U.S. DOT/PHMSA - Draft Regulatory Evaluation: Pipeline Safety: Polyamide-11 (PA-11) Plastic Pipe

Passage 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration#

Passage 2PIPELINE SAFETY: POLYAMIDE-11 (PA-11) PLASTIC PIPE DESIGN PRESSURES#

Passage 3Environmental Assessment [Docket No. PHMSA-2005-21305]#

Passage 4Prepared by: Environmental Engineering Division Volpe National Transportation Systems Center Research and Innovative Technology Administration and Pipeline and Hazardous Materials Safety Administration#

Passage 5This EA was prepared pursuant to section 102(2)(c) of the National Environmental Policy Act (42 U.S.C. § 4332) and the Council on Environmental Quality regulations (40 C.F.R. §§ 1500-1508). Table of Contents TOC \o "1-3" \h \z \u HYPERLINK \l "_Toc170114556" 1.0 Purpose and Need for Action PAGEREF _Toc170114556 \h 2 HYPERLINK \l "_Toc170114557" 1.1 Introduction PAGEREF _Toc170114557 \h 2 HYPERLINK \l "_Toc170114558" 1.2 Background PAGEREF _Toc170114558 \h 2 HYPERLINK \l "_Toc170114559" 1.3 Purpose and Need PAGEREF _Toc170114559 \h 2 HYPERLINK \l "_Toc170114560" 1.4 Public Involvement PAGEREF _Toc170114560 \h 2 HYPERLINK \l "_Toc170114561" 2.0 Alternatives PAGEREF _Toc170114561 \h 2 HYPERLINK \l "_Toc170114562" 2.1 No Action Alternative PAGEREF _Toc170114562 \h 2 HYPERLINK \l "_Toc170114563" 2.2 Alternative 1: Implement Arkema’s amended rulemaking petitions PAGEREF _Toc170114563 \h 2 HYPERLINK \l "_Toc170114564" 2.3 Alternative 2 (Proposed Action): Implement Arkema’s amended rulemaking petitions with modifications PAGEREF _Toc170114564 \h 2 HYPERLINK \l "_Toc170114565" 2.4 Comparison of the Alternatives PAGEREF _Toc170114565 \h 2 HYPERLINK \l "_Toc170114566" 3.0 Affected Environment and Environmental Consequences PAGEREF _Toc170114566 \h 2 HYPERLINK \l "_Toc170114567" 3.1 Affected Environment PAGEREF _Toc170114567 \h 2 HYPERLINK \l "_Toc170114568" 3.2 Environmental Consequences PAGEREF _Toc170114568 \h 2 HYPERLINK \l "_Toc170114569" 3.2.1 Public Health and Safety PAGEREF _Toc170114569 \h 2 HYPERLINK \l "_Toc170114570" 3.2.2 Hazardous Materials Transportation PAGEREF _Toc170114570 \h 2 HYPERLINK \l "_Toc170114571" 3.2.3 Socioeconomics PAGEREF _Toc170114571 \h 2 HYPERLINK \l "_Toc170114572" 3.2.4 Natural Resources PAGEREF _Toc170114572 \h 2 HYPERLINK \l "_Toc170114573" 3.2.5 Special Areas of Consideration PAGEREF _Toc170114573 \h 2 HYPERLINK \l "_Toc170114574" 4.0 List of Persons and Agencies Consulted PAGEREF _Toc170114574 \h 2 HYPERLINK \l "_Toc170114575" 5.0 List of Preparers and Reviewers PAGEREF _Toc170114575 \h 2 HYPERLINK \l "_Toc170114576" 6.0 References PAGEREF _Toc170114576 \h 2#

Passage 6List of Acronyms CEQ U.S. Council on Environmental Quality CFR Code of Federal Regulations DMS Docket Management System DOT U.S. Department of Transportation EA Environmental Assessment ESA Endangered Species Act GRI Gas Research Institute GTI Gas Technology Institute IPS Nominal pipe size NEPA National Environmental Policy Act NGL Natural gas liquids NHPA National Historic Preservation Act NPRM Notice of Proposed Rulemaking PA-11 Polyamide-11 PE Polyethylene PHMSA Pipeline and Hazardous Materials Safety Administration PVC Polyvinyl chloride psig Pounds per square inch gauge RCP Rapid crack propagation ROW Right of way SDR Standard Dimension Ratio PURPOSE AND NEED FOR ACTION INTRODUCTION#

