

This application initiates the Water Supply Division’s review and permitting process for source development
of a Groundwater Source to serve a Proposed or Existing Industrial/Commercial facility withdrawing
greater
than 57,600 gpd. Drinking water supply sources are required to obtain a separate permit.

A site visit will be scheduled following receipt of a complete application. Following construction of the
source the applicant shall submit a source testing proposal (on a form provided by the Secretary) and
the
applicant and/or applicant’s consultant shall attend a public meeting to address public concerns. Following
the public meeting and after receiving state approval for the source tesling proposal, the applicant shall
conduct source testing and address undue adverse impact concerns. The applicant shall submit a source
evaluation report that addresses these concerns. Once the applicant satisfies all administrative and
technical requirements the state will issue a Groundwater Withdrawal Permit.

I This line for WSD use only: WSD project ID # Associated WSH) # I Code I Date
For staff use WSD codes: C I
= completed NR = not required IR = info, required TBD to be determined

1. Town: Pownal
L
2. Facility_name:_Beaver_Wood_Enerciv_Pownal._LLC
3. Applicant name: Tom Emero
Mailing address: 230 West Street
Rutland, VT 05701
Daytime_phone:_(508)_321-1181 e-mail:_tomemero©ampil.com
[4. Source owner (if different from applicant): Procress Partners LTD.. attn: Richard Hem
: Mailing address: 132 Larchmont Ave
Larchmont, NY 10538
Daytime_phone:_914-907-6030 e-mail:_rthdesign@verizon.net
5. Hydrogeologist: Meddie Perry, CGWP
Mailing_address:_7056_US_Route_7._P0_Box_120
North FerrisburQh, VT 05473
Daytime_phone:_(802)_425-7788_ext_6454 e-mail:_mnerry@vhb.com

6. Describe the purpose of the groundwater withdrawal_(attach): attached


7. Time frame: F Peak amount: I Mean amount
Estimated daily withdrawal:

r
69,9Q_qallons per day 103,080 gallons pery
Estimated monthly withdrawal: I 630:000 qallons per day 103.080 gallons per day
Estimated yearly withdrawal: 279.500 gallons per day 103 gallons per day
8. Requested withdrawal rate: 465.2 gallons per minute

9. Describe the alternate means considered for satisfying the stated purpose of the water
withdrawal (attach): attached
10. Describe how the withdrawal is planned in a fashion that provides for efficient use of
the_water_(attach):_attached

r
F
11. Source of the proposed withdrawal (check applicable type):

Dspring ODug well X Unconsolidated drilled well Dother (describe):


Dsedrock drilled Well

12. provide detailed plans of the proposed source construction (attach): attached
• 13. a) Identify proposed and existing withdrawal location(s) on a USGS mao attached

-
10/19/2010
1/4
Oct 19 10 OC:29p Richard Hem (914) o33-9s69 p.2

h) Identify the withdrawal locations on a map thwing the subject parcel and ary
adjobtig parcIs wIthin 100 feet of the wkhdrawal posnt wh any iguied isOkIiC*i
dislsnc meastgedfixm the widySawal powit and showing the kratlon of associated
protective measures ftc protecting the souwe from advese hnpads (attach): attadial
14. GPS locattn(s) of the proposed withdrawal point(s), and of any existing water sources
for the project shall use the HAD 83 fonnat (report In Degrs, Minutes, and
secopct) for the horizontal GPS codbiates (attach): attached
15. Identify b€nchmait and elevatlas tr vertical r&erences arid itty th& bcaltns
onan appopt’iately scaled map (attach): ttacj1 -._______________

16. Descrl’e the place and rEinna of the rthn &w for the withdrawn water attached —

17.11 apØtabe, identify the return flow caUon(s) on an appmprialefr scaled map:
..._
___

18, EstImate] yearly amount at water that will not be rehxned to the watershed where the
proposed withdrawal Is located: 33240_ayeaoe Gallons
19. Inventory of actual arid potential contaminant courts, with locations identified on an
apptopdately scaled map (attach); attachel } —

20. Inventory of water resourc and uses (such as ddnklng water ssourtes,
significant wetlands, surface waters, otha water wlth&awals arid uses), with locations
hientflied on the came map the Inventory of contaminant sources attached
21, Develop a water buctzet for the acaWe(s) the withdrawal taking place from
Lattached
. Develop a conceptual hydcooloØc model of the withdrawal considering the water
budqa developed (attach):_attached
! 23. DelIneate tIle poteritfaf area of Influence showing preexisting conditions and the
conditions under proposed mimum withi*awal In both plan view arid profile view at
an appropriate scale, based on dt conceptual hydrogeolOgic model (ettach):
24. Describe how the ar was lneateo using the model (attach): attached
25. Pruvide a description of the withdcawal &fts on each of the contamliauon saa’c,
. water resources, water uses, and long term response of the agiier (ttacJe
26. Desathe the mitigation nasures to be inpiernented to remedy any expected undue
adverseWnaI!cj):att4.hffj
2?. Attach a signal and dated certification by pØç tfley met the pre
application pub& iz*rmatlonal meetMg reruirements: attached
2& Atlacha signed and dated cemtiftailon by the appicarit th t the proposed withdrawals’
In conformance with the regional plan adopted for the area in whtti the proposed
withdrawal Is located, and that it is in conformance with the municipal plan adopted for
the municipality that the proposed withdrawal Is located within: attached
29. If applicable, the prevlotsly assned permitted withdrawal voltsnes, establIshed safe
tlekls, or the known flow or withdrawal rates at the apIicant’s other water sources on
this or con Uquot j): attached
flAttachaflstotaUpersort(name add.ess,andpttorwnwnbe)whtharereçJiredto
• be notified of the pm_posed

(cab or money onlex mack PaYable the state of Veitnci nt):

recogrWze that by sçiing this apphcaiem I am ywmg wasat to ernpbyees of the Staw W enter
the
subject property ftr the pu of p.rocess:ng this apç*czborL.

5ature&ttieApayt
Date /O /%o
/
Date_______
si’?’ the Co-applCot (Owner of Wa Source
1 if dtet fli the Applint) /
9/1412010 214
Note: Attachments are voluminous and are not included in this
exhibit, but can be provided upon request.
STATE OF VERMONT

PUBLIC SERVICE BOARD

Petition of Beaver Wood Energy Pownal, LLC


for a Certificate of Public Good, pursuant to 30
V.S.A. § 248, to install and operate a Biomass
Energy Facility and an integrated wood pellet
manufacturing facility located north of the old D oc k e N O
)
Green Mountain Racetrack in Pownal, Vermont,
to be known as the “Pownal Biomass Project”

PREFILED TESTIMONY OF
MEDDlE PERRY

Exhibit BWEP —MP-- 3

Underground Injection Control Permit Application


Vaizc’se flangen Brusllnz Inc
Transportation Environmental Land Development Services

October 22, 2010

Mr. Jeff Fehrs


Engineer
Wastewater Management Division
Department of Environmental Conservation
103 South Main St. Sewing Building

Waterbury, Vermont 05671-0405

Re: Beaver Wood Energy Pownal, LLC


Underground Injection Control Permit Application

Dear Jeff:

Enclosed please find an Underground Injection Control (UIC) permit application for the
proposed infiltration system for the management of process water from the proposed
Beaver Wood Energy biomass facility in Pownal.

The enclosed UIC Permit Application NJarrative Report provides all the information
required by the UIC Rule, the permit application form, and the Schedule D for a
proposed Class V injection well. The application fee of $ 5,741.92 is also enclosed.

Please contact me if you have any questions or require any additional information.

Sincerely,
VANA HANGEN BRUSTUN, INC.

Meddiq1’erry
Senior Hydrogeologist

cc: Tom Emero, Beaver Wood Energy Pownal, L.LC


Bill Bousquet, Beaver Wood Energy Pownal, LLC
Hans Huessy, Kenlan, Schwiebert & Facey P.C.

\\Vtdata\projecta\57407.OO Beaver Waud Pownal\repor[s\UIC\UIc_App_coverLetter.doc


Page 1 of2
STATE OF VERMONT
AGENCY OF ENVIRONMENTAL CONSERVATION
DEPARTMENT OF WATER RESOURCES
AND ENVIRONMENTAL ENGINEERING

WATER POLLUTION CONTROL PERMIT REGULATIONS, CHAPTER 13


UNDERGROUND INJECTION CONTROL, SUBCHAPTER UIC

FORM WR-UIC-I

APPLICATION FOR A PERMIT TO DISCHARGE WASTES INTO AN INJECTION WELL

All information to typed or neatly printed and legible.


See instructions on following pages.

1. Applicant/Owner Beaver Wood Energy Pownal, LLC_ Legal Entity Limited Liability Cow.

2. Mailing Address 230 West Street, Rutland, VT 05701

3. Operator Mr. Bill Bousguet Telephone 603 465-2957

4. Name of Activity of Facility for which Application is submitted. Beaver Wood Energy
Pownal Biomass Plant

5. Description of Activity or Facility Subsurface disposal of process wastewater from cooling


tower blowdown, process drains (oil water separator effluent), and demineralization

SIC Codes 4911

& Nature of Wastes: Sanitary i Oil or Gas Related Fluids Commercial

Drainage Heat Pump Return Flow Other (Describe)

7. Classification of Injection Well I II III

8. Description of Location of Injection Well (Attach map per instructions)


2.500 feet north of former Green Mountain Race Track Grandstand in Pownal, VT

9. Status of Discharge sed Existing (Permit No._)

10. The applicant hereby applies for a discharge permit to discharge wastes into an injection
well from the above named activity or facility as described in this application, its attached
schedule(s), and specifications.

IL Application is for inatPermLt Permit Renewal If this is for a permit renewal.


is original application still valid in all respects? Yes No Ifnot, attach new schedules(s),
plans. and specifications.
______
_____

Page 2 of 2

12. List below by permt number or other identification all State or Federal permits
or
construction approvals received or applied for under any of the following programs for this
facility:
(I) Hazardous Waste Management program under RCRA. NQIIc

(ii) UIC program under SDWA. None

(iii) NPDES program under CWA. Construction General Permit 3-9020, Stormwater
Permit 3-9015

(iv) Prevention of Significant Deterioration (PSD) program under the


Clean Air Act.
None

(v) Nonattainment program under the Clean Air Act. None

(vi) National Emission Standards for Hazardous Pollutants (NESHAPS) preconstruction


approval under the Clean Air Act None

(vii) Ocean dumping permits under the Marine Protection Research and Sanctuaries Act.
None

(viii) Dredge or fill permits under section 404 of CWA. None

(ix) Other relevant environmental permits, including State permits. Vermont Section
248 (Public Service Board): Vermont Water/Wastewater Permit. Vermont Groundwater
Withdrawal Permit

13. Application fee enclosed $5,741.92 . Date of Application October 25. 2010

14. Signature of Authorized Representative (See INSTRUCTIONS)

CERTIFICATION
I certi’ under penalty of law that I have personally examined and am familiar with the
information submitted in this document and all attachments and that, based on my inquiry of
those individuals immediately responsible for obtaining the information, I believe that the
information is true, accurate, and complete. I am aware that there are significant penalties for
submitting false inlbrmation, including the possibility of fine and imprisonment.

I certify that to the best of my knowledge nothing in this application will cause or allow the
endangernient of any underground source of drinking water.

I ?urther certi’ that the Secretary or an authorized representative is hereby authorized to enter,
inspect, sample, monitor and have access to and copy records at reasonable limes at the facility
identified above. -.
Tom Emero Managing Member . .../ --
TYPE OR PRINT NAME TITLE SIGNATURE

F 57437 Pe,,, Wo P,.rj,tUKfo,m VRJK.L4


Note: Attachments are voluminous and are not included in this
exhibit, but can be provided upon request.
STATE OF VERMONT

PUBLIC SERVICE BOARD

Petition of Beaver Wood Energy Pownal, LLC )


for a Certificate of Public Good, pursuant to 30
V.SA. § 248, to install and operate a Biomass
Energy Facility and an integrated wood pellet
manufacturing facility located north of the old Docket No
Green Mountain Racetrack in Pownal, Vermont, )
to be known as the “Pownal Biomass Project” )

PREFILED TESTIMONY OF
MEDDlE PERRY

Exhibit BWEP -MP- 4

Flood Zone Maps


- -_

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‘I
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/

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STATE OF VERMONT

PUBLIC SERVICE BOARD

Petition of Beaver Wood Energy Pownal, LLC )


for a Certificate of Public Good, pursuant to 30
V.S.A. § 248, to install and operate a Biomass
Energy Facility and an integrated wood pellet
manufacturing facility located north of the old Docket No
)
Green Mountain Racetrack in Pownal, Vermont, )
to be known as the “Pownal Biomass Project”

PREFILED TESTIMONY OF
MEDDlE PERRY

Exhibit BWEP -MP- 5

Hoosic River Process Water Intake: De Minimis


Vu nasse 1-hangen Brustlin, Jnc.
Environmental Transportation Land Development Services

October 22, 2010

Mr. Brian Fitzgerald


Streamfiow Protection Coordinator
Vermont Agency of Natural Resources
Water Quality Division
103 South Main St.
Waterbury, VT 05671-0408

Re: Beaver Wood Energy Pownal, LLC


Proposed Hoosic River Intake
Pownal, VT

Dear Brian:

A process water intake that consists of a screened inlet below the water surface is
proposed as a component of the proposed Beaver Wood Energy Pownal LLC biomass
energy generating plant in Pownal Vermont. The water intake structure would he
constructed on the Hoosic River which runs along the Southern Vermont Energy Park
renewable energy development, where the project has been proposed. The purpose of
the proposed withdrawal is to enable Beaver Wood to obtain adequate quantities of
water for generating steam to turn the electric generating turbines, and for cooling.
Process water needs will vary based on the ambient temperature, humidity, and other
factors, ranging from 129 to 465 gallons per minute (gpm), and averaging 322 gpm
annually. The design of the structure has been based on the primary goals of providing
a practical means of withdrawing water, minimizing the amount of disturbance to the
river, and causing no significant effects to fish populations or aquatic habitat.

The proposed peak withdrawal rate would be equal to approximately 1.6 percent of the
site specific 7Q10 streamflow in the Hoosic River, and therefore meets the requirements
of the Agency Procedure for Determining Acceptable Minimum Streamfiows
(7/14/1993) for a de minimis withdrawal.

This letter proposes the de rninzmis withdrawal and presents information to detail the
water needs, options for alternative sources of supply, and hydrologic analysis of the
Hoosic River. Additionally, we have been in discussion with Martha Abair of the US
Army Corps of Engineers (USACE), and will be applying for a Water Quality
Certification for the project under Section 404 of the Clean Water Act.

7056 US Route 7
Post Office Box 120
North Ferrisburgh, VT 05473
802.4257788 FAX 802425 7799
w. vhbcom
Mr. Brian Fitzgerald
RE: Beaver Wood Energy Pownal, LLC, Proposed Hoosic River Intake
October 22, 2010
Page 2

I. Hoosic River Characterization

A. Watershed
At the project site, the Hoosic River has a relatively large watershed area of 211 square
miles. See page 1 of Attachment I for a map of the watershed showing the location of
the project site and the two USGS gauges that are situated upstream of the project site.
Rising in the Berkshire Mountains of western Massachusetts, the Hoosic flows
northward through Vermont and New York en route to the Hudson River.

B. Streamflows
Statistical strearnflows were determined by analyzing USGS gauge data from the Hoosic
watershed in accordance with standard hydrologic procedures.

1. 7Q10 Streamfiow was determined in accordance with USGS procedures (HC


Riggs, 1972, ‘Techniques Of Water Resources Investigations Of The USGS,
Chapter BI: Low-Flow Investigations”) based on the USGS Hoosic River near
Williamstown, MA gauge. The data were adjusted for the differences in
watershed area between the USGS station and the project site. See pages 2 and 3
of Attachment 1. A 7Q10 flow of 65 cfs, equal to 0.31 csm, was determined at the
project site based on 70 years of flow records.

2. de minirnis flow: For meeting the requirements of the Vermont Department of


Environmental Conservation (DEC), a de minim is flow of 5 percent of the site
specific 7Q10 flow was determined. Water may be withdrawn at any time from
the Hoosic River in accordance with the Agency Procedure for Determining
Acceptable Minimum Streamflows (7/14/1993) at a de minimis rate of 1,458
gallons per minute. See pages 2 and 3 of Attachment 1. In contrast, the proposed
water demand for the project on peak days is only 465 gpm, or only 32 percent of
the allowable de minimis withdrawal rate.

3. Aquatic Base Flow (ABE) was determined in accordance with the procedures of
the US Fish and Wildlife Service’s “Interim Regional Policy for New England
Streams Flow Recommendations” (the “USEWS flow policy”), as further
described in the Questions and Answers on the New England Flow Policy
document (Q#13, May 11, 1999, Vernon Lang, US F&WS). See pages 4 through 8
of Attachment 1. An ABF of 89 cfs, equal to 0.70 csm, was determined at the
project site based on 70 years of flow records. The site specific ABE is higher than
the default New England ABE of 0.50 csm, indicating that the Hoosic watershed
has a relatively high rate of base flow.

7056 US Route 7
Post Office Box 120
North Ferhsburgh, VT 05473
802.425.7788• FAX 802 425 7199
v.ww. vhb corn
Mr. Brian Fitzgerald
RE: Beaver Wood Energy Pownal, LLC, Proposed Hoosic River Intake
October 22, 2010
Page 3

H. Process Water Needs

The biomass energy generating plant requires between 129 and 465 gpm of process
water to generate steam necessary to turn the electric generating turbines and to cool the
plant. Potable water for employees is not included in this range, comprises
approximately 1.1 gpm, and would be provided separately from a drilled well on-site.

The process water needs will vary based on the ambient wet bulb temperatures and
relative humidity, which reflect the natural variations in temperature, moisture content,
and barometric pressure of the air. Pages 1 and 2 of Attachment 2 tabulate and graph
the water demands as a function of the wet bulb temperatures and relative humidity.
Page 3 of Attachment 2 summarizes the relative quantities of streamflow, average and
maximum plant demand, and return water flow. The peak demand withdrawal
represents only about 1 percent of the ABF flow, and the aimual average demand
represents only about 0.8 percent of ABE

Note that about 15 percent of the process water would be returned indirectly to the river
via the proposed process water infiltration field, which is being permitted under the
Vermont Underground Injection Control Rule (1982). Groundwater from the infiltration
field would flow towards the Hoosic River.