Passage 7The nation's pipelines are a transportation system that enables the safe movement of energy products to industry and consumers. The Pipeline and Hazardous Materials Safety Administration (PHMSA) is the federal safety authority for the nation's natural gas and hazardous liquid pipelines. PHMSA is the federal agency charged with the safe and secure movement of almost 1 million daily shipments of hazardous materials by all modes of transportation. The agency also oversees the nation's pipeline infrastructure which accounts for 64 percent of the energy commodities consumed in the United States (PHMSA 2007a). The Federal Pipeline Safety Law (49 United States Code (U.S.C.) 60101 et seq.), Section 60102 authorizes the Secretary of Transportation to issue regulations applying to design, installation, inspection, emergency plans and procedures, testing, construction, extension, operation, replacement, and maintenance of pipeline facilities.#

Passage 8In keeping with its mission, PHMSA is proposing changes to the Federal pipeline safety regulations in 49 CFR Part 192, which cover the transportation of natural gas by pipeline. Specifically, PHMSA is proposing to change the design pressure limits in Sections 192.121 and 192.123 for certain pipes made of Polyaminde-11 (PA-11), a thermoplastic material. The changes would allow new PA-11 pipelines with a nominal pipe size (IPS) of 4 inches or less and a standard dimension ratio (SDR) of 11 to be designed using a design factor of 0.40 (in lieu of the currently stipulated 0.32) in the plastic pipe design formulas in Section 192.121. The design pressure limit in Section 192.123 would be raised from 100 pounds per square inch gauge (psig) to 200 psig for new 4-inch IPS or less, SDR-11, PA-11 pipelines in distribution systems and in class 3 and 4 locations. This would allow design pressures up to those calculated using the formulas in Section 192.121, but not greater than 200 psig. All other design pressure limitations would remain unchanged (PHMSA 2007b).#

Passage 9Federal agencies are required to evaluate the environmental impacts of their actions under the National Environmental Policy Act of 1969 (NEPA). NEPA and the Council on Environmental Quality’s (CEQ) implementing regulations establish policies and procedures that ensure environmental information is available to decision makers, regulatory agencies, and the public before Federal actions are implemented. PHMSA, with the cooperation of the John A. Volpe National Transportation Systems Center (Volpe Center) prepared this Environmental Assessment (EA) for the purpose of analyzing the potential environmental impacts associated with the rulemaking proposed by PHMSA. This EA follows the procedures established by the United States Department of Transportation (DOT) to implement NEPA, pursuant to the CEQ regulations. BACKGROUND#

Passage 10Thermoplastic pipe is currently used in natural gas transportation in the United States. PA-11 is one of a number of thermoplastics used to make pipe for gas pipeline operations. More commonly used thermoplastics are polyethylene (PE) and polyvinyl chloride (PVC).#

Passage 11The theoretical design pressure of thermoplastic pipe is a function of the outside diameter, wall thickness, and hydrostatic design basis of the pipe. To calculate the allowable design pressure for plastic pipe, the theoretical design pressure is reduced by a safety factor, commonly referred to as the design factor. For plastic pipe used in the transportation of natural gas, the allowable design pressure is limited by the Federal pipeline safety regulations in two ways. First, the plastic design pressure formula in Section 192.121 limits the allowable pressure to 32 percent of the theoretical design pressure. Second, a design pressure calculated using the design formula in Section 192.121 cannot exceed the design pressure limitations specified in Section 192.123. For plastic pipes produced before July 14, 2004, the design pressure cannot exceed 100 psig in distribution systems and in class 3 and 4 locations. For PE 2406 and PE 3408 thermoplastic pipe produced after July 14, 2004, the design pressure cannot exceed 125 psig for 12-inch IPS or less.#