III. Alternatives Analysis

Potential alternatives to a river intake inctude groundwater wells and storage lagoons,
or some combination thereof.

Use of storage lagoons has been determined to be unfeasible, because the water used for
the plant must be clean and free of algae, sediment, and suspended matter whereas
water ponded in storage tends to develop high levels of these substances.

A portion of the northern end of the existing manmade pond on site would need to be
filled in order to construct the biomass facility at a location that is outside the regulatory
floodway limit. The resulting pond would measure approximately 6.6 acres, and with
an average water depth of 5.5 feet, could store approximately 12 million gallons (Mgal).
Refer to the Process Water Sources Map on page 4 of Attachment 2 for the location of the
pond and other site features.

As discussed in the Mass Balance Results section below, storage in the manmade pond
was evaluated in the context of withdrawal from the Hoosic River occurring only when
streamflows were above ABE, as potentially may be required in accordance with USFWS
flow policy that the USACE would evaluate during the process of permitting the project

7056 US Route 7
Post Office Box 120
North Ferrisburgh, VT 05473
8024257788 FAX 802.425 7799
ww* vhbeorn
a
Mr. Brian Fitzgerald
RE: Beaver Wood Energy Pownal, LLC, Proposed Hoosic River Intake
October 22, 2010
Page 4

under Section 404 of the Clean Water Act. The pond could not provide adequate
volumes of storage to enable the hiomass plant to function during the expected periods
of streamflow below ABF, and it is not feasible to expand it to a sufficiently large
volume. The mass balance analysis (see below) determined that a storage volume of 83
Mgal would be needed for the biomass plant to operate while relying on a river intake
with a minimum flow of ABE Maintaining the current depth of the pond, a total pond
area of 46 acres would be needed to provide the necessary storage, which is not feasible
because it would consume nearly the entire property that Beaver Wood is leasing.
Deepening the pond, rather than expanding it laterally, is not feasible because the pond
would need to become 40 feet deep, which is not geotechriically feasible. Lining of the
pond would be necessary to prevent water from exfiltrating into the surrounding
groundwater and compromising the quality of potable water in the nearby gravel well.

Use of well water is less desirable than river water because groundwater contains
elevated levels of minerals which affect the performance of the plant process equipment.
Water from both the Hoosic River and from an on-site well have been extensively
analyzed, and alkalinity, calcium, hardness, magnesium, silicon, sulfate, and total
dissolved solids in the well are significantly higher than in the river water, and as a
result the groundwater would be less suitable for process water. Refer to Attachment 3
for water quality testing results. The on-site well has a tested yield of approximately 626
gpm based on information on file with the Vermont DEC, Water Supply Division, and
may be usable as a backup source.

A. Mass Balance Analysis Methods


A mass balance hydrograph analysis was performed to evaluate potential alternative
source scenarios, with the essential goal of meeting the plant’s water demands at all
times.

National Weather Service data were used to determine wet bulb temperature and
relative humidity for every day that data are available, in order to calculate the daily
water demands. 63 years of record, from 1947 through 2009, are available.

USGS streamflow gauge data from the Wi]liamstown, MA station were used to
determine daily streamflow rates at the intake site for every day during the period of
record For the National Weather Service data. The data were adjusted for the differences
in watershed area between the USGS station and the project site.

The mass balance analysis was utilized to determine daily demand, river water
availability, well water availability, and storage volumes for every day over the 63 year
period of record. Statistical analysis of the 63 years of daily data was performed in order
to evaluate the results. Various scenarios were evaluated, including several

7056 US Route 7
Post Office Box 120
North Ferrisburgh, VT 05413
802.425 7788. FAX 802 425 7799
VtA’w. vhbcom
C Mr. Brian Fitzgerald
RE: Beaver Wood Energy Pownal, LLC, Proposed Hoosic River Intake
October 22, 2010
Page 5

combinations of different storage volumes, well yields, and streaxnflow limitations.

B. Mass Balance Analysis Results


Page 1 of Attachment 4 presents a summary of the results. Results from individual
scenarios follow and include a detailed tabulation of the results, and hydrographs
depicting the streamfiow, river withdrawal, well production, storage, plant usage, and
demand.

1. Scenario I
Scenario 1 consists of a river intake, no withdrawal when streamflows are less than ABF,
no well, and no storage. On average, 78 percent of the annual water needs would be
met. Plant demand would be fully met in only 3 percent of all years. Therefore this
scenario would not meet the water needs of the project and is thus not feasible. See
pages 2 through 6 of Attachment 4.

2. Scenario 2
Scenario 2 is representative of the State of Vermont’s de minimis flow policy, and consists
of a river intake, withdrawal at all natural streamflows based on the provisions of Part
C.6. of the USFWS Flow Policy, and no storage. Plant demand would be fully met in all
years and the withdrawal would not affect aquatic habitat or biota. Therefore this
scenario is feasible. See pages 7 through 11 of Attachment 4.

3. Scenario 3
Scenario 3 consists of a river intake, no withdrawal when streamfiows are Less than ABF,
no well, and the 12 Mgal of storage that would be available in the existing on-site man
made pond. On average, 93 percent of the annual water needs would be met. Plant
demand would be fully met in only 33 percent of all years. Therefore this scenario
would not meet the water needs of the project and is thus not feasible. See pages 12
through 16 of Attachment 4.

4. Scenario 4
Scenario 4 consists of a river intake, no withdrawal when streamfiows are less than ABF,
no well, and the amount of storage that would be needed to enable demand to be met at
all times. Plant demand would be fully met in all years. However, the requisite 83.4
Mgal of storage could not be constructed at the site, as discussed above, and is not
feasible. See pages 1? through 21 of Attachment 4.

5. Scenario 5
Scenario 5 consists of a river intake, no withdrawal when streamfiows are less than ABF,
use of the on-site well at up to 500 gpm when Hoosic River flows are less than ABF, and
no storage. This scenario preferentialk relies on the river, and uses the well as a water

7056 US Route 7
Post Office Box 120
North Ferrisburgh, VT 05473
802.4257788 FkX 802.425 77g9
vrnw. vhb corn
a
Mr. Brian Fitzgerald
RE: Beaver Wood Energy Pownal, LLC, Proposed Hoosic River Intake
October 22, 2010
Page 6

source only when streamfiows are below ABF, or when only a portion of demand can be
met with the River intake due to the need to maintain downstream flows at or above
ABF. Plant demand would be fully met in all years. Therefore, this scenario is feasible.

Well water would comprise 22 percent of plant usage on average. Thus, the average rate
of groundwater withdrawal would be 37.6 Mgal per year, equal to 103,080 gpd or 72
gallons per minute, and a Groundwater Withdrawal Permit from the Vermont DEC,
Water Supply Division would be needed. In some years, the well would not need to be
used at all. In a peak well usage year, the well would need to provide 58 percent of the
water used in a year by the biomass plant, equal to 102 Mgal per year, 279,500 gpd, or
194 gpm. At a peak monthly rate, the well would be called upon to produce 630,000
gpd, equal to 438 gpm. See pages 22 through 26 of Attachment 4.

6. Scenario 6
To evaluate options for using a well without exceeding the 57,600 gpd threshold for
needing a groundwater withdrawal permit, Scenario 6 consists of a river intake, no
withdrawal when streamflows are less than ABF, use of the well for up to 39 gpm, and
no storage. On average, 81 percent of the annual water needs would be met. Plant
demand would be fully met in only 3 percent of all years. Therefore this scenario would
not meet the water needs of the project and is thus not feasible. See pages 27 through
31 of Attachment 4.

7. Scenario 7
To further evaluate options for using a well without exceeding the 57,690 gpd threshold
for needing a groundwater withdrawal permit, Scenario 7 consists of a river intake, no
withdrawal when streamflows are less than ABF, use of the well for up to 39 gpm, and
the 12 Mgal of storage in the existing manmade pond on site. On average, 95 percent of
the annual water needs would be met. Plant demand would be fully met in only 40
percent of all years. Therefore this scenario would not meet the water needs of the
project and is thus not feasible. See pages 32 through 36 of Attachment 4.

8. Scenario 8
To further evaluate options for using a well without exceeding the 57,600 gpd threshold
for needing a groundwater withdrawal permit, scenario 8 consists of a river intake, no
withdrawal when streamflows are less than AEF, use of the well for up to 39 gpm, and
the amount of storage that would be needed to enable demand to be met at all times.
Plant demand would be fully met in all years. However, the requisite 73 Mgal of storage
could not he constructed at the site, as discussed above, and is not feasible. See pages 37
through 41 of Attachment 4.

7056 US Route 7
Post Office Box 120
North Ferrisburgh, VT 05473
802.425.7788 FAX 802.4257799
Www yhb.com
a
Mr. Brian Fitzgerald
RE: Beaver Wood Energy Pownal, LLC, Proposed Hoosic River Intake
October 22, 2010
Page 7

9. Summary
The two feasible scenarios are #2 and #5. Scenario #2, including withdrawal at no more
than 465 gpm at any natural streamfiow in accordance with the de mimmis, provisions of
the Vermont Streamflow Policy, and with no adverse impact to the biota or habitat in the
Hoosic River in accordance with Part C.6. of the USFWS Flow Policy, would meet the
biomass plant’s water needs at all times. Scenario #5, which relies upon the onsite well
when streamflows are below ABF, also would meet the biomass plant’s water needs at
all times but would require up to 58 percent of the plant’s water supply to come from
the well, which is less suitable for the plant than the river water.

IV. Intake Design

The intake has been designed to minimize physical disturbance to the river channel and
to avoid any entrainment of aquatic organisms. See design information in Attachment 5.

The intake is proposed to he hydraulically jacked into a deep pool in the river bottom
from a temporary pit on the project site. The jacking technique will avoid digging into
the riverbank so that the only physical disturbance will be the protrusion of the intake
pipe itself from the riverbed. A small (8-inch diameter) pipe is proposed.

A screened intake structure with internal baffles and a 0.45-inch screen opening will
ensure that entrance velocities are less than 0.3 ft/sec over its entire extent, preventing
any risk of entrainment. Typical requirements are for a maximum of 0.5 ft/sec entrance
velocity to avoid entrainment. The intake structure is 16 inches in diameter, 18 inches
long, and would be placed in a deep poo1 with over 5 feet of depth to ensure adequate
water depth at all times of year.

V. Summary

A process water intake along the Hoosic River is proposed as a component of the
proposed Beaver Wood Energy Pownal LLC biomass energy generating plant in
Pownal. The purpose of the proposed withdrawal is to enable Beaver Wood to
obtain adequate quantities of water for generating steam to turn the electric
generating turbines, and for cooling. Water needs will range from 129 to 465
gpm depending on weather conditions, and will average 322 gpm annually.

The site-specific 7Q10 flow in the Hoosic River has been determined, and the
proposed peak withdrawal rate would be equal to approximately 1.6 percent of
the 7Q10 streamfiow at the site, and therefore meets the requirements of the

7056 US Route 7
Post Office Box 120
North Ferrisburgh, VT 05473
802.425.7788 FAX 802.425.7799
s. vhb.com
I’ll,
Mr. Brian Fitzgerald
RE: Beaver Wood Energy Pownal, LLC, Proposed 1-loosic River Intake
October 22, 2010
Page 8

Agency Procedure for Determining Acceptable Minimum Streamflows


(7/14/ 1993) for a de minirnis withdrawal.

The design of the intake structure has been based on the primary goals of
providing a practical means of withdrawing water, minimizing the amount of
disturbance to the river, and causing no significant effects to fish populations or
aquatic habitat. The project will be applying for a Water Quality Certification
from the US Army Corps of Engineers under Section 404 of the Clean Water Act.

Please feel welcome to call me if you have any questions.

Sincerely,
VANASSE HANGEN BRUSTUN, INC.

Meddie J. Perry, CGWP


Senior Hydrogeologist

MJP!cpc
Attachments

cc: Tom Fmero, Beaver Wood Energy Pownal, LLC


Bill Bousquet, Beaver Wood Energy Pownal, LLC
Hans Huessy, Kenlan, Schwiebert & Facey PC.

\Vtda, \projecta\S?
OO 8
497 Wood Pownal\docs\Ietter5\ DEC withdrawa) \6tzgerald_l bc

7056 US Route 7
Post Office Box 120
North Ferrisburgh, VT 05473
8024257788 FAX 8024257799
ftv;v vhb.corn
Note: Attachments are voluminous and are not included in this
exhibit, but can be provided upon request.
____

STATE OF VERMONT

PUBLIC SERVICE BOARD

Petition of Beaver Wood Energy Pownal, LLC


for a Certificate of Public Good, pursuant to 30
V.S.A. § 248, to install and operate a Biomass
Energy Facility and an integrated wood pellet
manufacturing facility located north of the old Docket No
Green Mountain Racetrack in Powna, Vermont,
to be known as the “Pownal Bioniass Project”

PREFILED TESTIMONY OF
MEDDlE PERRY

Exhibit BWEP —MP-- 6

Source Protection Plan: Potable Water Supply Well


Gravel Well: Source Protection Plan

BEAVER WOOD ENERGY


POWNAL, LLC
WSID #2 585

Pownal, Vermont

Prepared for Beaver Wood Energy Pownal, LIC.


230 West Street
Rutland, Vermont 05701

Prepared by Vanasse Hangen Brustlin, Inc.


7056 US Route 7
Post Office Box 120
North Ferrisburgh, VT 05473

October 8,2010

t2inasse Hangen Brustlin, Inc


BEAVER WOOD ENERGY POWNAL, LLC.
WSID #2585
SOURCE PROTECTION PLAN: Gravel Well

jofContent

1.0 Introduction 1
2.0 Wellhead Protection Area 2
3.0 Potential Sources of Contamination 3
4,0 Management Plan 6
5.0 Contingency Plan 8
References 132
BEAVER WOOD ENERGY POWNAL, LLC.
WSID #2585
SOURCE PROTECTION PLAN: Gravel Well
1

1.0 Introduction
I

This Source Protection Plan (SPP) has been prepared by Vanasse Hangen Brustlin, Inc.
(VHB) for Beaver Wood Energy Pownal, LLC.’s (Beaver Wood) Public Non-Transient, Non-
Community (NTNC) water system, WSTD #2585. The water system is located in the Town
of Pownal, Vermont, The NTNC water system is composed of an existing gravel well that
was drilled in 1962 as part of the original construction of the Green Mountain Race Track
(GMRT) which is located along US Route 7 and the Hoosic River (see Site Plan and Property
Parcel Map on page 2 of the Appendix). The well is located on land owned by Progress
Partners, Ltd. and is leased to Beaver Wood, who also leases the property near the well
where the biomass facility has been proposed. The well will serve as the source of potable
water for the employees and office staff of the proposed Beaver Wood biomass project.
Typically, the water system would serve a population of about 41 employees. Well
construction and yield characteristics of the well are presented in Table 1. The driller’s well
completion report is included on page 1 of the Appendix.

Table 1: Summary of Well Characteristics

Source ID
Total
Depth
Static
Water I I
Diameter
Pump
Intake .
Well
Screen
Wel1
I
Screen
Slot
Level L
(in) Setting Setting
(It) Size
(ft) (It) ft) (gpm)*
(in)
Beaver
Wood
67 13 18 57 52-67 0.120 626
Gravel I

Well
I I

gpm = gallons per minute


BEAVER WOOD ENERGY POWNAL, LLC.
WSID #25S5
SOURCE PROTECTION PLAN: Gravel WeJI
2

I 2.0 Wellhead Protection Area

A Welihead Protection Area (WHPA) has been designated for the Gravel Well. The WHPA
Map and the Potential Sources of Contamination (PSOC) Map showing Zones 2 and 3 of the
WHPA, the well, and property parcels are located on pages 3 and 4 of the Appendix,
respectively. These maps are presented to provide the overall WHPA delineations on U.S.
Geological Survey topographic (page 3 of the Appendix) and U.S. Department of
Agriculture National Agriculture Imagery Program (NAIP) aerial photographs (page 4 of

the Appendix).

The Welihead Protection Area was hydrogeologically delineated based on information from
prior pump testing conducted on the well. Although the proposed demand for the public
NTNC potable water system would be only 1.1 gpm, a delineated source protection area
based on a 500 gpm pumping rate was used to represent a worst-case scenario in which the
well would also be used as a process water source. In such a situation, the total pumping
rate of the well should be considered in the source protection area delineation, because the
quality o the potable water would be affected by any potential sources of contamination
within the entire zone of influence. Providing a factor of safety, the 500 gpm design
pumping rate is higher than the proposed biomass plant’s normal water consumption rate
of 321.6 gpm, or the peak consumption rate of 465.2 gpm (based on a revised water balance
analysis, September 29, 2010).

The Wellhead Protection Area Zone 2 was delineated by Lincoln Applied Geology based on
the 1994 pump test to represent the capture zone of the existing well pumping at 500 gpm,
during steady.state conditions (i.e. constantly pumping at 500 gpm until the cone of
depression has reached equilibrium and has stopped expanding). This zone 2 indicates the
well’s area of influence, where groundwater levels would be affected by the well.

Zone 3 of the Wellhead Protection Area represents land that is outside of the well’s area of
influence, but that likely contributes recharge water to the well. Groundwater from Zone 3

.VmlassfJIangPnBnsstiin mr
________

BEAVER WOOD ENERGY POWNAL, LLC.


WSID #2585
SOURCE PROTECTION PLAN: Gravel Well
3

passively flows by gravity to the area of influence, where the drawdown caused by the
well’s operation would cause groundwater to flow into the well. VHB delineated Zone 3 as
all land area topographically upslope from the area of influence.

The property parcel mapping for the area encompassed by the WHPA is presented on the
PSOC map included on page 4 of the Appendix. A total of 13 property owners are included
within the WHPA, one of which is the project parcel (see page 5 of the Appendix for a list of
landowners within the WHPA). Private landowners and Progress Partners, Ltd. own most
of the land encompassed within the SPA. Present land uses within the WHPA include the
access roads to the former GMRT grandstands that host a variety of events such as car and
bike shows, concerts, and other large events, US Route 7, and the Boston & Maine Railroad.
Residential buildings are currently located in the WHPA Historically, land within the
WHPA was mainly agricultural, residential, and forested. The GMRT was in operation
during the 1960s through the 1990s. Page 6 of the Appendix provides a list of abutting
property owners.