Passage 12Beginning in the late 1990’s, research into the ability of PA-11 pipe to perform successfully and safely at higher pressures than currently allowed by Federal pipeline safety regulations was undertaken by Nicor Technologies (Nicor) for the Gas Research Institute (GRI) and its successor, the Gas Technology Institute (GTI). Their research included laboratory studies of the physical, mechanical, and chemical properties of PA-11 pipe materials, as well as laboratory and field evaluations of the economic feasibility for the use of PA-11. Final reports on the research performed by Nicor were published by GTI and are available in the Docket Management System (DMS) managed by the DOT ( HYPERLINK "http://dms.dot.gov" http://dms.dot.gov, see PHMSA-2005-21305-13, -14, and -15). The comprehensive technical research on the properties of PA-11 found that PA-11 pipe can safely be operated at higher pressures. Additionally, they found PA-11 can also be used in systems that necessitated exposure to high temperatures, which currently prevented the use of plastic pipe (GRI 1998). Lastly, the research concluded that PA-11 pipe could be used economically under pressures ranging from 150 psig to 300 psig (GRI 2000).#

Passage 13Subsequent to the completion of the laboratory and field research, a waiver was requested by Nicor Gas for a trial system of PA-11 pipe to be operated in Woodstock, Illinois, at higher pressures than currently allowed. That waiver was approved by the Illinois Commerce Commission and PHMSA. The following additional PA-11 trial systems were subsequently installed:#

Passage 14Atmos Energy – Louisiana Nashville Gas –Tennessee Questar Gas – Utah City of Mesa Gas Utilities – Arizona Public Service Company of New Mexico – New Mexico#

Passage 15Three of the trial systems were designed using a design factor of 0.40. One system was designed using a hydrostatic design basis of 1600 psig at a temperature of 140º F. All of the trial systems operate between 60 psig and 200 psig, with half operating above 175 psig. The GTI final report summarizing the results of the trial tests, “Utility Participation in PA-11 Evaluation Project,” March 2005, was published and is available on the DMS (see PHMSA-2005-21305-12). As a result, the trial systems operated safely for several years at operating pressures determined using the 0.40 design factor, which validated the safety of PA-11 in a variety of settings (GTI 2005).#

Passage 16In October 2004, Arkema, Inc. (Arkema), a manufacturer of PA-11 pipe, submitted two petitions to PHMSA requesting certain revisions of 49 CFR 192.121 and 192.123 relating to new PA-11 pipe. On April 6, 2006, Arkema submitted two amended petitions to PHMSA to replace the original petitions. Those amended petitions addressed public comments received by PHMSA and recommendations made by PHMSA staff. In its petitions, Arkema argued that new PA-11 material would pose equivalent or possibly less risk to the public at a design factor of 0.40 than older thermoplastic piping materials used with a 0.32 design factor (the current design factor). Furthermore, Arkema argued that allowing an increased design pressure for PA-11 pipe would allow gas pipeline operators to replace some steel pipe, with its risk of corrosion failure, with plastic pipe. PURPOSE AND NEED PHMSA is concerned with maintaining the safety of all pipe installed by gas pipeline operators, including thermoplastic pipe. PHMSA does not, however, want to continue with rules that have been overtaken by technological improvements in the production of pipes. Based on the research performed by GTI and Arkema’s rulemaking petitions, along with the positive public comments received on those petitions, PHMSA is considering taking action to amend the regulations in 49 CFR Part 192 regarding PA-11. The need for this action has been established through the receipt of Arkema’s rulemaking petitions. The purpose of this action is to maintain, and increase where possible, the safety of gas pipelines while allowing for improvements as the technology allows for increased safety, efficiency, and environmental protection. Therefore, PHMSA has initiated the rulemaking and NEPA processes to evaluate the impacts of amending the regulations regarding PA-11. PUBLIC INVOLVEMENT Public involvement is a critical aspect of the NEPA process. As such, PHMSA must consider any comments received from the public and any comments and recommendations of the Technical Pipeline Safety Standards Committee and other relevant stakeholders. PHMSA has already solicited public comments on the Arkema petition; responses, which generally have been favorable toward amending the regulations, can be found on the DMS. A notice of proposed rulemaking (NPRM) for “Pipeline Safety: Polyamide-11 (PA-11) Plastic Pipe Design Pressures” will be published after the completion of the EA, in which PHMSA will again request public comments on the proposed rulemaking. The public will also have the opportunity to comment on this EA before the Final EA is published (PHMSA 2000b).#