3.0 Potential Sources of Contamination


I
The PSOCs within the WHPA were identified through site research and inspection, and are
discussed below. All PSOCs are identified on the PSOC map on page 4 of the Appendix.
Page 7 of the Appendix lists PSOC identification and owner information. Table 2 provides a
brief summary of the PSOCs.

Table 2: PSOC Summary


1
I’SOC ID ‘ PSOC Description Risk Level
P5CC 1 Underground Storage Tanks Low
P5CC 2 Historic Leachfield Low
3 Municipal Sewer Line Low
P5CC
P5CC 4 US. Route 7 Low
P5CC 5 Railroad Low
PSOC 6 Stormwater Pond Low
P8CC 7 Lovett Yard Cemetery Low

C
BEAVER WOOD ENERGY POWNAL LLC.
WSID #2555
SOURCE PROTECTION flAN: Gravel Well 4

Table 2: PSOC Summary


PSOC ID PSOC Description Risk Level
r PSOC 8 Grave] Pit Low

As described below, all PSOCs pose a low level of risk to the gravel well.

PSOC #1, Pulled Underground Storage Tanks, low risk: Ruanaidh Realty Corporation is the
responsible party for four underground storage tanks (UST’s) that were removed from the
former Green Mountain Race Track site on November10 and 11, 1993. Three of the pulled
UST’s were located within Zone 2 of the WHI’A, and the closest UST was located
approximately 185 feet away from the gravel well. Initial groundwater and PID test results
showed elevated levels of volatile organic compounds (VOC), benzene, toluene,
ethylbenzene, and xylene (BTEX), and methyl tertiary butyl ether (MTBE) in the immediate
vicinity of the USTs. As a result, the site was designated as Vermont Hazardous Site #93-
1511. Groundwater samples collected the following year before, during, and after a 7-day
long pump test at the GMRT well and six installed monitoring wells contained no detectable
contaminant concentrations. Due to the absence of contamination, the hazardous site was
closed, and the Vermont DEC issued a Site Management Activities Complete (SMAC)
determination on May 2, 1995. Additionally, the gravel well was tested for all contaminants
required for an NTNC water source and no VOCs were detected in samples collected from
the gravel well on August 24, 2010. Risk of contamination to the gravel well is low because
no VOCs have been detected in groundwater at the site.

P5CC #2, Historic Leachfield, low risk: The GMRT formerly operated a leachfield that
served the track manager’s office and was located approximately 530 feet away from the
gravel well. The leachfield is non-operational, and groundwater samples collected on June
4, 2010 and August 24, 2010 contained low concentrations of nitrate measuring 0.36 mg/L
and 0.40 mg/L, respectively. The nitrate concentrations are well below the Vermont
Drinking Water Maximum Contaminant Level (MCL) of 10 mg/L (ANR 2005) and are

J{arnasseJkzngcnfirisfll& Inc
BEAVER WOOD ENERGY POWNAL, LLC.
WSID #2585
SOURCE PROTECrION PLAN: Gravel Well
S

typical of natural ambient levels in groundwater. Therefore, this PSOC is a low risk of
contamination to the gravel well.

P5CC #3, Municipal Sewer Line, low risk: The Town of Pownal operates and maintains an
existing sewer line along US Route 7 that crosses through Zone 3 the WHPA, passing within
950 feet of the well at the closest point. Risk is low because of the significant distance to the
well and because the sewer line was constructed in 2006 following current standards.
Groundwater samples collected on June 3, 2010 and August 24, 2010 contained low
concentrations of wastewater indicators such as nitrate. See PSOC #2 above.

• P5CC #4, Us Route 7, low risk: US Route 7 is a principal arterial highway along the west
side of Vermont that crosses through Zone 3 the WHPA, passing within 950 Feet of the well
at the closest point. Potential leaks and spills from vehicles, along with road salt
application, are potential contamination sources. The risk of contamination to the gravel
well is minimal due to the distance from the well. The low concentration of chloride of 35
mg/L was detected in groundwater samples collected on June 3, 2010. This low chloride
concentration is well below the secondary drinking water MCL of 250 mg/L (ANR 2005).
Likewise, the sodium concentration of 14 mg/L is substantially lower than the 250 mg/L
secondary MCL, indicating tha[ road salt application does not significantly affect the
groundwater quality in the well.

• P5CC #5, Railroad, low risk: The Boston & Maine Railroad owned by Pan Am Southern,
LLC. crosses through Zone 3 of the WHPA, passing within 950 feet of the well at its closest
point. The risk of potential contamination is minimal because the rail system has limited
activities that could contaminate groundwater. Groundwater samples collected from the
gravel well contained no detectable pesticides, herbicides, or synthetic organic compounds
(SOCs), indicating that herbicide application along the tracks has not affected the
groundwater.


BEAVER WOOD ENERGY POWNAL, LLC.
WSID #2585
SOURCE PR0TEc’rloN PLAN: Gravel Well
6

PSOC #6, Stormwater Pond, low risk: An existing pond that was formally used as a
stormwater pond is owned by Progress Partners, Ltd. The pond is located in Zone 3 of the
WHPA within 275 feet of the well at its closest point. The well has been determined by the
VT DEC to be not under the direct influence of surface water. The pond’s location in Zone 3
and the uncontaminated nature of site runoff make it a low risk of contamination to the
well.

• PSOC #7, Lovett Yard Cemetery: The Lovett Yard Cemetery located in Zone 3 of the WHPA
and approximately 1300 feet from the well is owned and maintained by the Town of
Pownal. Cemeteries normally do not pose a significant risk of contaminating groundwater
because proper burial practices involve adequate vertical separation above the water table.
The possible historical and current application of herbicides for grounds maintenance also
makes the cemetery a potential source of contamination. The age and small size of the
cemetery make this a low risk to the gravel well.

• PSOC #8, Gravel Pit, low risk: A portion of the graveL pit is located within Zone 3 of the
WHPA approximately 2000 feet away from the well at its closest point. Possible
contaminant risks include potential spills of fuel, lubricating oil, and fluids from machinery.
The risk is low because gravel extraction is being conducted above the water table. No
VOCs have been detected in the gravel well so it poses a low risk of contamination.

4.0 Management Plan

Management of PSOCs within the WHPA is essential in maintaining acceptable water


quality at the NTNC source. The following mechanisms would help ensure proper
management of the PSOCs.

Notification of Key Town and State Personnel


The following key town, water system, and State personnel must be notified of any potential
water quality threats within the WHPA:

S
BEAVER WOOD ENERGY POWNAL, LLC.
WSID #2585
SOURCE PROTECTION PLAN: Gravel Well 7

Pownnl Town Clerk:


• Ms. Karen Burrington
467 center Street
Pownal, Vermont 05261
(802) 823-7757

Pownal Town Health Officer:


• Mr. James Gilbert
4588 Rte. 346
Pownal, Vermont 05260
(802) 823-7253
Department ofEnvironmental Conservation:
• Mr. David Swift Regional Engineer

DEC Rutland Regional Office


450 Asa Bloomer State Office Building
Rutland, Vermont 05701-5903
(802) 786-5903

• Mr. William Burke Natural Resources Board-Act 250


DEC Rutland Regional Office


450 Asa Bloomer State Office Building
Rutland, Vermont 05701-5903
(802) 786-5923

A sample copy of a letter to be sent to these key personnel notifying them of the
implementation of this SPP, and their responsibilities associated with it, is included on
pages 8 and 9 of the Appendix. This letter would be sent after final approval of this SPP by
the WSD.

Identification and Notification of Landowners within the WHPA


Names and addresses of all landowners within the WHPA are included in the list presented
on page 4 of the Appendix. Following approval of this plan, all landowners would be
notified of their property’s presence within the WHPA, and steps that should he taken to
ensure continued protection of drinking water quality. A copy of a sample letter to be sent
to these landowners notifying them of the implementation of this SPP, and their

J(asasxeRangn Bntstlin Inc —


BEAVER WOOD ENERGY POWNAL, LLC.
WSID #2585
SOURCE PROTECTION PLAN: Gravel Well
S

responsibilities associated with it, is included on pages 10 and 11 of the Appendix. This
letter would be sent after final approval of this SPP by the WSD.

Management of Potential Sources of Contamination


Generally, management of land uses and P5CC within the WHPA would be through public
educational efforts via the letters noted above, which discuss the landowner’s presence
within the WHPA and basic management techniques that can be used to minimize risk to
groundwater quality.

SPP Update
The SF1’ will continue to be updated ever’ three years following approval of this plan. This
would involve an update of the landowner list, PSOC inventory, and updated notification
letters to any new landowners and to the owners/operators of any new PSOC, informing
them of their presence within the WHPA and proper PSOC management techniques. The
listed key personnel would also receive notification letters.

15.0 Contingency Plan

In the event of prolonged contamination, hazardous waste spill event, or catastrophic loss of
the current water supply, the water system operator should follow the contingency plan
described below:

System Failure due to Bacterial Contamination:

1. In the event that water from the well becomes biologically contaminated,
pumped groundwater would be chlorinated before distribution. The well and
storage tank will be shock-chlorinated if samples indicate that the problem
persists.

C
BEAVER WOOD ENERGY POWNAL, LLC.
WSID #2585
SOURCE PROTECTION PLAN: Gravel Well
9

2. The water system operator will obtain samples from the finished water. If
bacterial contamination persists, the well will be deactivated.

3. In the event that the well water is biologically contaminated and is not treatable
with chlorination, potable water will be trucked in from water haulers in the area
and deposited in the storage tank. A list of bulk water haulers is provided in the
Appendix, page 12. This is considered an emergency source of water, and
therefore a boil water notice would be issued, as required by the Vermont Water
Supply Rule (Rule). See page 13 of the Appendix for a sample Boil Water
Notification to be delivered to all residents. The WSD will be notified (1-800-823-
6500) within 12 hours that an emergency source is being used. Bottled water
may also be provided to residents for drinking.

System Failure due to Catastrophic Loss of Supply:

1. The first course of action to be followed if there is a shortage of water is to


determine if it is due to an easily repairable problem (i.e., well pump motor
failure, leaking water main, leaking storage reservoir, or a malfunction with
electronics or controls), or due to a more serious situation (i.e., depletion of the
aquifer or collapse of the well). The operator should initially inspect the water
system to check for leaks, functioning of the control switches and motors, and
proper electrical current to diagnose any water shortage. Measurement of static
and operating water levels in the well, in conjunction with pumping rates, is
recommended to diagnose potential problems with the well and aquifer. Down-
well camera inspection may be useful to determine the nature of well problems.

2. In the event that there is a loss of supply (i.e., severe drought, or collapse of the
well), potable water will he trucked in and deposited into the water storage
reservoir. This is considered an emergency source of water, and therefore a Boil
Water Notification would be issued, as required by the Rule. The WSD will be

C
BEAVER WOOD ENERGY POWNAL, LLC.
WSID #2585
SOURCE PROTECTION PLAN: Gravel Well 10

notified (1-800-823-6500) within 12 hours that an emergency source is being used.


Bulk water haulers are listed on page 12 of the Appendix. See page 13 of the
Appendix for a sample Boil Water Notification to be delivered to all residents.

In the event of prolonged water shortages, the system operator will notify all
water users of the problem, and may require water conservation measures (i.e.,
banning non-essential uses of water). The WSD will be promptly notified of
system failure (1-800-823-6500).

3. Residents will be asked to limit non-essential water usage.

Loss of Water Due to Hazardous Spill Event:

1. The water system operator should contact the following agencies in the event of
a hazardous spill:

• Vermont Water Supply Division, Waterbury VT:


Mr. Dennis Nealon
(800) 823-6500
(802) 241-3411

• Vermont Department of Health, Environmental Health Division:


(802) 863-7220

• Pownal Town Clerk:


Karen Burrington
(802) 823-7757

• Pownal Health Officer:


James Gilbert
(802) 823-7253

• Pownal Fire Department:


(802) 823-7703
911

• DEC Hazardous Materials Spills Hotline


BEAVER WOOD ENERGY 1’OWNAL, LLC.
WSJD #2585
SOURCE PROTECTION PLAN; Gravel Well 11

(800) 641-5005

EPA National Response Center


(800) 424-8802
Vermont
State Police — (Shaftsbury Barracks)
(802) 442-5421

Water System Hydrogeologists:


VHB
(802) 425-7788

2. If a well source is threatened, the well should he immediately deactivated.


Continued use of uncontaminated storage tank volumes may occur under this
scenario; a sample of storage tank water should be collected for laboratory
analysis, to determine if contamination has reached the well/storage tank. The
WSD should be promptly notified (1-800-823-6500).

3. If the well has been contaminated (that is, if contaminant is present in water
pumped from the well to the storage tank) the well will he deactivated, the main
valve to the distribution system will be closed, and the storage tank drained.
X’Vater from taps in the distribution system will he sampled; if contaminated
water has entered the distribution system, users will be notified to consume
bottled water until further notice and the distribution system will be drained.
The storage tank will be refilled using bulk delivery water (bulk water haulers
are listed on page 12 of the Appendix). The storage tank will be sampled for
known contaminants, and draining and refilling of storage tank will be repeated
until water is uncontaminated. The main valve to the distribution system will be
re-opened only when the water in storage reservoir is determined to be
uncontaminated, and the WSD has authorized this in writing. Tap samples will
be obtained from locations in the distribution system until contaminant is not
present, and for longer if required by the WSD. The storage reservoir will
continue to be operated using trucked-in water until the hazardous spill has been


BEAVER WOOD ENERGY POWNAL, LLC.
WSID #2585
SOURCE PROTECTION PLAN: Gravel Well
12

remediated, the well decontaminated, and re-use of the well has been specifically
authorized in writing by the WSD. (Note that a Boil Water Notification shall be
sent to all users as long as trucked-in water is being used).

4. When adequate hazardous spill containrnent/remediation is achieved, the


contaminated well will be pumped to dispose of waste for several hours in order
to purge the well and obtain a confirmatory water sample prior to putting the
well back on-line. The well will be reactivated only after authorization by WSD.

C
BEAVER WOOD ENERGY POWNAL, LLC.
WSID #2585
SOURCE pRoTEcrloN PLAN: Gravel Well
13

References

LAG (1995). Green Mountain Race Track: 7-day Pump Test of the Production Well. Lincoln
Applied Geology, Inc. February 20, 1995.

Vermont Agency of Natural Resources: Department of Environmental Protection, Water Supply


Division (1997). Protecting Public Water Sources in Vermont.

Vermont Agency of Natural Resources: Department of Environmental Protection (2005).


Groundwater Protection Rule and Strategy. Chapter 12. February 14, 2005.

Vermont Agency of Natural Resources: Department of Environmental Conservation (2005),


Environmental Protection Rules, Water Supply Rule, Chapter 21.

F:\57407OO Beaver Wood Powna\reports\SPP_CMRTweII\SPP draft doc


APPENDIX
I I I I 1 I I H,, .1—•-
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-.
flS- D9

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Beaver Wood Energy Pownal, LLC.


fegend Sources: Background USDA NAIl’ Or tho,hou
Pownal, Vermont Benrlrgtcei
-

); Steams and Watarbodiet from VI. Hydrography


Public Water Source —-- Contour 20 ft
-

dalaset and VCCI (2008); Contours horn VHS (2010);


Parcel Boundaries — Contour -tOO ft Site Plan and Property Parcel Map Public Water
Source frornVTANR (2010); parcel boundaries obtained
from
Barrcington County egiorai PtarjdngComrnirurn
— Proposed Site P)an (fl6 Rceds
obtamed 1,0cc Vtrans (2008b Source Soc Plan rovided
— Sfreams (VHD) September 28, 2010 Assodates (9/212010).
by Onno

Watetbody (VHD)
Roads
Feet Vanasse Hangen Brustlin, Inc.
Paupared by: !vUS)LBS
Legend Beaver Wood Energy Pownal, LLC.
S,urcas: Background USC5Topograi-ucai
9 Public WaterSource
Pownal, Vermont -

Ebwnal (2005); public wails and W}OPAa from


Quadrangle North
-

Wellhead Protection Arsa Zone 2 VTANR(2010);


- PrreI Boundades obtained from Bemirsgton
Weithead Protection Area Zone 3
Welihead Protection Area Map Earring Commission (2006k Roads oblained
County Regond
Itan Vtrrs aT
-
j-
2
Project Waimead l’toteclion Area ddineated
by VHS (2010); Panda
O Panel Boundaries September 28,2010
obtained from VT Hydrrgtopby datasetand
VCCI (2 Source
— Proposed Site P)an Sie Plan providedby Bruno Asaooates (9/7)2020).

Ponds
Roads
Vanas,ce Ifangen Rrusth* Inc
P:\57407.DO\CIS\Project\SPP_WNPA_topo.mxd
E- “. _l’e

PSOC t4
US Route 7

P5CC #8
Gravel Pit

• PSOC#6

( Stormwater Pond

——

3..I-c-..4.