Passage 17ALTERNATIVES PHMSA considered the following three alternatives with respect to PA-11 pipe:#

Passage 18Take no action. Implement Arkema’s amended rulemaking petitions. Implement Arkema’s amended rulemaking petitions with modifications. NO ACTION ALTERNATIVE Under the no action alternative, PHMSA would ignore the petition made by Arkema and would not make any changes to 49 CFR Part 192 regarding PA-11. Under this alternative, no regulatory changes would be made, no costs would be incurred, and no benefits would result.#

Passage 19Taking no action would require ignoring current technological research as well as the subsequent petition by Arkema. PHMSA believes that taking no action would prevent industry from using a more cost effective technology that provides an equivalent or potentially greater degree of safety to the public. ALTERNATIVE 1: IMPLEMENT ARKEMA’S AMENDED RULEMAKING PETITIONS On April 6, 2006, Arkema submitted two amended petitions to PHMSA to replace the original petitions. Those new petitions addressed public comments received by PHMSA and recommendations made by PHMSA’s staff. In the executive summary of the first petition, Arkema requested an increase in the design factor in Section 192.121 for new PA-11 piping from 0.32 to 0.40 for “all pipe diameters” with two conditions: (1) the minimum wall thickness shall be SDR-11 and (2) the rapid crack propagation (RCP) characteristics at each new larger pipe diameter, or new increased wall thickness for an already tested diameter, shall be measured in accordance with accepted industry test standard methods. The language proposed for the new rule, however, was inconsistent with the executive summary. Arkema’s proposed rule only addressed new PA-11 pipe with wall thickness SDR-11 and does not address RCP. The proposed rule in Arkema’s second petition also did not address RCP, although it was covered in the discussion leading up to the rule. Furthermore, in the second petition, Arkema talks of limiting the PA-11 covered by the proposed change to 4-inch IPS and smaller, but the wording of the proposed rule did not include any wording regarding pipe diameters. Because of these flaws in Arkema’s amended petitions, this alternative was not considered viable and was dismissed from further analysis. ALTERNATIVE 2 (PROPOSED ACTION): IMPLEMENT ARKEMA’S AMENDED RULEMAKING PETITIONS WITH MODIFICATIONS PHMSA’s proposed action is to implement Arkema’s amended rulemaking petitions with some modifications. Specifically, the design pressure limit in Section 192.123 would be raised from 100 psig to 200 psig for new 4-inch IPS or less, SDR-11, PA-11 pipelines in distribution systems and in Class 3 and 4 locations. Additionally, the design factor for these pipelines would be raised from 0.32 to 0.40. Focusing exclusively on new PA-11 pipe that is also SDR-11, this alternative would not include any RCP provisions. Additionally, based on comments received from the Illinois Commerce Commission, the modified alternative would include a requirement that pipes with design pressures above 100 psig be buried with a warning tape or other suitable device to alert excavators of the presence of a high pressure gas line prior to reaching the burial depth of the pipeline. These modifications of Arkema’s amended rulemaking petitions would allow new PA-11 pipe to be used without compromising safety when (1) the design pressure does not exceed 200 psig, (2) the pipe is 4-inch IPS, (3) the pipe has a standard dimension ratio of SDR-11, and (4) a warning tape or other suitable device is present to warn excavators of a buried high-pressure gas line.#

Passage 20The 0.32 design factor was accepted as a conservative value based on the state of plastic pipe technology in 1978. Advances in plastic pipe technology, coupled with extensive laboratory and field research on PA-11 by Nicor/GTI, provide sufficient evidence that the design factor can be increased to 0.40 for certain PA-11 pipes without sacrificing safety. Research has also determined that “PA-11 pipe is a suitable plastic alternative to steel systems operating at higher pressure and under exposure to high temperatures for a short period of time” (GRI 1998). Based on Arkema’s petition, PHMSA believes that the new PA-11 material will achieve an equivalent (or potentially greater) level of safety for the public at a design factor of 0.40 as older thermoplastic piping materials used with a 0.32 design factor; and, allowing increased design pressure will in turn allow gas companies to replace metal piping systems with 2-inch plastic pipe operating up to 200 psig and avoid the potential risk of corrosion in steel pipes (Arkema 2006). Based on the research and validations that have occurred, PHMSA believes that implementing the proposed action will provide (at a minimum) equivalent safety. COMPARISON OF THE ALTERNATIVES Table 2-1 presents a tabular comparison of the environmental and socioeconomic consequences (listed by impact category) of the alternatives. Due to data availability and the scope of this assessment, the information detailed below concentrates on qualitative rather than quantitative analyses. Nevertheless, it is evident from Table 2-1 that the proposed rulemaking may result in beneficial impacts – most importantly, the positive impacts to public health and safety, in addition to positive indirect impacts to aspects of the physical and human environment.#

Passage 21Table STYLEREF 1 \s 2‑ SEQ Table \* ARABIC \s 1 1. Comparison of the alternatives by impact category. Impact Category No Action Alternative Proposed Action Alternative Public Health and Safety The No Action Alternative would not change the current and projected status of public health and safety. Potential impacts from incidental leaks and accidents to the human environment would continue to occur. Potential minor benefits due to increased usage of PA-11 decreased potential for corrosion leaks. Hazardous Materials Transportation The No Action Alternative would not change the current and projected status of hazardous materials transportation. Potential impacts from incidental leaks and accidents to the natural and human environment would continue to occur. Potential minor benefits due to increased usage of PA-11 decreased potential for corrosion leaks. Socioeconomics The No Action Alternative would not change the costs associated with pipeline safety and incidents, as there would be no changes to existing regulations. Increased usage of PA-11 is expected to result in minor beneficial impacts due to a reduction in the need for cathodic protection and potential reduction in corrosion leaks. Natural Resources The No Action Alternative would not change the current and projected status of natural resources. Potential impacts from incidental leaks and accidents to the natural environment would continue to occur. Potential minor beneficial impacts due to increased usage of PA-11 and a decrease in the risk of corrosion leaks, potential minor adverse impacts from ground disturbances. Additional “Special Areas of Consideration” Endangered Species Potential impacts to endangered species would continue to occur. However, since the rate of pipeline incidents is low, these impacts are expected to be minor. Impacts of the Proposed Action are not expected to be significantly different from the No Action. Resources protected by the NHPA Potential impacts to NHPA resources would continue to occur. However, since the rate of pipeline incidents is low, these impacts are expected to be minor. Impacts of the Proposed Action are not expected to be significantly different from the No Action. Section 4(f) resources Potential impacts to Section 4(f) resources would continue to occur. However, since the rate of pipeline incidents is low, these impacts are expected to be minor. Impacts of the Proposed Action are not expected to be significantly different from the No Action.#

Passage 22AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES AFFECTED ENVIRONMENT PHMSA is responsible for regulating the safety of over two million miles of gas and hazardous liquid pipelines. The nation’s pipelines are located throughout the United States, onshore and offshore, and traverse of variety of environments – from highly populated urban sites to remote, unpopulated rural areas (PHMSA 2007c). The proposed action would apply to all operators of gas distribution systems, as well as to the operators of gas transmission and gathering lines in Class 3 and Class 4 locations.#

Passage 23PHMSA estimates that approximately 1,450 gas distribution systems would be affected by the proposed rule. Those systems operate approximately 1.2 million miles of gas distribution mains, and connect to approximately 63 million services. PHMSA also estimates that approximately 1,450 gas transmission and gathering systems would be affected by the proposed rule. Those systems have approximately 35 thousand miles of pipeline in Class 3 locations and approximately 1,400 miles of pipeline in Class 4 locations. Although it would not be required under the potential amendment, since it deals strictly with operation and design parameters, PHMSA assumes that given the material’s cost efficiency, all operators would eventually incorporate some PA-11 into their systems.#