14 Pulled USTs I’
II

Historic teachfied
P5CC #5
Boston & Maine Railroad

- it.L.-. i

Legend Beaver Wood Energy 1’ownal, LLC. Sources: Backgrotmd -tS)A NA]?
Orthlmto-3evsingtn (29);
S flftciectoase tin:
Pownal, Vermont
Public Water Sources from VTANR 10); Parcel
&undaries
o b5he.d
PamenItaasdanno
—Cen
0
2 5loo:-
obtained horn Bennington County Regional Plamsing
Commission
(2006); Roads obtained fi-osn VThans (2008); Weilhead
pmovabas Aea zono- o —Casnssr-ISft Potential Sources of Contamination Map Psotechon Area delineated b VHB (2010); Ponds obtained from opr
7
5
EO)StT usdengreced 555:0 Te
Closed t(aaardea Waste Site Fthogrnphy dataset and VCGI (254€); Source
Sit€ Pi
r.ji.d uwlnre.acndsonga re*lrsOCa:)
[Seoric L.athfldd (P5°C P2)
• Avi,eHaadeus wsln age
October 4, 2010
by Bruno Asacciates (9JZflOMO: Historicel LeadiFald
interview (2010); Underound StotageTarth
by Vt-SB I mm
— Proposed Ste Plan s obtained from
VTANR (2006); Hazardous Waste Silos from
Reads (PSOC 045 500 250 0 500 Contours from V518 (2050)
VTANR (2069)
nd,iPsocrS
I
‘Feet
Vanasse Ifangen BrustUn, Inc.
F: 57407 .00\ GlS\ Project 5?? PSOC_Or ib a med
Prepared by: MIS/LBS
Beaver Wood Energy Pownal, LLC.: Source Protection Plan
-
Beaver Wood Energy Pownal, LIC. Water System Property Owners within Welltiead Protection
Area
October 4, 2010

Parcel ID # Site Address Last Name First Name(s) Owner Address


7-34-12 1000 Brookman Road, Pownal, VT 05261 Strong Mason mi Asset Mgt do WM Strong, 477 Madison Ave
WiIIam
8th floor. New Yoriç NY 10022
1-1)57-21 (EWE) US Route 7, Pownar, VT 05261 Progress Partners. Ltd Beaver Wood Energy Pownal, LLC 712 5th Avenue, New York, NY 10019
7-US7-21 .2 US Route 7, Pownal, VT 05261 Lovett Yard Cemetery NA Town of Pownal. 467 Center Street, Pownal, VT 05261
1-US7-22 US Route 7, Pownal, VT 05261 Hart Stephen Trustee, 24 Walnut Street, Williamstown, MA 01267
7-US7-23 141 Purcell Road, Pownal, VT 05261 Pinard Michelyne J 141 Purcell Road, Pownal, VT 05261
7-US7-24 136 Purcell Road, Pownal, VT 05261 Sweet Robert 136 Purcell Dugway, Pownal, VT 05261
15-65-1.1 96 8 Hill Road, Pownal, VT 05261 Morneault Michael & Jean P0 Box 275, Pownal, VT 05261
1 5-65-2 320 B Hill Road, Pownal, VT 05261 Clermont Robert A 320 B Hill Road, Pownal, VT 05261
15-65-4 3648 Hill Road, Pownal, VT 05261 Hall Jean L P0 Box 124, Pownal, VT 05261
1 5-65-5 B Nil Road, Pownali, VT 05261 lannuedllo Anthony J 5 Wood Dale Road, Baliston Lake. NY 12019
15-65-6 3828 Hill Road, Powna’, VT 05261 Kiemm George M Ill North Street, Williarnstown, MA01267
Boston & Maine Railroad NA Pan Am Southern LLC NA
J 1700 Iron Horse Park, North Billerica, MA 01862

US Route 7 NA Vermont AOT NA National tile Building, Drawer 33, Montpeil)er, VT 05633
f
Beaver Wood Energy Pownal, LLC. Source Protection Plan
-
Beaver Wood Energy Pownal, LLC. Water System Abutting Property Owners
October 4, 2010

Parcel ID # Site Address Last Name First Name(s) Owner Address


6-9-26 824 Northwest Hill Road. Pcwral VT 05261 Nich cit as Deborah_,,,,,,,,,j,_______ P0 Box 178. Powial, VT 05261
I’S’S 2 I 151 NorlF’west Hill Road, Powra VT 05261 Lyille Pamela 1151 Northwest Hilt Road, Pownal, VT 05261
7-9,39 1503 Northwest Hill Road. Pownal, VT 05261 Peaslee Dearwa 1503 Northwest Hill Road. Pownal, VT 05261
7-9.40 24 Poor Mans Road, Pownal, VT 05261 Porter & Mason Shelley & Jill 24 Poor Mans Road, Pownal, VT 05261

7’US7.18 21 Cash Place, Pownal. VT 05261 Smith Cherie 21 Cash Place. Pownat, VT 05261
7-US 1.2’ US Route 1, Pownal, VT 05261 Progress Partners, .,td NA 712 5th Avenue, New York, NY 10019
7.US7’21.1 (8WE) US Route?, Pownal, VT 05261 Progress Partners. Ltd. Beaver Wood Energy Pownal. LLC 158 Westmoreland Ave. White Plains, NY 10606
7’U57.21 .1 US Route 7, Pownal, VT 05261 Tietgens John & Heather 473 Men Steet, Stamford, VT 05352
74,15721 .2 US Route 7, Pownal, VI 05261 Lovett Yard Cemetery NA Town of Powrial. 467 Center Street. Pownal, VT 05261
7-1)57-22 US Route?, Pownal, VT 05261 Hart Stephen Trustee. 24 Walnut Sheet, Williamstown, MA 01267
15-1’12 39 Church Street, Pownal, VT 05261 NWP Inc
[ NA c’o Robert L. Kobelia, 2340 West Road, Bennington, VI’ 05201
15-1-13 chSIeet,°ovn’0526 Winchester James & Vernelle P08o*22. PoemS, VT 05251
15-9-19 498 Northwest Hill Road. Pownal VT 05261 Polled i’en’y 498 Northwest I-ill Road, Pownal, VT 05261
15-9-24 719 Northwest Hill Road. Pownal, Vi’ 05261 Tan zm an living 719 Northwest Hill Road, Pownal, VT 05261
15-US7’25 6275 US Route 7. Pownal. V’F 05261 Pedercini Keith & Jeanne PG Box 167, Pownal, Vi’ 05261
1 5-U 57 ‘30 US Roi,te 7. °owrwl VT D52E .
Mi a’d Mobile Honie Part, LLC NA 34 Ashlaed Street, No.111 Adams, MA 01247
1 5’65.1 .1 966 Hill Road. Poeral, VT 0525’ Pcrreaut Michael & Jean PG Box 275. Powr’al. ‘IF 0526’
15-34 6’ 1 Route 346, Pownel, VT 05261 Ala Garden Estates MHP Inc NA 101 Trernont Street, Berre, VT 05641
I S’PIJMPPV. I 215 Sunflower Street, Pownal, VT 05261 Pownal WWTF NA PG Box 128, North Pownal, VT 05260
Bostur & Mere Railroad NA Pan Am Southern LLC NA 1700 Irors Horse Part. North Billenca, MA 01862
US Route 7 Vermit AOT NA Nafional Life Boiling. Drawer 33, Montpealior, VT 05633
7

Beaver Wood Energy Pownal, LLC.: Source Protection Plan


NTNC Water System (WSID # 2585) PSOC Inventory -

October 4, 2010

List of Potential Sources of Contaminations (PSOC)


PSOC # Description Comments Risk Level
. Removed November 10-11,
1993, no VOCs detected in
J
Green Mountain
groundwater water quality
Race Track
test, Owner: Progress Low
Underground
Partners, Ltd., Site: Lovett
Storage Tanks
Cemetery Rd. Pownal, VT
05261
. Non-operational, low nitrate
! levels detected in
Green Mountain groundwater water quality
2 Race Track test, Owner: Progress Low
Historic Leachfield Partners, Ltd., Site: Lovett
F Cemetery Rd. Pownal, VT
I 05261
. Owner: Town of Pownal
Municipal Sewer i Low
3 Site: Adjacent to Route?
Line
Pownal, VT 05261,
. Owner: Vermont AOL Site:
4 USRoute7 Low
Route 7 Pownal, VT 05261
-

I • Owner: Pan Am Southern,


3 Railroad LLC., Site: Boston & Maine Low
Railroad Pownal, VT 05261
Green Mountain • Non-operational, Owner:
6 Race Track Progress Partners, Ltd., Site: Low
Storrnwater Pond Green Mountain Race Track
I Lovett Yard
• Owner: Town of Pownal
7 Site: Route 7 Pownal, VT Low
Cemetery
05261
• Gravel extraction completed
above water table, Owner:
8 Gravel Pit Steven M. Hart Low
I Site: Route 7 Pownal, VT
05261

F\57407.OO Beaver Wood Poal\repoits\SPP OMRTweII\PsOc Table.docx


8

Vanasse Hangen Brustiin, Jnc.


Transportation Environmental Land Development Services

October 6, 2010

Ref.: 57407.00

Town of Pownal
c/o Karen J. Barrington
467 Center Street
Pownal, Vermont 05261

Re: Beaver Wood Energy Pownal, LLC.


Public Non-Transient, Non-Community Water System WSID #2585 -

Pownal, Vermont
Source Protection Plan Notification

Dear Ms. Burrington:

Enc’osed please find a map showing the Welihead Protection Area (WI-WA) for Beaver
Wood Energy Pownal, LLC.’s Non-Transient, Non-Community (NTNC) Water System
(WSID #2585) located in Pownal. A Source Protection Plan (SPP) has been developed
for the water source to help protect the groundwater quality within the WHPA that has
been mapped for the water source. Activities within the WHPA have the potential to
affect the groundwater quality of the NTNC water supply source.

Because you and the other recipients of this letter may be involved in making land use
decisions for the Town of Pownal, this notification serves to make you aware of the
presence of the WHPA so informed decisions can be made concerning any proposed
land uses that have the potential to threaten groundwater quality.

It would be greatly appreciated if you would keep the appropriate officials of the Town
of Pownal and of Beaver Wood Energy Pownal, LLC. informed of any planning and
decision processes that have the potential to introduce potential sources of
contamination within the WHPA. Prevention of contamination is extremely important,
as the cleanup of contaminated groundwater is extremely difficult and costly.
9

VOIIC1SSL’ Ilazige;i Bins//tn, Inc

Ms. Karen J. Burrington


Ref: 57407.00
Page 2
October 6, 2010

Thank you very much for your attention to this matter. The SPP is a working and
changing document and it can only be kept truly up-to-date if we are thformed of
activities within the WHPA. Please do not hesitate to contact us with any questions,
comments, or iriforrrtation you may have.

Sincerely,
VANASSE HANGEN BRUSTLIN, INC.

Meredith Simard
Environmental Scientist

cc: Gregory Burke, Bennington County Regional Commission


James Gilbert, Pownal Health Officer
William Burke, Natural Resources Board Act 250 —

David Swift, OEC Regional Engineer


Dennis Nealon, DEC Water Supply Division
Bill Bousquet, Beaver Wood Energy Pownal, LLC.

F-\574W CC Beave Wood PownaI\re rtsSPPCMRrweU.Otflc,als ocx


10

Vauasse Hangen Brustlin, lnc.


Transportation I Environmental J Land Development Services

October 6, 2010

Ref.: 57407.00

Mr. William Strong


Mason Hill Asset Management c/o WM Strong
477 Madison Aye, 8th Floor
New York, NY 10022

Parcel #6-9-26

Re: Beaver Wood Energy Pownal, LLC.


Public Non-Transient, Non-Community Water System WSID #2585 -

Pownal, Vermont
Source Protection Plan Update Notification

Dear Mr. Strong:

Vanasse Hangen Brustlin, Inc. (VHB) of North Ferrisburgh, Vermont is working with
Beaver Wood Energy Pownal, LLC. (Beaver Wood) to develop a program to protect the
water quality of the water supply source associated with the Public Non-Transient, Non-
Community (NTNC) Water System (WSID #2585) that will serve the proposed Beaver
Wood biomass facility. The NTNC source consists of a gravel well. VHB has developed
a Source Protection Plan because groundwater quality can be affected by activities that
take place on the ground surface throughout the Welihead Protection Area (WHPA) that
has been mapped for this gravel well.

As shown on the enclosed Welihead Protection Area map, your property has been
identified as being located within the WI-WA. Therefore, it is important that activities on
your property do not discharge contaminants that may threaten groundwater quality.

Some concerns include accidental chemical spills (e.g., paint thinner, gasoline, and oil)
that ma;’ occur during routine maintenance activities. Also, releases from fuel storage
tanks that may be used for the storage of heating oil are a serious concern. All attempts
should be made to minimize or eliminate these types of releases. Household hazardous
11

lt?nasse Hangen BrusH/n, Inc

Mr. William Strong


Ref: 57407.00
Page 2
October 6, 2010

materials should be disposed of on Household Hazardous Waste Collection days (free)


and should never be disposed of into a sewer or septic system or onto the ground. The
use of pesticides, herbicides, and fertilizers should be minimized or eliminated if
possible.

The potential contaminants discussed here are some common examples, and are by no
means an exhaustive list. As part of the maintenance of high quality groundwater for
the Beaver Wood water system, we are requesting that you please do your best to
minimize release of contaminants within the WHPA. In the event of any spills or
contamination on your property, please notify Beaver Wood and the Town of Pownal
immediately.

If you have any questions concerning further information available to help you adopt
these preventative measures, please do not hesitate to contact us. Thank you for your
attention to this matter.

Sincerely,
VANASSE HANGEN BRUSTLIN, INC.

Meredith Simard
Environmental Scientist

cc: Karen J. Burrington, Pownal Town Clerk


Bill Bousquet, Beaver Wood Energy Pownal, LLC.

F. ?4O7 20 3,am Wo Farna. repDr.5FP_GMRTw.:: 015rnas oa


•.. •.
12

Bulk Water Suupliers:


• Aqua Clear Pool Water
Valley Falls, New York
(518) 663-9010

• Bennington Pool, Spa & Hearth


Bennington, Vermont
(802) 442-5237

• Knight Tubs, Pools, & Spas


Ludlow, Vermont
(802) 228-2260

Suppliers of Bottled Water:


• Monadnock Mountain Spring Water
Wilton, New Hampshire
(603) 654-2728

• Leader Distribution Systems, Inc.


Brattleboro, Vermont

(802) 257-0847

• Water of Sands Springs


Williamstown, Massachusetts

(413) 458-8281

F.\5?4e7oo Beaver Wood Pownal\reports\SPP.CMRTweII\Water Suppliersdocx


13

DRINKING WATER WARNING


Beaver Wood Energy Pownal, LLC.
Public NonTransient, Non-Community Water System
Water is Contaminated with Coliform Bacteria

BOIL YOUR WATER BEFORE USING


Total coliform bacteria were found in the water supply on [Date 1. Total coliform bacteria are
generally not harmful themselves, but indicate that other bacteria that can make you sick may be
present in the water. These bacteria are a particular concern for people with weakened immune
systems.
Or,
Due to problems with the water supply well, the water system is using trucked-in bulk water as an
emergency source of drinking water. This trucked-in water is not approved for use as a source of
public drinking water, and may contain bacteria.

What should I do?

• DO NOT DRINK THE WATER WITHOUT BOILING IT FIRST. Bring all water to a boil, let it boil
for one minute, and let it cool before using, or use bottled water, Boiled or bottled water should
be used for drinking, making ice, brushing teeth, washing dishes, and food preparation until
further notice. Soiling kills bacteria and other organisms in the water.

• Co//forms are bacteria which are naturally present in the environment and are used as an
indicator that other: potentially-harmful, bacteria may be present. Cob forms were found in fore
samples than allowed and this was a warning of potential problems.

• People with severely compromised immune systems, infants, and some elderly may be at
increased risk. These people should seek advice about drinking water from their health care
providers. General guidelines on ways to lessen the risk of infection by microbes are available
from EPA’s Safe Drinking Water Hotline at 1 (800) 426-4791.

What happened? What is being done?

Bacteria contamination can occur when increased run-off enters the drinking water source (for
example, following heavy rains). It can also happen due to a break in the distribution system (pipes) or
a failure in the water treatment process.

We will inform you when tests show no bacteria and you no longer need to boil your water. We
anticipate resolving the problem within [ESTIMATED TIME FRAME________________
1
For more information, please contact [ENTER NAME of CONTACT] at [ENTER PHONE NUMBER] or
[ENTER MAILING ADDRESS1. General guidelines on ways to lessen the risk of infection by microbes
are available from the Water Supply Division at (800) 823-6500.

Please share this in formation with all the other people who drink this water, especially
those who may not have received this notice directly (for example, people in apartments,
nursing homes, schools, and businesses). You can do this by posting this notice in a
public place or distributing copies by hand or mail.

This infcrmation is being sent to you by Beaver Wood Energy Powna’, LLC.
Date Distributed: [DATE 1.
=-.51407ca Bs a,,-
Wooc e:a.ssrp
SVR.we’•.9D,lWaer errçlae d:cx
_

STATE OF VERMONT

PUBLIC SERVICE BOARD

Petition of Beaver Wood Energy Pownal, LLC


for a Certificate of Public Good, pursuant to 30
V.S.A. § 248, to install and operate a Biomass )
Energy Facility and an integrated wood pellet )
manufacturing facility located north of the old Dock e t N 0.
)
Green Mountain Racetrack in Pownal, Vermont, )
to be known as the “Pownal Biotnass Project”

PREFILED TESTIMONY OF
MEDDlE PERRY

Exhibit BWEP —MP- 7

Two Year Travel Analysis: Domestic Wastewater


Transportation
Land Development
Environmental
$ e r vices

7056 US Route 7
7; Vasiasse 1-Icengen Th’ustIin, Inc. Post Office Box 120
Nonh Ferrisburgh, Vermont 05473
Memorandum
802.425.7788
FAX 802.425.7799

To: Beaver Wood Energy Pownal, LLC Date: October 18, 2010
Permitting File
Project No: 57407.00

From: Meddle 1. Perry, CGWP Re: Domestic Wastewater Leachfield:


Two Year Time of Travel Analysis

This memorandum evaluates the proposed domestic wastewater leachfield


for the
Beaver Wood Energy Pownal, LLC biomass facility. The leachfield site is within
the
Welihead Protection Area for the Alta Garden Estates Mobile Home Park (MHP)
, WSID
#5628. This public community water system (PCWS) is supplied by a drilled
bedrock
well. The hydrogeologic investigation performed by VHB Pioneer has determined
that
groundwater from the proposed leachfield will not reach the Alta Gardens well,
or any
other existing water supply well, and therefore the leachfield site meets the
applicable
regulatory requirements, and does not pose a risk to any existing water supply
well.

Regulatory Background

The 2007 Vermont Wastewater System and Potable Water Supply Rules require
septic
systems and leachfields to meet isolation distances to wells (section 1-807(a]).
These
Rules do not prescribe a specific isolation distance, but rather refer to “the
Department
of Environmental Conservation’s Water SupplY Division for isolation distances
relative
to a public community water supply.’ Isolation distances for a public community
water
supply are then specified in the 2005 Vermont Water Supply Rule, section A-3.3,
which
specifies an isolation distance equal to “a minimum of a two year travel
time in
saturated materials,” for “on site sewage disposal systems located within the
recharge
area.” The two-year travel zone is required to provide protection from
sewage
pathogens. and is based on the lifespan of the pathogens. The ‘recharge area’
for a
l’Vjnc,sse Jla;zeei theist/ire, Inc

RE: Domestic Wastewater Leachfield: Two Year Time of Travel Analysis


Date: October 18, 2010
Page 2 of 11

public community water system such as Alta Garden Estates is delineated


as the
welihead protection area (WHPA).