Passage 24The physical environment potentially affected by the proposed action includes the airspace, water resources (e.g., oceans, streams, lakes), cultural and historical resources (e.g., properties listed on the National Register of Historic Places), biological and ecological resources (e.g., coastal zones, wetlands, plant and animal species and their habitat, forests, grasslands, offshore marine ecosystems), and special ecological resources (e.g., threatened and endangered plant and animal species and their habitat, national and state parklands, biological reserves, Wild and Scenic Rivers) that exist directly adjacent to and within the vicinity of pipelines.#

Passage 25Because the pipelines subject to the proposed rulemaking contain hazardous materials, these resources within the physical affected environment, as well as public health and safety, may be affected by gas pipeline incidents such as spills and leaks. Depending on the size of the spill or gas leak, and the nature of the impact zone, the environmental impacts could vary from property damage and environmental damage to injuries or on rare occasions, fatalities. Incidents on pipelines can result in fires and explosions, with resulting damage to the local environment. In addition, since pipelines often contain gas streams laden with condensates and natural gas liquids (NGL's), failures also result in spills of these liquids, which can cause environmental harm. ENVIRONMENTAL CONSEQUENCES This EA will focus only on those resource categories that are potentially impacted by the alternatives, those that are of interest to the public, and/or important to the decision. The resource categories to be analyzed in this EA are: public health and safety, hazardous materials transportation, socioeconomics, natural resources, and other special areas of consideration. No construction is planned for this action, as it is a regulatory modification that expands the circumstances in which PA-11 is used. However, modifications to the existing regulations could lead operators to increase their replacements of steel piping with PA-11. Nonetheless, since the use of PA-11 is not mandatory, operators would only replace pipes ahead of schedule if it is the most cost-effective strategy, depending on their operational needs. If this is the case, a slight increase in construction and excavation activities could occur. If operators chose to replace any existing pipes at a quicker rate using PA-11 as a result of the modification of the regulations, it would be accomplished in established rights-of-way and through established methods for minimizing adverse impacts. Excavation activities would be temporary in nature with the area usually being restored to its preexisting condition. Therefore, no significant increase in adverse construction impacts is expected with this action. Similarly, no increase in adverse impacts to solid waste is expected as a result of this action. In general, the adverse environmental consequences of amending the regulations regarding PA-11 are expected to be minimal. Public Health and Safety No Action Alternative Under the No Action Alternative, PHMSA would not modify 49 CFR Part 192 regarding PA-11. Therefore, the design factor for PA-11 would remain at 0.32 psig and would also maintain the design pressure for PA-11 at 100 psig. Current pipelines would remain in place, and any steel pipelines would be expected to deteriorate at rates typical for that material. Leaks and incidents would also be expected to remain the same. Information on incidents in 2006 and their consequences is detailed in REF _Ref169087918 \h Table 3‑1. Although incidents do occur, PHMSA maintains high safety standards through regular maintenance and inspections of lines. Adopting the no action alternative is expected to result in the same level of adverse impacts that currently occurs.#

Passage 26Table STYLEREF 1 \s 3‑ SEQ Table \* ARABIC \s 1 1. Gas line incidents and associated damages in 2006. Type of Line Incidents Fatalities Injuries Property Damage Gas Distributions Lines 134 26 25 $22.5M Gas Transmission Lines 141 3 4 $48.6M 2006 Totals 275 29 29 $71.1M (PHMSA 2005)#

Passage 27Proposed Action Alternative Under the proposed action alternative, PHMSA would amend the regulations regarding PA-11 in 49 CFR Part 192 to modify the design factor and design pressure. Modifying the regulations should have no direct impact on public health and safety. No operators would be required to install these types of pipes, and therefore no significant increases in digging or other ground disruptions should occur. However, the regulation will allow operators to use PA-11 pipe in certain circumstances. In particular, operators of high pressure pipelines may opt to replace existing steel pipe with the approved PA-11 pipe.#