Work Performed

To evaluate the geology and hydrogeology of the site and to assess the two-year
travel
requirement, VHB reviewed the information on file at the Vermont Depart
ment of
Environmental Conservation, Water Supply Division, analyzed topographic
and
bedrock geologic maps, and evaluated the potential impacts to the Alta Garden
s well
from the proposed wastewater leachfield on the project site.

o VT-lB performed a GIS analysis by georeferencing the engineering plans


for the
Beaver Wood project and superimposing them over aerial photog
raphs,
topographic contours, and surficial geology. Locations of public wells
and
wellhead protection areas were depicted on the maps. The GIS-based
map is
provided on page 1 of the Attachment.

• VHB reviewed the information on file at the Vermont DEC. Water


Supply
Division concerning the Alta Gardens water system. Information regarding
well
construction characteristics, geology, water usage, delineation of the WHPA
and
two-year travel zone, the most recent Source Protection Plan, and water
quality
were evaluated (see pages 2 to 13 of the Attachment). The file review
obtained
the well completion report, Permits, sanitary surveys, correspondence,
a Source
Protection Plan, and an Engineering Evaluation Report.

• VHB reviewed prior hydrogeologic studies conducted at the Beaver Wood


site,
including testing of the gravel water supply well and installation
of monitoring
wells (Lincoln Applied Geology, 1995). Refer to page 14 of the Attach
ment for
the well driller’s report for the Beaver Wood site well.

o VHB installed 6 monitoring wells in the unconfined water table in the vicinit
y of
the proposed leachfield. See pages 15 to 23 of the Attachment for drilling
reports

F\574O7 00 Beaver Wood Fownal \docs\ memos’ two-year_travel


ItlflUSS& ikngeii /3;?! s/I/n, inc

RE: Domestic Wastewater Leachfield: Two Year Time of Travel Analysis


Date: October 18, 2010
Page 3 of 11

and soil logs. Page 24 of the Attachment shows the well locations on a map. The
monitoring wells were tested to determine the depth to the water table, ambient
groundwater quality, groundwater flow direction, permeability, and flow
velocity in the water table.

Monitoring wells were surveyed by Bruno Associates in collaboration with VT-lB


to establish their precise locations and elevations. This information was used to
determine groundwater elevations and gradient.

• Permeability tests (“K-tests”) were conducted by VHB at 8 locations to measure


the permeability of the soils in the unconfined water table. See page 24 of the
attachment for a map showing the K-test locations; data are on pages 25 to 26.

• Groundwater levels were measured by VHB using an electronic water level


probe, to the nearest 0.01 foot below the top of each monitoring well casing.
Using the surveyed elevations of the top of each monitoring well casing, the
elevation of the groundwater table was determined. Page 27 of the Attachment
presents water level and elevation data.

• The groundwater elevations were used by VHB to generate the groundwater


contour map shown on page 24 of the Attachment.

• VHB reviewed the report of a hydrogeologic study conducted by Lincoln


Applied Geology (LAG) in 1994 and 1995. LAG had installed two groundwater
monitoring wells in the vicinity of the proposed leachfield and additional
monitoring wells to the south near the site’s gravel supply well, and had
water

measured groundwater flow directions. Contour maps from the Lincoln


Applied Geology Report (1995) are provided on pages 28 and 29 of the
Attachment, and show a westward groundwater flow in the water table, toward
the Hoosic River.

[F;\574fl7 Seav,r Wood Fownal \docs\memos\ two-yearjraveldocJ


I4qim$se Hc.tiiç’en BnLdUu;z, Inc

RE: Domestic Wastewater Leachfield: Two Year Time of Travel Analysis


Date: October 18, 2010
Page 4 of 11

• Based on the groundwater contour mapping and the measured permeability, the
groundwater gradient, flow direction, flow velocity were calculated as shown on
pages 30 to 32 of the Attachment.

o Finally, VHB developed a conceptual model of the hydrogeology of the area.


The conceptual model, described below, explains the locations, origins, and flow
of groundwater at the site.

Site Description

The site is located along the bottom of the Hoosic River Valley, near the floodplain.
Because the 2007 Wastewater Rules prohibit siting leachfields in floodways, it was
necessary to propose the leachfield at a location outside the floodway that is within
zone 3 of the WHPA for the Alta Gardens bedrock well. The leachfield site is
approximately 1,000 feet downslope of the well.

Site Geology and Hydrogeology


At this location, surface soils consist of sand and gravels to depths of approximately ten
to twenty feet below grade. Beneath the sands and gravels, the soils grade finer to silts
and clays. The well completion report from the Alta Gardens well indicates that the
clay layer is 40 feet thick (see pages 2 and 3 of the Attachment).

An unconfined water table is present, between approximately 7 and 12 feet below


grade, in the sand and gravel soils above the silt and clay layer. Groundwater in
the
water table flows westward at a gentle gradient towards the Hoosic River, and
discharges to the River.

Bedrock at the site is buried approximately 60 feet below the clay, silt, sand, and gravel
surficial materials. According to the Centennial Geologic Map of Vermont (1961),
bedrock at the site is comprised of the Ordovician-age Bascom formation,
and
undifferentiated Luke Hill, Naylor Ledge, and Hastings Creek Limestones, which
consist of interbedded dolomite, limestone, and marble; calcareous sandstone, quartzite,

[F:\5?40?OO Beaver Wood Poe7IaL\docs\memO5 \two-year_traveLdocj


l’iizcisse !Icingc’n I3ri,stlin, Ijic

RE: Domestic Wastewater Leachfield: Two Year Time of Travel Analysis


Date: October 18, 2010
Page 5 of 11

and limestone breccia. To the west of the leachfield site, bedrock


is identified as the
Ordovician-age Hortonville formation, which consists
of black, carbonaceous and
pyritic slate and phyllite, which is locally sandy, and comm
only contains brown
weathered limy beds near the base. Yields of drilled bedrock wells
in the area are fairly
low; the Alta Gardens Estates Delineated Source Protection Area report
(ANR, 2002)
identifies twelve nearby wells that were analyzed to characterize the
geology of the area
(see pages 7 and 8 of the Attachment). As summarized in the table below, the average
yield of these area wells was 10 gallons per minute (gpm), with severa
l wells yielding
zero, 1, or 2 gpm. This information indicates that the bedrock aquifer at the site
yields
low amounts of water. A low-yielding well typically is the result of
a low-permeability
and low-transmissivity aquifer, and creates a small area of influen
ce because flow is
limited.

Table 1: Area Well Summary


from 2002 Report by Vermont ANR, DEC, Water Supply Division
RE Alia Gardens MI-Il’ Source Protection Area Delineation
Well Well Yield Depth to Well
Number (gpm) Bedrock (it) Depth (It) Note

1 1 26 500
14 3 12 155

ii
156 15 60 170 Alt Gardens Well
256 15 gravel& clay 117
252 30 99 200
318 2 10 502
324 30 75 100
349 15 60 125
Excluding well p256 (gravel well), the
Mean 10 34 251 yield of the bedrock wells is 9 gpm
Mm 0 4 100
Max 30 99 502

[F:\57407.OO Beaver Wood PownaI\docs\memos\two-yearjraveldocj


I a;ta%c JJcuie’i Thus/fiji flu

RE: Domestic Wastewater Leachfield: Two Year Time of Travel Analysis


Date: October 18, 2010
Page 6 of 11

Proposed Leachfield
The proposed leachfield has been designed for a peak daily flow rate of 980 gallon
s per
day (gpd). The leachfield would discharge through the unsaturated sand and
gravel
soils to the shallow water table, from where the groundwater flows west toward
s the
Hoosic River. The Alta Gardens well is located about 1,000 feet east and upslop
e from
the leachfield site.

Alta Gardens Well


The Alta Gardens Estates MHP PCWS well is a drilled bedrock well with a
yield of 15
gpm reported by the driller, and a total depth of 170 feet. Bedrock was encoun
tered 60
feet deep beneath layers of gravel and clay. The static level was reporte
d as 30 feet
below grade. See the well completion report on pages 2 and 3 of the
Attachment.
According to the Permit to Operate the Alta Gardens Estates water system
(October 20,
2004), the well is not under the direct influence of surface water.

The Permit to Operate states that the water system has 56 connections
and serves
approximately 137 people. Demand is specified as 3,596 gpd on average,
and 10,800
gpd maximum, based on meter readings. An Engineering Evaluation
of the Alta
Garden Estates Water System (Wright Engineering, 2001) explains that the major
water
system components consist of a bedrock well, a control building, underground
two

7,000-gallon precast concrete storage tanks, booster pumps, and disinfection


equipment.
The water is treated prior to storage with sodium hypochlorite for disinfe
ction and
polyphosphate for corrosion control. This report notes that “there is a
significantly
thick clay layer overlying the bedrock aquifer, helping to protect it from surface
water
contamination”.

The wellhead protection area for this well was delineated by the Vermont DEC
in 2002.
The report of the delineation methodology and calculations is attached
on pages 4
through 13 of the Attachment. Zone 11 of the WHPA, representing the well’s
area of
influence, was delineated using the Uniform Flow Equation (Todd, 1980)
to calculate
the area impacted by the pumping of the well, based on the well’s pumping rate,
the
aquifer permeability, and the hydraulic gradient, or slope of the groundwater
as it
F:\52407.OO Beaver Wood Pownal\docs\ memos \ rwo-)’eartraveldocl
l’anci sse Ilcingc;i in re%tlitt Inc

RE: Domestic Wastewater Leachfield: Two Year Time of Travel Analysis


Date: October 18, 2010
Page 7 of 11

flows. The report delineated the two-year travel zone around the well, which was equal
to the WHPA Zone II. Noting that the groundwater flows westward toward the Hoosic
River at a gradient of 0.16, the DEC report calculated the downgradient extent of the
well’s pumping influence. This distance was determined to be 200 feet from the well,
indicating the westward extent of the two-year travel zone. This report also used the
uniform flow equation to determine the lateral (north to south) extent of the two-year
travel zone as being 800 feet from the well. Additionally, the report calculated the
upgradient extent of the two-year travel distance as 1170 feet east from the well.

The Permit to Operate notes that there are 2 septic systems within 150 feet of the Alta
Gardens well, but that water quality tests show no evidence of source contamination.
The Source Protection Plan identifies these septic systems as belonging to Alta Gardens.
Nitrate, which is an indicator of contamination from sewage and septic systems, has
frequently been monitored in the Alta Gardens Well. Out of 32 samples of water from
the well that have been tested for nitrate since 1990, nitrate has only been detected in 7
samples. The highest detected nitrate level was 121 mg!L, which is significantly lower
than the Maximum Contaminant Level of 10.0 mg/L. Nitrite has been monitored six
times since 1990 and has not been detected (see data, page 33 of the Attachment). The
lack of contamination in the well despite proximity of these septic systems indicates the
effectiveness of the clay layer at protecting the bedrock aquifer from surface
contaminant sources.

In summary, the DEC WHPA delineation report identified the two-year travel zone
surrounding the Alta Gardens Well as a zone extending 200 feet west of the well, 800
feet north and south of the well, and 1,170 feet east of the well. The proposed leachfield
site is located 1,000 feet west of the well and is therefore outside the two-year travel
zone. Groundwater from the leachfield flows west, away from the welL

Other Area Wells


No other water supply wells are located in proximity to the proposed leachuield site.
There are no private wells located between the leachfield site and the groundwater

[F. 5?4G7 00 Beaver Wood Pownal\docs\memoa\two_ycarrravel.docl


-Th

(yr T’CIflfl%’.C I/an ç’eiz /31 us/un tnt

RE: Domestic Wastewater Leachfield: Two Year Time of Travel Analysis


Date: October 18, 2010
Page 8 of H

discharge zone along the Hoosic River. The leachfield site is not within the WHPA
for
any other public water supply xvell.

An existing gravel well on the subject property is being proposed for use as the
supply
well for the Beaver Wood Energy project. This well is located about 2,500 feet south
of
the leachfield site. A proposed WHPA for this well has been hydrog
eologically
delineated, based on the results of a pumping test, and is at least 2,400 feet away
from
the leachfield site at its closest point (see map, page 1 of the Attachment). The
driller’s
well report for this well is on page 14 of the Attachment; a layer of clay and silt reporte
d
from 30 to 41 feet below grade, consistent with the Alta Gardens well log, indicat
es the
regional presence of a layer of low permeability materials below the unconfined
water
table, protecting the underlying gravel and bedrock aquifers from surface activit
ies.

Hydrogeologic Study

Results:
a The GIS mapping indicated that surficial materials at the project site and
Alta
Gardens consist of alluvium (silt), and clay. In the higher terrain outside
the
valley bottom, more permeable materials such as sand, glacial till, and
kame
deposits (sand and gravel) are present enabling groundwater recharge.
See the
Surficial Geology Map on page 1 of the Attachment.

• Prior hydrogeologic studies conducted at the Beaver Wood site indicat


e a
westward groundwater flow direction towards the Hoosic River
in the
unconfined water table. The regionally extensive clay layer was confirmed
in the
LAG study (Lincoln Applied Geology, 1995) and in the well completion
report
from the Beaver Wood site well (See page 14 of the Attachment).

• Soil logs from the 6 monitoring wells that VHB installed in the unconfined
water
table in the vicinity of the proposed leachfield indicate that the water
table is
present in sand and gravel materials that extend to depths of approximately
10 to

F:\574O7OO Beaver Wood Pow,,al\ docs\meinos\nvo-year_traveIdor


li/tdS5U J1ciiiçc’ii Iii I(st!t/7 fin

RE: Domestic Wastewater Leachfield: Two Year Time of Travel Analysis


Date: October 18, 2010
Page 9 of 11

20 feet below grade. See pages 15 to 23 of the Attachment for drilling reports
and
soil logs. Page 24 of the Attachment shows the well locations on a map.

• Permeability tests (“K-tests”) conducted by VHB determined an


average
permeability of 18.2 ft/day in the upper sand and gravel layer. This
permeability
is within the low end of the typical range for these materials. See page 24
of the
attachment for a map showing the K-test locations; data are on pages 25
to 26.

• Groundwater elevation measurements indicated that the unconfined water


table
is found between 7 and 12 feet below grade in the vicinity of the
proposed
leachfield. The water table flows westward at a gradient of 2.5 percent
between
this location and the Hoosic River. Refer to the groundwater contour map
shown
on page 24 of the Attachment, and groundwater elevation data on page
27. A
flow velocity of 1.2 ft/day was determined for groundwater in the water
table.
Due to the low permeability of the underlying silt and clay materials, a
70-year
travel time was determined for groundwater vertically infiltrating
to the
underlying bedrock (see pages 30 to 32 of the Attachment).

Hydrogeologic Concepbial Model


Site geology ensures that activities at the Beaver Wood site will not affect
the Alta
Gardens bedrock well. An extensive layer of clay overlying the bedrock
protects the
bedrock aquifer from infiltration of surface activities and shallow ground
water. The
unconfined water table is present above the clay layer in sand and gravel
surficial
materials, as determined by monitoring well installation and testing at the Beaver
Wood
site. Above the clay layer, groundwater in the unconfined water table in the
vicinity of
the proposed leachfield flows westward, away from the Alta Gardens
well and away
from the Beaver Wood project well.

GIS mapping indicates the presence of alluvial materials, silt, and clay, in
the valley
bottom underlying the Beaver Wood site, consistent with the results of the
monitoring
well drilling. Well completion reports for the Alta Gardens well and the Beaver
Wood
project well indicate a thick clay layer above the bedrock.

fF\5?407.OO Beaver Wood PowraI\docs\memos\twoyear_traveIdocJ


Vanasse Jiangen Bras/I/n. Jiw

RE: Domestic Wastewater Leachfield: Two Year Time of Travel Analysis


Date: October 18, 2010
Page 10 of 11

The Alta Gardens bedrock well’s area of influence and a two-year travel zone around
the well were delineated by the Vermont DEC, and the proposed leachfield site is
approximately 800 feet outside of these zones. Water in the bedrock aquifer supplying
the Alta Gardens well originates as recharge east of the well in the hills within its
WHPA. Groundwater in the vicinity of the Alta Gardens Well and the Beaver Wood
site flows westward to the Hoosic River, and the leachfield site is located west of the
Alta Gardens well, at a downgradient location outside the area of influence.

Permeability of the sand and gravel in the water table was measured to be 18.2 feet per
day (ft/day). The groundwater gradient is reported to be 16 percent for groundwater
flowing to the Alta Gardens well from the high terrain to the east. At the leachfield site
the measured gradient of 2.5 percent is gentler, as the gradient flattens along the valley
bottom near the Hoosic River. The groundwater flow velocity is reported to be 1.6
ft/day for groundwater flowing to the Alta Gardens well from the high terrain to the
east (DEC. 2002). The groundwater flow velocity from the leachfield westward to the
River was calculated to be 1.2 ft/day. Groundwater recharging vertically through
the
clay layer to the underlying materials would take approximately 70 years.

Conclusions

There is no hydrologic connection between the proposed leachfield site and any existin
g
water supply well. The leachfield site is outside of the delineated two-year travel
zone
for the Alta Gardens MHP water system, and is outside of the WI-IPAs of all other
public water supply wells, including the proposed WHPA for the Beaver Wood Energy
project well. Therefore the leachfield site is outside of a two-year travel distance from
any well, and complies with the permitting requirements of the 2007 Vermont
Wastewater System and Potable Water Supply Rules, and the 2005 Vermont Water
Supply Rule.

Ft\57407.OO Beaver Wood PownaI\docs\ memos\two-yesrjraveldoc)


Vanasse Han çeii I$rustlin, Inc.

RE: Domestic Wastewater Leachfield: Two Year Time of Travel Analysis


Date: October 18, 2010
Page 11 of 11

References Cited

LAG (1995). Green Mountain Race Track: 7-day Pump Test of the Production Well.
Lincoln Applied Geology, Inc. February 20, 1995.

Todd, D.K., 1980. Groundwater Hydrology. John Wiley & Sons, New York.

Vermont Agency of Natural Resources: Department of Environmental Conse


rvation,
Water Supply Division (1997). Protecting Public Water Sources in Vermont.

Vermont Agency of Natural Resources: Department of Environmental Conse


rvation,
Water Supply Division (2002). Alta Gardens Estates MHP (WSID 5628) Deline
ated
Source Protection Area.

Vermont Agency of Natural Resources: Department of Environmental Conse


rvation
(2005). Groundwater Protection Rule and Strategy. Chapter 12. February 14,
2005.

Vermont Agency of Natural Resources: Department of Environmental Conse


rvation
(2005),
Environmental Protection Rules, Water Supply Rule, Chapter 21.

Vermont Agency of Natural Resources: Department of Environmental Conse


rvation
(2007). Environmental Protection Rules, Chapter 1: Wastewater System and
Potable Water Supply Rules. Effective September 29, 2007.

Vermont Geological Survey, 1961. Centennial Geologic Map of Vermont.

Wright Engineering, 2001. Evaluation of the Alta Garden Estates Water System
WSID
#5628.

[F;\5740?OO Beaver Wood Powna \docs\mernos\owc-year_trave1.doc


ATTACHMENT

(
‘I’ 1’
Fl:

Sources: Badcground VSDANAW Orthophoto


-

Beaver Wood Energy Pownal,


!
Becell.rgtms (29); public web ord WNPKs from VTANR
• Public Water Source — Contour-lOft Z10);
Parcel Boundaneo obtained from Belulingoon Crursty
Regice-al
WHPA- Zone I —Coctour-1ft
Two-Year Travel Study: Planning Conuniasion (2) Roads obtained froi VTrans2g)-
topogosphiccontours and Ftojecl Welltieod ProtectionAsea
WHPA Zone 2 Sanfidal Geologic Volts

2yrTravel Zone Surficial Geology Map delineated by VI-IB (2010); Site Pt onprovidedby
BrimoAnsociates
(1018/2010); Surficial geologor frost VT Geologic Survey
(2St8).
WNPA Zone 3: Retharge Area
-
Slmonss Es-urn VCGS and VT HydsogTa
hv Dataset (2Coa).
1
WI-SPA Zone 3
- October 8, 2010
— Streams C/ND) SIC

Parcel linuisdalies
Roads
C Vanasse Hangen Brustlin, Inc.
Water Supply Division
Page 1 of 3 2

Water Cupply Division \!I DEC


wsd home regulations permits grants/loans publications calendar contacts
F
dec home > wsd home
) Critical Infrastructure
Protection Information
A1e II Details
) Permit, Certification & Date Completed 06/25/1975 Quick Links
License Application Forms Date Received 0210611980 ‘> List of Vermont
& Information kRWJLrJJJf
) Water System Capacity Dri[ler 29 David Kessler Tn
Development & DWSRF State Water Service w QriJ.r.Lc!nsi
) Well Driller & Well Well Report Number giaLe PUF
156 ,>
Location Program Tag
) Source Water Protection Comments
) Water System Operators Town Pownal
) Drinking Water Quality Map Cell Current Nationwide
Tax Map Throat Level: Yeflow
) The TNC Handbook
E91 1 Address
) Rules and Regulations
SubDivision
) Staff Directory Lot Number
) News Owners First Name
I Other Links of Interest Owners Last Name ALTA TRAILER PARK
I Agency of Natural Purchaser First Name
Resources 615 Internet Purchaser Last Name
Mapping
Well Use Trailer Park
Well Reason
Drilling Method Other
Well Depth 170.00 feet
Yield Gallons Per Minute 15.00
Yield Test Tested For Hours 0,00
Static Water Lever 3000 feet
Over Flowing 0
OverBurden Thickness 60 feet
Casng Length 61.00 feet
Casing Diameter 6.00 inches
Casing Length Below Land
Surface 0.00 feet
Casing Length Exposed 0.00
Casing Material
Casing Weight 0.00 lbs/Foot
Casing Finish
Liner Length 0.00 feet
Liner Diameter 0.00 inches
Liner Materia
Liner Weight 0.00 lbs/loot
Grout Type
Seal Type
Dameter Drilled In Bedrock 0.00 inches
Depth DrHIed in Bedrock 0.00 Feet
Screen Make Type
Screen Material

http://www.vermontdrinkingwater.org/cfmJWeIlRePOrtVieWDetailS.C
fm?id 128478 8/13/2010
Water Supply Division
Page 2 of 3

Screen Length 0.00 feet


Screen Diameter 0.00 inches
Screen Slot Size 0.000 inches
Depth of Screen 0.00 feet
Gravel Size Type
Casing Sealing Method
Yield Test Method Compressed air
Well Development
Not Steel Casing 0
Water Analysis 0
Well Screen 0
AW Partal 0
Unique GIS Name PQ15G
Lat Degree 0
Lat Minutes 0
Lat Seconds 0.0000
Long Degree 0
Long Minutes 0
Long Seconds 0.0000
Location DeterminationMethod
Well Type
Depth To Liner Top 0.00
Hydro Fractured 0
Hydro Fractured Resulting Flow 0.00
Well Location Submitted As A
Dot On A Map N
Starting Ending Water Lithology Lithology
Depth Depth Bearing Code Description
0.00 10.00 G gravel
10.00 50.00 C clay
50.00 60.00 G gravel
shale quartz
60.00 170.00 R marble and
granite

If you would like search for a well or wells in a specific


area the following link will relocate you to the ANR
GIS Internet Mapping Program.
http:/www.anr.stae.vt.us’stettrnJrnaps.b,n

wwwsermontDrirking Water. org


VT DEC. Water Supply Division:103 South Main Street, Old Pantry Building: Waterbury.
Telephone toil-free in VT: 800-823-6500 or call S02-241-3400 :1 Fax: 802-241-328VT 05671-0403
4
DC home ca1ncir c.Qntact.dec tQpic,ifldN site map
about dec
scarch
assistance divisions & programs dec permits dec regulations dec publications
decgrants& Iqans dec maps & GiS hotline numbers related links pd-racy policy ANR home
9•,- .;,,i..,->O •*,4tt•oq4qe4., •)

State of Vermont Agencies... & Depts. Access Government 24/7 About Vcrrnorit..Gov Privacy Policy Ask a State
Librarian a?
A vermont Government Website copyright 2004-2006 Stale of Vermont
All rights reserved
-

http;//www.vermontdrinkingwaterorg/cfiw’WellReportviewDetailscfm
?ith’128478 8/13/2010
4

Alta Gardens Estates MHP (WSID 5628)


Delineated Source Protection Area

Prepared By:

Agency of Natural Resources


Department of Environmental COnservation
Water Supply Division

April 2002
5

Alta Gardens Water System, WSID 5628


Draft
Purpose
The federal Safe Drinking Water Act requires all states to establish a Source Protection Area
program. This federal requirement is supported by two State statutes, Public Water Supply and
Groundwatcr Protection, Chapters 56 and 48 of Title 10 respectively. These state statutes require
the adoption of rules for the protection of public water source protection areas. In turn, the rules
establish a program containing procedures to determine the public water source protection area.
The rule relevant to this goal are the Water Supply Rule.

The purpose of delineating a Source Protection Area (SPA) is to determine the recharge area
which supplies water to a public water source. The recharge area or SPA for a groundwater
source is defined bythe nature of subsurface flow and that induced by pumping.

Within the SPA land uses and naturally occurring materials may render the public water source
vulnerable to contamination. While naturally occurring contaminants are most often controlled
through treatment, land uses are managed by a Source Protection Plan (SPP). A SPP is a
document that in part identifies management techniques to control land uses within the SPA that
may threaten the water source. -

The SPA for the Alta Gardens Water System consisted of a three thousand foot radius
surrounding the well source. This type of SPA gives little consideration to the hydrogeology or
groundwater flow of the area. To delineate a more appropriate SPA for this water system
existing infonnation regarding the groundwater flow in the area was examineth This information
included a review of existing geologic literature, the well completion reports within the area, an
assessment of aerial photographs, cirthophotos, and topographic maps. A field investigation was
also conducted.

Location
The ABa Gardens Water System is located in the southern extremity of Pownai Village just ivest
of the Hoosic River. It is located southwest of state route 7. The well serving the water system
is on [he southeast corner of the Mobile Home Park. Topographic features of the area are found
on the United States Geological Survey’s Pownal, VT. Quadrangle.

Geology
Bedrock
The water system is in the Taconic Mountains geomorphic region and along side the Hoosic
River valley. The ivells drilled to bedrock encounter a comparitively less resistant slate and
phyilite with quartz. According to well completion reports (attached) the depth to bedrock varies
from the surface to over 100 feet deep. However, all well locations within the area of the water
system have not been field located and may be only considered approximate. The bedrock is
highly metamorphosed, that is, pressure, temperature, and chemical processes were responsible
for its development. Those wells with large yields in the area are probably highly fractured.
Fracturing of the slate is highly probable.
Qa
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Surficial Geology
The unconsolidated sediments described in well completion reports are predominately sand with
gravel and underlying clay. The thickness of these uncosolidated sediments range from Oft. to
100 ft. The sand and gravel thicknesses is variable. Along the Hoosic River the valley floor is
composed of silts and clay: Near Ladd Brook within the flood plain of the Hoosic River gravel
deposits can be 30 ft. deep.

Of the 12 well completion reports referenced in the area’9 describe clay or harpan overlying
bedrock. Similar to the sand, the clay can be quite thick. In one instance the clay is over 80 ft.
thick but averages some 20 to 30 feet in thickness. Gravel deposits may underlie the clay and
occurs directly over bedrock. Where clay isabsent,the sand, gravel,, or till overlies the bedrock.
below.

Well Number Well Yield Depth to Bedroek WeIl.Depth


1 1 GPM 26 FEET 500 FEET
14 3 12 - 155
15 2 4 245
16 0 12 455
32 1, . 10 200
73 .

.9 . ,, 245
156 15 60 17Q
256 15 gravel& clay 117
282 30 99 200
318 ‘2 10 502
324 30 75 100
349
C—
15 60 125

SPA Delineation
The area defined by outer most boundary of the SPA is referred to as Zone III. Zone fflis the
area of recharge to the source where possible impacts from potential sources of contamination
may occur. This area may also be thought of as the area supplying recharge to the public source
simply by natural groundwater flow.

Groundwater flow generally mimics the lay of the land, therefore, the outer boundary of the SPA
was based in part on the topography of the area. As expected, this common characteristic
appears to be reflected in the statjc water level reported for the well at Alta Gardens and the
water level within the Hoosic River. For instance, the Alta Garden’s well is at a topographic
B

Nearby Private Wells


Pownal, Vermont N
® WeII#1

\ Zone3 700 0 700 1400 Feet w


) Zone2
S
S Private Wells Scale 1:12,000
Date Prepared: 4/22102
9

Surficial Geology Nearby the Pita Gardens Water System

Legend
AL Albviurn
T Till
STC Silty Clay
LS Lake Sand
K Karne
KM Kame Moriane
10

elevation of about 580 ft. with a static water level of approximatelS’ 30 below
ft. ground surface.
The water level in the well is about 550 feet above sea level and the Hoosic
River levels is
estimated at 520 ft. Groundwater flow is therefore, from the well to the river.

Applying the above concept indicates that groundwater flow is topographically


upgradient from
the Alta Gardens’s well. The height of land within the proposed SPA isl200 ft.
as estimated
from the topographic map. The well has an elevation of about 580 ft., as mentioned.
A
difference of 620 ft. between the well and the height of land was calculated.
The distance
between the height of land and the well is about 4000 ft. Dividing the differe
nce in elevation
between the two features by the distance between gives a hydraulic gradient of
0.16 or otherwise
known as the slope of the groundwater.

The hydraulic conductivity of the aquifer is similar to permeability. It is the ability


of the
aquifer to transmit water to the well. Thei-e is no aquifer test fbr the Alta Garden
’s well which
could provide site specific information. However, estimates for similar rock
types provide a
hydraulic conductivity of I squared fL/day. The well encounters a wide variety
of sediments
including sand, gravel, clay, and afterwards slate. It is estimated that the hydrau
lic conductivity
represents this range of lithology or rock types. The well is 170 feet deep with
60 feet of well
casing. This leaves 110 ft. of roclc or slate exposed within the well.

The well pumps a maximum of 10800 gallons per day as reported by the operato
r of the water
system. This amount translates to 1444 cubic feet of water per day. Given
this discharge and
combining the above parameters into the Uniform Flow equation, the width of
the SPA can be
calculated.

The Uniform Flow Equation is: Y = Q/Kbi where: Y is the width of the SPA
Q is the maximum pumped
from the well
K is the Hydraulic Conductivity
b is the exposed aquifer
i is the hydraulic gradient

orY 14441(,l)(llO)(0.16) ‘SOO ft.

The above calculation defines the lateral extent of Zone In.

The inner boundary of the SPA defines an area referred to as Zone II. Zone
II is an area where
there will be probable impacts from potential source of contamination.
This area may also be
thought of as the recharge area which is impacted by the pumping of the well.

Zone II was calculated using the second portion of the Uniform Flow Equati
on. This equation
also considers the pumping rate of a well, the hydraulic conductivity (perme
ability) of the
geologic character of the area, and the slope or hydraulic gradient of the ground
water.
This second portion of the Uniform Flow Equation defines the downgradient
affects of pumping
11

Alta Gardens Estates MHP (WSiD 5628)


Source Protection Area
Pownal, Vermont
N
Zone2.shp
Newspas.shp
Minrds 800 0 800 1600 Feet w F
® Source
. Esite
S
Scale 1:12,000
Date Prepared; 04/19102
12

the well and can be calculated by:

X= Q/2 11KM

orX= 1444/(2)(fl)(l)(1lO)(0.16)200ft. where:flispi

Another equation can be used to define the upgradient extent of Zone II. This equation
is base on
the velocity of groundwater flow. It uses the hydraulic gradient of the aquifer, the hydrau
lic
conductivity, and the porosity of the aquifer. The porosity is defined as the amount
of void space
within aquifer and is used to estimate the amount of water within the aquifer. Porosity
can be
thought of as a percentage and is estimated as 0.1. In addition, the equation takes into accoun
t
the life expectancy of bacteria which has been determined to be two years. This period
is
important since it represçnt the time bacteria would have to migrate with the groundwater
to
adversely impact the well. Bacteria associated with groundwater flow beyond this area
would
have died off causing no adverse impact The equation is:

V= 1(1/p where: V is groundwater flow velocity


p is porosity

or V=1(0.16)/0.1 l.6ftiday

The velocity of the groundwater flow isl .6 ft/day. Within a tWo year period groundwater
would
have traveled about 1170 feet The udgradient extent of Zone H is approximately 1170
feet
which coincides with the aerial extent of the sand and gravel deposits found in the area.

The equation given above provide approximations of groundwater flow both natural and
that
induded from pumping.. The calculations have been used in conjunction with the geolog
y of the
area to delineation the Source Protection Area for the Aita Gardens Water System.in
Pownal, Vt.
References:

David DeSimone and David Dethier, 1988. Surficial Geology of the Pownal and North
Pownal
1:24,000 Quadrangles, Vermont

Pownal Quadrangle Vt USGS Topographic Mapj 954

Well Completion Reports Nearby the Alta Gardens Water System


13

Alta Gardens Estates MHP (WSID 5628)


Source Protection Area
Pownal, Vermont N

/‘v’ Zone2.shp
Newspas. shp
Minrds 800 0 800 1600 Feet w E
® Source
® Esite
S
Scale 1:12000
Date Prepared: 04119/02
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15

Monitoring Well Logs


Pownal, Vermont: Beaver Wood
Logged by OWM


July 26, 27 2010

Monitoring
Sampled Interval Log
MW-i 5.0 7.0’: Dark brown, moist, fine to coarse gravel.

10.0— 120’: Brown, saturated, fine to coarse gravel, sand.


15.0— 17.0’; Brown, saturated, fine to coarse gravel, sand at 15.25
Gray, saturated, very fine sand, trace silt at 15.25’ to 15.7’. Light brown,
saturated, very fine sand, trace silt at 15.7’ to 16.4.
Well Construction Details:
. 2”PVC pipe
. Stick down = -0.45’
o Well Depth = 15.0’
e Filtersand=4.0’— 15.0’
. Bentonite seal= 3.0’— 4.0’
. Natural backfill = surface 3.0

. Water level (BTP) = 6.38’


MW-2 5.0 7.0’: Light brown, some gray and orange, damp, tine to medium

sand at 5’-6.1’ Light brown, damp, coarse sand, fine gravel at 6.1’ to 6
10.0— 12.0’:Light brown, some gray, saturated, fine to coarse gravel,
trace sand, cobble.
15.0— 17.0’: Light brown, saturated, fine to coarse grave! at 15’ tol5.2’.
Light brown, saturated, very fine sand, trace silt at 15.2’ toi6.5’. Light
brown, saturated, more silt, very fine sand at 16.5’ 16.7’
Well Construction Details:
. 2”PVC pipe
a Stick down = -0.55’
. WellDepth=15.0’
. Filtersand = 4.0’— 15.0’
. Bentonite seal = 3.0’— 4.0’
• Natural backfill = surface 3.0’

. Waterlevel(BTP) = 7.7’
MW-3 5.0 7.0’ : Brown, damp, fine to medium sand, some gravel. Light

[prown damp, fine to medium sand at 5.2’ to 6.25’.


• 10.0— 12.0’: No recovery, wet.
15.0— 1 7.0’: Light brown, gray, saturated, silt with trace very fine sand.
Well Construction Details:
. 2”PVCpipe
• Stick down = -0.50’
• Well depth = 15.0’
• Filtersand = 4.0’— 15.0’
a Bentonite seal = 3.0’— 4.0’
16

Monitoring Well Logs


Pownal, Vermont: Beaver Wood
Logged by OWM
July 26, 27 2010

Monitoring
Sampled Interval Log
a Natural backfill = surface 3.0

. Waterlevel(BTP) =8.9’
MW-4 5.0— 7.0’: Gray with some orange, damp, fine to coarse gravel from
5.0’
to 5.2’. Gray silt from 5.2’ to 6.7’
10.0— 12.0’: No recovery, wet.
15.0— 17.0’: Light brown, very orange at 15.3, saturated, silt with some
medium gravel at 15.0’ to 15.1’
18.0’— 20.0’:Gray at 18.0-18.6’, saturated, gray silt, some fine sand.
Light brown at 18.6-19.6’ saturated, silt
Well Construction Details:
a 2”PVC pipe
. Stick down = -0.52’
a Wel(depth=18.0’
. Filtersand 7.Q’-18.0’
• Bentonite seal = 6.0’-7.0’
a Natural backfill surface 6.0’

a Waterlevel (BTP) = 10.9’


MW-5 5.0— 7.0’: Light brown with some orange, moist, fine to medium sand,
gravel at 5.0-5.2’
10.0 12.0’: Brown with some orange, saturated, medium to coarse

gravel, trace sand, broken rock.