Passage 28Extensive research, testing, and field trials of PA-11 indicate that increasing the design factor and design pressure are well within the safety limitations of this type of pipe. The field trials were designed to cover a variety of geographic, climatic, and operating temperature and pressure environments. The conclusions of the research indicated that PA-11 piping systems can be safely and effectively installed at higher operating pressures than currently listed in the regulations regardless or geographic or climatic influences (GTI 2005). If some operators chose to replace existing steel pipe with PA-11 pipe, there could be a decrease in risk of corrosion leaks as PA-11 pipe is not susceptible to corrosion. This could result in beneficial impacts to public health and safety as the risk of leaks and leak-related accidents may be reduced slightly. Nonetheless, replacement of steel piping would be an individual business decision, and therefore the extent of the potential benefits is unclear, and assumed to be minor. Hazardous Materials Transportation No Action Alternative No changes to the pipeline regulations or the pipelines themselves would occur under the no action. Therefore, no changes to hazardous materials transportation should result. Leak and incident rates would be assumed to remain the same. Proposed Action Alternative The proposed action will widen the circumstances under which PA-11 may be used to transport gas. Specifically, PA-11 could be used in high-pressure distribution systems as long as the design pressure did not exceed 200 psig.#

Passage 29According to the extensive GTI research and field trials, PA-11 has been demonstrated as safe and environmentally safe for operations at the modified design pressure (200 psig) and design factor (0.40) for a variety of pressure and operating environments as specified in the petition (GTI 2005). Since the safety of these pipes have been verified, no adverse impacts to hazardous materials transportation would be expected if operators install them for uses allowed under the modified regulations.#

Passage 30Implementing the modifications to the regulations would have no other direct effects on hazardous materials transportation. However, this action would allow operators the choice to install thermoplastic piping instead of the standard steel piping, which is susceptible to corrosion. PA-11 piping, due to structure and composition, would not require cathodic protection. Therefore, as operators chose to replace steel piping with PA-11, there could be minor benefits of increased safety of hazardous materials transportation associated with this action as PA-11 would not be susceptible to corrosion leaks. Socioeconomics No Action Alternative No changes to the existing regulations would maintain the status quo regarding pipeline management. No costs would be incurred and hence no change in impacts would result. Operators would be required to use PA-11 only for design pressures less or equal to 100 psig, and hence high pressure distribution systems would continue to use and maintain steel operating systems. Proposed Action Alternative GTI states in their analysis report that studies have shown “that PA-11 piping systems offer all the advantages of plastic piping systems while greatly extending the operating pressure and offering a cost competitive alternative to steel piping systems. With the expanded use of PA-11 systems, gas consumers will benefit from the lower cost of these systems” (GTI 2005).#

Passage 31A detailed economic assessment was performed for this proposed rulemaking, and is detailed within the Regulatory Assessment for the NPRM on the DMS. The Regulatory Assessment found that quantified benefits could not be calculated for the proposed rule. Non-quantified benefits of the proposed rule would include a reduction in the need for cathodic protection when PA-11 pipe replaces steel pipe, as well as a reduction in the number of leaks due to corrosion when PA-11 pipe replaces steel pipe (PHMSA 2007d).#

Passage 32The costs associated with the propose rule include the costs of PA-11 pipe installation, and the costs of PA-11 pipe operations and maintenance. Installation estimates were only available for 2-inch IPS SDR-11 PA-11 pipe installed from coils. Those estimates, based on the experience of the PA-11 trial systems installed by Nashville Gas, Questar Gas, and the Public Service Company of New Mexico, were $11 to $17 per foot (in 2003-2004 dollars). No information was available for 4-inch IPS SDR-11 PA-11 pipe. No information was available for the operation and maintenance costs of PA-11 pipe (PHMSA 2007d).#