15.0’— 17.0’: Brown and gray, saturated, some fine gravel, trace sand,
silt at 15.0’— 15.6’. Gray, saturated, silt at 15.6’— 16.4’.
Well Construction Details:
• 2”PVC pipe
. Stick down = -0.25’
a Welldepth—15.0’
a Filtersand 4.0— 15.0’
a Bentonite seal = 3.0— 4.0’
• Natural backfill surface 3.0’

a Water level (8W) = 8.6’


MW-6 5.0’ 7.0’: Light brown, some orange, damp, fine sand throughout, some

coarse gravel at 5.0’ 5.2’.


10.0’— 12.0’: Light brown, saturated, fine sand to coarse gravel, some
iargçgravel._Fine sand from 10.0—10.2’.
15.0’ 17,0’: Brown, saturated, fine to medium sand, medium to coarse

17

Monitoring Well Logs


Pownal, Vermont: Beaver Wood
Logged by OWM


July 26, 27 2010

Monitoring
Sampled Interval Log
gravel. Fine to medium sand from 15.0’ to 15.3’
Well Construction Details:
. 2”PVC pipe
. Stick down = -0.18’
a Welldepth=15.0’
a Filtersand = 4.0’— 15.0’
. Bentonite seal = 3.0’— 4.0’
a Natural backfill = surface 3.0’ —

a Water level (BTP) = 9.28


F ‘57407 00 S,aver Wood Pownal\ Data\ UIC Beaver Wood Pownal-MW Logs doc
18

P.O. BOX 4603 BORING NUMBER: MW-I Sheet I o(


sWLifl cc BURLINGTON VT
054084503 PROJECT NAME: BA/HG BEAVERW000
6-WAFmPZ1WM PTCW
T: 8&2458-0820
F: 802-860.1014 PROJECT LOCATION: POWNEL, VERMONT
SOIL BORING LOG

BORr4G LOCATION: NORTHEAST CORNER

DATE AND TIME STARTED: 7/26fl0tO930 RIG HOURS METER START: 7756.6
FOREMAN: CHRIS ALDRICH H & N STAFF: CHRIS ALDRICH & JOHN MCTERNAN
DATE AND TIME COMPLETED: 7128/IDa 1100 RIG HOURS METER END: 7755.1

ME TN 00: 4 114 HOLLOW STEM AUGER 2 114 lISA 61/4 H S A WASH/SPIN and DRIVE AIR HAMMER
SAMPLING METHOD: SPLIT SPOON DIRECT PUSH CUTTINGS BACKHOE HAND AUGER
SIZE: 24 HAMMER: 14018. FALL: 30
STRATA
NO, REC. fIN.) DEPTH (FT.) .
BLOWS I SAMPLE DESCRIPTION CHANGE
F
PID
12 5.7 15.19.1545 SPNO. GRAVEL.
-

2 8 10-12 21,22,25,22
I SATURATEDSAND/GRAVEL.
18 16-17 1l,10,l1,13 ASABOVE.GRAYSILT.
— SET 2” PVC WELL TO 15’.

L
E_________
H*tEEEEE,

H WELL CONSTRUCTION DETAILS

PVC Saeon: 2 in. diameter Slot: 0.010 Sections: 10’ Set from: 15 to 5
PVC Rise,:
Fiet Sock:
2 In. diameter Sections. 4.5’ Set lien: 5 ICZiEI
Sand Pack: 15 to 4 bags S Cap
Bentonile Seat’ 4 to 3 bags 1)2 PIug
to bags G,ipper
Flush Guard B Nahvo 0acII: 3 to

S’.SVHOleeaverwood\tRQoVeIWOod Sail logs 7.26-10 PovmaLxls)MW’G


I

7
-

BORING LOCAT(ON:
/
‘::.‘fl”
‘r’7
‘‘
P.O. BOX 4503
BURLINGTON) VT
05408-4503
I 802468.0820
F: 802460.1014

MIDDLE EAST SIDE


BORNO NUMBER: MW-2

PROJECTNAME: SN1-(BBEAVERW000

PROJECT LOCATION: POWNEL, VERMONT


SOIL BORING LOG
Sheet 1 ci

DATE AND TIME STARTED: 7128110 @1125 RIG HOURS METER START: 7758.1
FOREMAN: CHRIS ALDRICH H & N STAFF: CHRIS ALDRICH & JOHN MCTERNAN
DATE AND TIME CoMPLETED: 7128110 @1230 RIG HOURS METER END: 7759.4

BORINOMETHOD: - 41/4HOLLOWSTEMAUGER 21/4HSA 8l/4HSA WASI-IISPINandDRIVE AIRHAMMER


SAMPLING METHOD: fWflPOON DIRECT PUSH CUTTINGS BACKHOE HAND AUGER
SIZE: 24’ HAMMER: 140 LB. FALL: 30’
STRATA
NO. REC. (IN.) DEPTH (FT.) BLOWS SAMPLE DESCRIPTION CHANGE PlO

I 18 54 4,5,5.7 MOIST SAND/GRAVEL.


8
WATER
2 5 10-12 39.17,15 SATURATEDSAND/GRAVEL.
3 18 15-17 4,8,6,6 ASABOVE,GRAYBROWNSILT@16+.
SET 2’ PVC WELL TO IS.

t I
WELL CONSTRUCTION DETAILS

[“Pvc Screen: 2 in. diameter Slot: 0.010 Sections: 10’ SelIrorn: 15

[ PVC Riser:

Fit[ec
Sock:
2 in. diameter Sections: 4.5’ Set front
Stick up:
5
4’
‘ Sand Pack: 15 Ia 4 ‘nags 5 cap
Bentonile Seal: 4 Ia 3 bags 1/2 Pug Q
Grout seal: 10 ‘naps Gripper
Well Finish: ‘ Flush Guard 81W Native Backfill: 3

SrvHSIBeaVe(WoOdliBEaVerWOOd Soil logs 7.25.10 Po’,’,nal.xIslMW’6


____________

20

ØSC&8L rr P.O. BOX 4503 soR;NG NLJk’.BER: MW-s Sheet 1 of I


BURLINGTON, Vt
064064503 PROJECT NAME: SNHB BEAVERWOOD
T: 8024684820
F: 8028604014 PROJECT LOCATION: POWNEL. VERMONT
SOIL BORING LOG

BORING LOCATION: SOUTHEAST CORNER


DATE AND TIME STARTED: 7126/10 1245 RIG HOURS METER START: 7758.4
FOREMAN; CHRIS ALDRICH H & N STAFF: CHRIS ALDRICH & JOHN MCTERNAN
DATE AND TIME COMPLETED: @ 1400 RIG HOURS METER END: 7760.9

BORING METHOD: 4II4HOLLOWSTEMAUGER 2114H8A 8 II4HSA WASH/SPiNand DRIVE AIR HAMMER


SAMPLING METHOD: SPLIT SPOON DIRECT PUSH CUTTINGS BACKHOE HAND AUGER
SiZE: 24” HAMMER: 140L8. FALL: 30’

NO. REC.çIN. DEPTH (FT.) STRATA


BLOWS SAMPLE DESCRIPTION CHANGE P10
I 5 5-7 12,12,13,25 ‘MOSTLY BROWN SAND, SOME GRAVEL.

2 0 10-12 - 7,11,2,4 NORECOVERY.WET.

3 14 15-17 22,9.? BROWN GRAY SILT.

SET 2WVC WELL TO 15’.

: I

WELL CONSTRUCTION DETAILS

PVC Screen: 2 in- diameter Slot: 0.010 Secliens: 10 Set from: IS to 5


PVC Rise,: 2 in. dian,eter Soclior,s: 4.5 Setfrorn:5loj
Filler Sock:
Stick up: -3”
Sand Pack; 15 to 4 bags 5 Cap
Sentonfle Seal: 4 - to 3 bags 1/2 Plug q
Grout seal: to bags Gripper ‘
Well FinIsh:
Guard 31W Nat,va Beckflhl: 3

S wN8\5eaveNtetBeaVeIWOOd 5,11 bg& 7-26-10 Po,mal xs11cW.6


CraLn’ P.O. BOX 4603 BORING NUMBER: MW-4 Sheet I of

77 wjt BURLINGTON VT
05406.450.3 PROJECT NAME: SNHBBEAVERW000
;:- .. t/...’:rj;.-:w T: 8024684820
2:;
-r;?
I .

F: 802S60-1014 PROJECT LOCATION: POWNEL, VERMONT


SOIL BORING LOG

BORING LOCATION: NORTHWEST CORNER

DATE AND TIME STARTED: 7127110 t 0910 RIG HOURS METER START: — 7764
FOREMAN: CHRIS ALDRICH H & N STAFF: CHRIS ALDRICH & JOHN MCTERNAN
DATE AND TIME COMPLETED: 7/27110 t 1040 RIG HOURS METER END: 7765.6

BORING METHOD: 4 1(4 HOLLOW STEM AUGER 2 114 N S A 6 1/4 H S A WASH/SPIN and DRIVE AIR HAMMEiI
SAMPLING METHOD: SPLIT SPOON DIRECT PUSH CUTTINGS SACKHOE HANDAUGEI1
SIZE: 24 HAMMER: 14016. FALL: 30
SrRATA
NO. REC. (IN.) DEPTH (FT.) BLOWS SAMPLE DESCRIPTION CHANGE PlO

I 19 5.7 323,6 7 GRAVEL @ 5. THEN VERY FINE SAND/GRAY SILT.


2 0 10-12 2,12,3

3 14 15-17 1.2,1,2 SATURATED VERY FINE SAND/GRAY SI LT, GRAVEL t 14.


4 20 18-20 2,2,4,3 AS ABOVE.

SET2’PVCWELLTOlS’.

WELL CONSTRUCTION DETAILS

PVC Screen: in. diameter Slot: 0.010 Sections: 10 Set (corn:

L.i
18 to - 8
PVC Riser; in. diameter Sections: 7 7 Set from: B to 0.3
Filler Sock: Stick up:
Sand Pack:
Benlonite Seal:
Grout seal:
: bags
:______
Gripper ‘

Well Finish: Flush Guard 81W Native B ack/ill: 6 to 0

S:tVHBtBe8veft’0I6eaVertOd Soil logs 7-26-10 Po-Mlal xlsJMW-6


_
____
__
__

22

rc:z n P.O. BOX 4503 BORING NUMBER: MW-5 Sheet 1 ol 1


a BURLINGTON, Vt

wwlssnac2& l’Zw 054064503 PROJECT NAME: SM-iS BEAVERW000


T: 8024584820
F: 802.860.1014 PROJECT LOCATION: POWNEL. VERMONT
SOIL BORING LOG

BORING LCCATION: WEST SIDE MIDDLE


DATE AND TIME STARTED: 7/27110 @ 0745 RIG HOURS METER START: 7726.7
FOREMAN: CHRIS ALDRICH H & N STAFF: CHRIS ALDRICH &JOHN MOTERNAN
DATE AND TIME COMPLETED: 7/27110 § 0900 RIG HOURS METER END: 7764

BORING METHOD: 4 1/4 HOLLOW STEM AUGER 2 114 H SA 6 1/4 H S A WASI-I/SPIN and DRIVE AIR HAMMER
SAMPLING METHOD: fLIT SPOON DIRECT PUSH CUTTINGS
-.

BACKHOE HAND AUGER


SIZE: 24 HAMMER: 140L8. FALL SW

NO. REC.(IN.) DEPTH (FT.) BLOWS SrRATA


SAMPLE DESCRIPTION CHANGE
I 16 57 6,7,7,23 MOIST BROWN SAND, GRAVEL ON TOP.
2 10 10-12 10,15,j2_ SATURATEOSANDIGRAVEL WITH SOME LARGE STONES.
3 $7 15•l7 4,7,7,20 BROWN SAND TO 15 1/nHENGY1LTAL
LSAT!RATEDL_

SET 2 PVC WELL TO ¶5’.

WELL CONSTRUCTION DETAiLS

PVC Screen: 2 in. diameter Slot: 0.010 Sections: 10’ Set from: IS to
PVC Riser: 2 in. diametet Sections: 4.5’ Set horn:
Filter Sock:
Slick up:
Sand Pack: IS 4 bags S Cap
Bentonite Seal: 4 to 3 bags 1/2 9
PIu
Grout Seal: to bags
Gripper

Well Finish: Flush Guard Nave BacII: 3 to


S:rVI-1SrSeaverOOr1l{BeaV9rcOcd Soil logs 1.25-19 xrs’.RV-6
23

se&ictziL yr P.O. BOX 4503 BORING NUMBER: MW-B Sheet I of I


8 BURLINGTON, Vt
064064503 PROJECT NAME: SNHB BEAVERW000
fl&tY’Xt4J 3W
T: 602.656-0820
F: 802-660-1014 PROJECT LOCATION: POWNEL. VERMONT
SOIL BORING LOG

BORING LOCATION: SOUTHWEST CORNER


DATE AND TIME STARTED: 7l26/1Oi 1415 RIO HOURS METER START: 7761 —

FOREMAN: CHRIS ALDRICH H & N STAFF: CHRIS ALDRICH & JOHN MCTERNAN
DATE AND TIME COMPLETED: 7/26/10 @ 1530 RIG HOURS METER END: 7762.4

BORING METHOD; 4 114 HOLLOW STEM AUGER 2 1/4 H S A 6 1/4 H S A WASH/SPIN and DRIVE AIR HAMMER
SAMPLING METHOD: SPLIT SPOON DIRECT PUSH CUTTINGS BACKHOE HAND AUGER
SIZE: 24 HAMMER: 140W. FALL: 30’
STRATA
NO. REG. (IN.) DEPTH (FT.) BLOWS SAMPLE DESCRIPTION CHANGE plo
1 20 5-7 3,3,6,9 MOIST SILTY SAND. BROWN/GRAY.
2 6 10-12 10.6,2,5 SAND/SHAWL. SOME LARGE STONES.

3 12 15-17 4,5,5,5 AS ABOVE.

SET 2’ PVC WELL TO 15’.

IE
Ilz.i H
WELL CONSTRUCTION DETAILS Ii

PVC Screen: 2 in. d,ameter Slot: 0.010 Secltons: 10’ Settrorn: 15 to


S
PVC Riser: 2 In. diameter Sections: 4.5’ Set from: 5 to 0.3
Sock: Stick up: .3’
Filter

Sand Pack: 15 to 4 bags 5 Cap________


Bntorite Seal: — 4 to 3 bags 1./2 Pltg
Grout seat: —_____________ to bags Cripper________
Well Finish: FIus’i Guard Native BackSII:
37W
3 to 0

S:IWB\BeavewootBOaY&’OOd Sod logs 7.26.lOPownaI.xIsjMW-6


.1.!

Wl;
::‘::-::t:è?:. -

- Lc
(:j:;:: : :
L.
:;‘:j:.;::ç’.: ; :
Proposed ‘‘I...
.4

Leachfield

Sources Badtground 0 USDANAW


, hot Orth
Legend -

Serrington (29c public weRe ar4 WHPAs frost VTANR


9 Public Waler Source Beaver Wood Energy Pownal, LLC. Parcel Boundaries obtained from Bennington County Regional
Planning Conm-tission (26); Roads obtained from VTrarts
Groundwater Contour (8/3/2010)
Two-Year Travel Study: Site Plan prcvidedby Bmno Assodatet (iu/8/2010); Streams
2l);

4 Monitoring Well
Groundwater Contour Map VCGI and VT Hydsogrophy Dataset (2008). Groundwater
&om
momto,
weLls and K-teaisby VHS Q010). end dtgttized fronsLintok
WHFA Zonel
- ApplieR
Geooey (;995 Groundwatercoosrwrsbv ‘/MB (2010(.
3 WHPA - Zone 2 & 2-Yr Travel Zone
October 8, 2010
K-test

WHPA Zone 3
-

— Streams (VtTD) Vanasse Hangen Bntstlin, Inc.


Road a
25

-
Beaver Wood Energy LLC. Pownal VT
Slowdown Water Underground Injection System Site Investigation
Point Hydraulit C onduoti city Testing
Augusta -0,2010

Toni K-I ions 6-2 ions to tonSK4


Hole OnpIe 2.5 9 Hod Depien 2.5 Hole DeplO 2.2 t Hole Depth 2.5 9
IS.Onm Lno— 15.Dane Ic— bOon Leo SCorn
.
35,070
:wm0m peweaenlrrp- 2.OOoe p.mo.sebrtn 3557i reinermaLnrh- 3555Q7i
0.eanwPn 0= ls
1
0.Otne 0 0.302515 Qn
K e lSSqnn%
2.772-03 cr15 — 5.74004 cents Ku 7.046-Do Ohm K — 2 00E-ol won
70.07 S/day 123 ioday n 2.23 ftldap 010 tOday
Toni Data - IertDaln Tart Cola Teal Data
C (cm) change(rat) Time h toni) rOnene can) lime Sm (till) change (eon) IS/tie S Iris) rhaoge rn)
. :20 0.0 0.0 000:00 0.0
0•00• tO 70 70 0.2
0 00.15 0.2 0.2 0:00:15 7.2 7.2 0:20:15 7.0 7,5
00030 70 00 0:00.30 0.3 0.0 0:00:30 7.2 0.0 0:00:30 7.7 0.2
000-45 0:00:40 0.2 0.0 0:00:40 7.2 0.0
e 0:00:43 0.5 0.0
7.0 0.0 0:02:00 0.2 0.0 0:01:00 7.1 3.0 0:01:00 5.0 00
2.9 001:15 62 0.0 3:01:10 74 0.2 0:07: tO 0.0 35

001 30 .
. 2.4 0:01:30 5.2 0.0 0:01:30 7.6 9.2 0:00:30 10.0 0.0
0.01.45 13 0 0.7 0:0140 0.2 0.0 0:07:45 7.7 0 7 0:01 ‘45 10.0 0.5
1 3.2 0.2 0:02:00
0.02:02 0.2 0.2 0:02:02 7.0 0.0 0:02:20
0.02,10 10.0 00
02.0 03 0.02:70 0.5 2.3 3:33:15 7.9 0.1 0:01:10 II H 35
0.02.30 71.0 0.4 0:02:33 11.0 2.1 0:02:30 5.0 0.0 0:02:30 1 2.0 0
0:02:45 14.2 0.3 0:02:45 02.2 0.0 0:02:45 0.1 0.5 0:02:40 72.3 03
0:03.00 14.0 0.3 0:03:00 14 0 1.0 0:03:00 0.2 0.1 3:03:00 11.0 02
0:03:10 14.0 33 0.03:15 10.0 2.0 3:03:10 0.3 0.1 0:03:10 130 0.4
3:33:30 10.1 0.3 0:33:33 I 0.0 3.0 0:03:30 5.4 0.1 0:03:33 13.0 00
0.03:40 70.0 0.1 0:02:40 10.3 7,7 0:03:45 0.5 0 I 3:02:40 73.7 0.2
0.04.33 75.0 0.2 0:04:00 00.0 1.0 0:00:00 0.0 0.0 0:04:00 14 I 04
0.04:10 13.7 0.1 0:04.15 30.4 1.5 3:04:15 5.0 0,2 0:04:75 04.5 0.4
0:04:20 10.1 0.4 0:0430 22.3 0.0 0:04:30 0.0 0.0 0:04:30 70.0 0.5
0:04.40 50.3 02 0:0440 23.0 1.6 00445 0.0 0.0 0.04:45 15.3 0.3
0:20:00 is.s 0.2 00000 20.4 1.0 0•0S•20 0.0 0.1 00000 0 5.7 0.4
0:00:75 10.7 01 0:05:15 100 I 4 0:00:75 0.7 0.1 0:05.1) 16.0 0.3
0.03:30 17.0 0.3 0:05:20 20.3 1.5 0:05:30 1.1 0.1 0:05:30 76.4 0.4
0.00:40 07.2 0,2 0:05:40 29.6 7.3 0:00:40 0.3 01 0:00:43 5.6 0.4
0:06:00 17.4 0.2 000:00 31.1 0.5 0:04:00 0.4 0.7 0.05:00 I 7.2 0.4
D:w: 75 17.0 0.2 0:04:10 32,7 1.0 0:06:10 0.0 0.1 0:00:15 I 7.5 0.3
0.04:30 07.0 0.3 0:06:10 32.0 2.2 0:05:33 3.0 0,0 0;06:30 17.0 0.3
0:00:41 05.1 0.2 0:00:40 30.2 1.3 2:00:40 07 0.1 3:20:40 10.3 0.5
2:07:00 16.3 0.2 0.0702 305 03 2.07:20 0.0 0.2 0:07:00 I 0.n 0.3
0.07.15 10.5 0.2 0:07:15 37.5 I 0 0:07:10 70.0 0.1 0:07:15 I 0.0 04
0:27:23 0 0.6 0.7 0:07:30 30 I 1.0 0:07:30 72.1 0,7 0:07:30 10.4 0.4
0:07:43 10.7 2.1 207:40 40.4 2.3 0:0730 00.2 0.1 0:07.40 10.0 0.4
0:00:00 19.0 0.3 0.0600 47.6 7.0 0.0040 10.2 0.0 0:20:00 10.7 0,3
0.00.70 10.2 0.1 0:00:10 42.3 0.7 0:00:10 70.3 0.1 0:00:15 20.0 0.4
0:00:30 10.4 0.2 0:00:30 43.0 1.0 0:06:30 10.4 0.0 0:00:20 20.0 0.3
0:00:40 10.0 02 0:00:40 447 0.0 0:05:45 00.5 0.1 000.40 27.2 0.4
2.00:00 10.5 0.3 0:0500 40.4 07 I II 00 10.6 0.1 0:00:00 II 0 0.4
0:00:10 20.1 0.2 0:06:10 47.2 0,5 0:00:10 10.7 0.1 0:00:10 31.0 0.0
0:0030 30.2 0.0 0:0030 40.0 1.3 0:00:30 10.0 0.1 0:05:30 22.0 0.3
005:40 30.4 0.2 000:41 49.0 13 00040 10.0 0 1 0:03:45 22.0 0.4
070:00 20.4 0.2 0:10:00 01.1 0.3 0.50:00 71.0 0.7 0:10:00 23.2 04
0:10:10 11.1 0.1 0:10:15 23.3 0.3
0:10:30 01.3 0.2 0:10:20 23.0 0.3
0: 00:40 01.4 0.1 0:10:45 24.0 0.4
0:11:00 11.0 0.0 0:1 0:02 24.3 3.3

n..-. Weal ?ea0


00lol010540nrea.oo
05 K.T00o 6160050
26

-
Beaver Wood Energy tIC. Pownal, VT
Blowoll Waite Underground Injection Syslew Uo&Insiog
Po,es HydeeoSc C onductie,ty Testiro
0905003 ,0. 3010

1.5004 Ted 64
8
J 14-7 T.etK-6
Hole Deplh 2.0 0 Hole DepiS 2.5 0 Hole OopIO = 00 0
Lee tIde D.001 2.0 6
15.0cm Lw= lOOno, Lee 16.Oae we 350am
0— 35 26= 3.09,5 ‘o 3.5-30, ewe 2Sam
eemeeeeel, K— lSSlee0 pemeeaeece,K— 3OSloe, p.mieee.1.,Ke 2.00e,e p.mie.enaletKe e
0
3g5,
0- 2.OScrils Ce 1.Otnm% Qe
049e’e% 0. 16.33’e
K 0
0.220-OOcWc 4 SlOE-OS 09* 14 I 00644 ore/c
e 00 = 3 36E-D2 aede
1106 OJeay e 1504 lOday =
0.21 OIday 00.33 ISOday
reel Dale
reel Dora Tesl 0.0. 7enl Oil.
ieee b/eeeo etwr0900e7 00orc 0aw.(W 000. eue0 rney.laeO See. eaed.angeooe)
0.00.03 0.0 00 210350 0.0 2.0 000.00 2.2 0.0 0;0040 00 0.0
0:00:15 S.D 00 0.04’S 1.0 02 0:00.70 0:9 ED D006 160 65
09320 O.K 06 01,0:32 103 11 0.00:20 6.0 0.1 000.30
0:00.40 500 3.5
7.3 0.7 0:00:43 11.4 1.3 3:00.45 0.0 0.0 0.50.45
0:01.00 20.2 02
0.2 0.0 0:01:00 100 1.1 0:01:00 0.0 0.0 0:01:00 30.0 0.3
3:01 10 0.5 0.0 0:01:10 I 3.2 0.7 0:01:15 0.0 0.0 001 0
0:0020 35.0 5 3
04 04 01,0:30 003 II 0’0:30 09 00 0:01.20 40.3
0 71 40 4.5
03.2 0.8 3:01.45 15 I e.g 3345 0.0 0.0 021.45 40: I 4.0
0.02 00 10.7 0.0 3:0300 190
[ 0.0 022 00 00 0-27.30 4
50.0
00005 005 •:7 0020555.5 00 0.0115 405 369 0.0210 04.0 65
0:01:20 12.1 0.7 0:01:30 17 5 0.0 0:01:30 40 7 0.2 0:00 30 550 4.6
0:0245 11.5 0.4 3:02:45 104 0.0 0:02:45 45 0 0.3 001:40 03.3 3.6
0:01:30 1 3.2 0.7 0:02:00 10.1 0.7 0:03:00 46.2 0.3 0:02:00 89 I 4 0
1.0115 140 06 0:0311 50.6 07 00313 400 0.3 0:5314 124 43
323.36 144 04 02=130 2’S 07 0°=3.30 450 33 3:0303 70.3 34
0 03-45 15.0 0.0 0:03:43 21 3 0.8 0:0345 40 0 0 I
00435 150 1.5
j 3:00:50 27.0 1.7 234:20 Z7.0 /12
0:00.15 16.2 0.7 1:34:15 22.6 0.6 004.15 47.3 0.2
0:04:30 16.7 0.5 0:04:30 13.4 0:04:30
0.0 47.5 0.2
0:04.45 57.3 0.6 0:04:45 24.0 0.0 0:04:45 47.5 0.0
00500 16.0 0.7 0:05.00 347 0.7 00000 440 05
2.50:15 89.5 0 1 I 0.05:5 25.4 2.7 0:4.15 462 0.2
0.05:30 19 0 0.5 0:0030 25.0 0.6 0:05:30 46.5 0.3
00544 80.6 36 0:0545 306 06 000:45 406 31
0:06 00 20.0 0.4 0:06:00 27.5 0.7 0:04:05 40.1 0.3
0:06.10 20.5 0.0 0:00.15 26.1 0.0 0:50:15 49.4 0.3
0:00:30 01.1 0,6 0:45:30 26.6 0.7 0:06:30 45.7 0.3
006.45 317 06 0:0640 204 06 0:0045 500 33
0.07.30 03.1 14 3:07.50 76.’ 0.5 3-3e 00 50.3 27
0:0710 00.6 05 0.07:10 30.5 0.0 3:0713 50.5 0.2
2.07:30 130 06 0.0730 3:4 07 :0715 50.9 0.3
0 0745 22.0 06 0:0745 22.0 0.0 0.05 60 51.0 0.3
0:08 00 34.3 0.5 0:00:00 30 7 0.7 0:00:00 01.4 0.3
0:00 IS 30.0 0.7 000:75 33.4 0.7 0:00:15 01.0 0.2
0:00:30 254 04 006:30 340 5.6 009.30 50.6 0 2
05040 26.: 08 0-30* 347 07 1:0.40 54.0 07
0.0500 26.0 0.5 0:09:00 36.3 00 0.09:00 52.2 0.2
0:00.85 27.0 00 039.05 349 06 3:040 520 13
000:30 275 05 0•0930 350 57 03030 509 0.3
0:0045 20.0 0.5 0:00.49 27.3 0.7 0:00:40 53.7 0.2
0:10.00 29.4 0.0 0:70:00 37.0 0.5 0:10:00 43.3 0.0
0:10:15 304 0.6
• 01030 30.0 06
0:10.44 35.5 05
0:1100 40.2 0.7 I

Acreage: 152100a0 I
27

Beaver Wood Energy, LLC. Pownal, VT


Blowdown Water Underground Injection System Site Investigation
Groundwater Elevation Data

Total Top-of-Casing
Stickup
Well ID Depth Elevation Measurement 81312010
(feet BTC) (feet)
Water Level (Ft BTC) 6.63
Mw-i 14.55 -0.45 541.59 Water Level (Ft Below Grade) 7.08
water Elevation (ft) 534,96
water Level (Ft BTC) 7.92
MW-2 14.5 -0.55 542.46 Water Level (Ft Below Grade) 8.47
Water Elevation (if) 534.54
water Level (Ft BTC) 9.17
MW-3 14.5 -0.50 541.98 Water Level (Ft Below Grade) 9.67
Water Elevation (ft) 532.81
Water Level (Ft SIC) 11.22
Mw-4 17.5 -0.52 540.32 Water Level (Ft Below Grade) 11.74
Water Elevation (if) 529.10
Water Level (Ft SIC) 8.97
Mw-S 14.8 -0.25 541.06 Water Level (Ft Below Grade) 9.22
Water Elevation (if) 532.09
Water Level (Ft BTC) 9.63
Mw-6 14.8 -0.18 541.06 Water Level (Ft Below Grade) 9.81
Water Elevation (if) 531.43
.
Water Level (Ft Below RP) 12.64
Hoosic --

— 540.95 Water Level (Ft Below Grade)


River —

Water Elevation (if) 528.31


Well elevations from survey by Bruno Associates of Woodstoclc, VT

River Water Level on 8/2/2010 = 528.31

F:\57407.00 Beaver Wood Pownai\Data\U1C\Mon Well WL.xisj Water_Levels


8/18/2010
Beaver Wood Energy Pownal LLC.
Groundwater Flow Calculations
iJnconfined Water Table
VHS 101812010

1) Determine Groundwater Flow Rate in Unconfined Water Table (Sand and Gravel)

n (Porosity) = 0.39 (for Coarse Sand, see following page)


K (Permeability) = 18.2 ftlday (from onsite testing)
I (gradient) = 2.50% measured from groundwater contour map

(K)(i)

V (flow velocity) = 1 .2 ft/day


D (Distance to River) = 400 feet along groundwater flowpath
T (Travel time to River) = 343 days

2) Determine Travel Time for Groundwater from Water Table to Reach the Bedrock Aquife

(K) (i)
n
where:
V = groundwater velocity (ft/day, vertical infiltration)

K = hydraulic conductivity = 0.00066 fUday for clay (textbook value, see 2nd following page)

= hydraulic gradient 100% for downward vertical flow

n = porosity = 42% (typical porosity for clay see next page)


-

0.0007ttldayx 100%
= 1.57E-03ft/day

Tot= (D)/(V)

where:
Tot = time of travel (days)
D = Distance = 40 feet, thickness of clay layer (see Alta Gardens Well Log)
V = velocity = 1 51E-03 feet per day, from above

Tot = 2.55E+04 days


or 70 years

Conclusion: It takes well over 2 years for groundwater to recharge the bedrock aquifer
due to the thick
layer of clay over the bedrock. Therefore there is no two-year travel zone for the bedrock
aquifer.

F:\57407.o0 Beaver Nooc Pcwnai\Oata\Ulc\WW Moundingxisl GWVCalcs


10/8/2010
_________

28 31
GROUNtWArERH. LOGY
rials are listed in Table 2.1. It should be recognized that
porosities for
a particular soil or rock can vary considerably from
these values.
In sedimentary rocks subject to compaction, measuremen
ts show
that porosity decreases with depth of burialY
6 Thus, a typical rela
tion has the form
= e° (2.4)
where a, is the porosity at depth z, a is the porosity
at the
a is a constant, and e is the base of Naperian logarithms. surface,

Soil Classification. Unconsolidated geologic materials


mally classified according to their size and disthbution are nor
A com
monly employed system based on particle, or grain, size
is listed
in Table 2.2. Evaluation of the distribution of sizes is
accomplished
by mechanical analysis. This involves sieving particles càarser than
0.05 mm and measuring rates of settlement for smaller particles
in suspension. Results are plotted on a particle-size distribution
graph such as that shown in Fig. 2.3. The percentage finer scale on
the ordinate shows the percentage of material smaller than that of
a given size particle on a thy-weight basis.
The effective particle size is the 10 percent finer than value (d
).
10
The distribution of particles is characterized by the uniformity coef
ficient TJ as
= d/d, (2.5)

TABLE 2.1 Representative Values


of Porosity (after Morrisand Johnson9
Porosity, Porosity,
Material Percent Material Percent
Gravel, coarse 28 Loess 49
Gravel, medium 32’ Peat 92
t. cwt-rd
Gravel, fine 34’ Schist 38
W4{eC
Siltstone 35
SauUJnedmm 39 Claystone 43
Sand, fine 43 Shale 6
Silt Till,
zs:- —‘tt c_.._,.EZzZz3D predominantly silt 34
CL an stone, Till,
fine-grained 33 predominantly sand 31
Sandstone, Tuff 41
medium-grained 37 Basalt 17
Limestone 30 Gabbro, weathered 43
Dolomite 25 Granite, weathered 45
Dune sand 45
q’hese values are for repacked samples; all others are undisturbed.
Ipi
C
rc’n ‘Thdd, t3Yc eo, CL(CJYJJ4Er
t
.80
OtS;

GROUNDWATER MOVEMENT
11
tii
TABLE 3.1 Representative Values of Hydraulic Conductivity
(after Morris and 45
Johnson
)

I
Hydraulic Type of
Material Conductivity, rn/day Measurements
Gravel, coarse 150 H
Gravel, medium 270 R
Gravel, fine 450 H
Sand, coarse 45 R
Sand, medIum 12
Sand, tine 2.5 R
silt 0.08 H
/
z Clay .
0.0002 y. 3 . c-f(Pl H O-otlo6t
“ ttv
Sandstone, finegrained 0.2 V
Sandstone, medium-grained
Limestone
3.1
094
V
V
I
Dolomite 0001 V
Dune sand 20 V
Loess 0.08 V
Peat 5.7 V
Schist 0,2 V
Slate 0.00000 V
Till, predominantly sand 0,49 H
Till, predominantly gravel 30 H
Tuft 0.2 V
Basalt 0.01 V
Gabbro, weathered 0.2 V
Granite, weathered 1.4 V
[{ horizontal hydraulic conductivity, K is a repacked sample, and
V is verticsl
hydraulic conductivity.

mental work. Most permeability formulas have the genera


l form
k = cd
2 (3.15)
where c is a dimensionless coefficient, or
Ic
2
f,f,d
= (3.16)
wheref is a’grain (or pore) shape factor,
3
f isa porosity factor, and
d is characteristic grain ’
diameteri
3 7 ” Few formulas give reliable
estimates of results because of the difficulty of including all possib
le
variables in porous media. For an ideal medium, such as an
assem
blage of spheres of uniform diameter, hydraulic conductivity
can
be accurately evaluated fromknown porosity andpacking conditi
ons.
Because of the problems inherent in formulas, other techniques
for determining hydraulic conductivity are preferable.
Alta Gardens PCWS (WSID 562S)
Nitrate Monitoring Results Data from VT Water Supply Division
-

Compliance Monitoring Database (October 2010)

Nitrate Nitrite
Date
mg/L mgJL
8/22/1990 ND
9/4/1990 ND
12/13/1993 ND ND
12/14/1993 ND ND
9/20/1994 ND
10/6/1994 ND
10/16/1995 0.38 ND
12/28/1995 ND ND
3/9/1996 0.684
11/18/1996 ND ND
7/8/1997 ND
12/18/1997 ND
7/23/1998 ND
12/15/1998 ND
8/23/1999 ND
11/17/1999 ND
12/12/1999 ND
W14/2000 ND
1/26/2000 ND
/17t2ao1 ND —

3/30/2001 ND
1/23/2002 ND
1/15/2002 0.33
//22/2003 ND
//30/2003 1.21
7/21/2004 ND
9/13/2004 ND
7/13/2005 0.1
7/17/2005 0.89
3/7/2006 0.63
8/26/2008 ND
7/23/2009 — ND
8/24/2010 ND
n 32 6
Mean* 0.21 — ND
Minimum 0.10 ND
Maximum 1.21 ND

ND = Not Detected (Detection Limit not Specified)


Detection Limit of 0.1 mg/L assumed for all ND samples
Maximum Contaminant Level = 10.0 mg/L

\\Vtdata\projects\57407.03 BWE Pownal Permitting\DatatAjtaGardens WQxIsxF N03


10/18/2010

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