Passage 33The installation of PA-11 would not be mandated; it would be optional. Operators need not install PA-11 pipe if it does not make good business sense to do so. Therefore, PHMSA expects operators to install PA-11 pipe only if installation of PA-11 is the most cost-effective option. Consequently, PHMSA anticipates that the benefits of the proposed rule will equal or exceed its costs (PHMSA 2007d). Natural Resources No Action Alternative As no changes to the pipeline regulations would occur, no change to the management of pipeline distribution and transmission systems would occur. Rates for leaks and incidents would be assumed to stay the same. Currently, most distribution and transmission systems have effective leak management programs. Therefore, since the incidence of accidents is low, significant adverse impacts to natural resources, including air quality, water quality, and wildlife would not be expected. Proposed Action Alternative As discussed previously, amending the regulations regarding the design factor and design pressure for PA-11 may broaden its usage by operators. PA-11 does not biodegrade, dissolve, corrode, chalk, or otherwise decompose when left in the ground or in water. The same material is also used in buried and submerged communications and power cables, and in outer sheaths (in contact with sea water) of offshore oil and gas pipes. The material is environmentally stable (PHMSA 2007e). Therefore, because of the material’s stability, no increase in leaks or incidents is expected. Consequently, no adverse impacts to air quality, water quality, or wildlife are expected. Rather, given the material’s stability as compared to steel, there may be minor benefits to natural resources due to the potential decrease in risk of leaks if operators chose to use the material.#

Passage 34Replacement of pipes with PA-11 would occur at the operator’s discretion and according to established methods and rights-of-way. Therefore, no significant adverse impacts are expected to land use as no land conversions would be associated with this action. If operators chose to install new pipes, they would be responsible for complying with applicable Federal, State and local wetland, wildlife protection, and other relevant environmental laws. Therefore, this action should have no significant adverse impacts to wetlands, nor to flood plains, coastal zones, coastal barriers, or wild and scenic rivers. Special Areas of Consideration Special areas of consideration evaluated in this EA include endangered species protected under the Endangered Species Act (ESA), historic properties protected by Section 106 of the National Historic Preservation Act (NHPA) and DOT Section 4(f) properties. No Action Alternative No changes to the pipeline regulations would mean that the design factor for PA-11 would remain at 0.32 psig and would also maintain the design pressure for PA-11 at 100 psig. This should have no adverse effects on any special areas of consideration. Current pipelines would continue to need regular maintenance and replacement at the same rates as previously recorded. Incidental leaks and accidents, which have the potential to impact special areas, would be expected to remain the same. Proposed Action Alternative In general, revising the pipeline safety regulations in 49 CFR Part 192 concerning PA-11 is expected to have minimal negative impacts on the special areas of consideration mentioned above. As discussed previously, the change in regulations would broaden the circumstances under which PA-11 may be used. Therefore, there could be a slight increase in usage of PA-11, which under the new regulations, could be used in high pressure distribution systems. Given the material’s environmental stability and demonstrated safety, no increases in incidents, leaks, or other disturbances are expected. Therefore, no significant adverse impacts are expected to wildlife, including threatened and endangered species, in association with the increased use of the material. However, if operators chose to install new pipe, the would be responsible for complying with applicable Federal/State endangered species laws depending on the presence of species or habitat in the area of excavation.#

Passage 35Based on the information found at 36 CFR 800.16(y), the rulemaking proposed under the Proposed Action Alternative constitutes an undertaking, as it is an activity funded under the direct jurisdiction of PHMSA. Based on the lack of national data on pipelines in the vicinity of Sec. 106 protected resources, it is impossible to estimate the extent of potential impacts on historical and cultural resources protected under the NHPA. However, the rulemaking should not directly affect any historic or cultural resources, as it allows for an increased design factor and design pressure for PA-11. Given the environmental stability and demonstrated safety of the material, use of PA-11 should not increase the incidence of accidents or leaks.#

Passage 36Modifications to the existing regulations could lead operators to increase their replacements of steel piping with PA-11. According to the socioeconomic analysis, it is assumed that operators would only replace pipes ahead of schedule if it is the most cost-effective strategy, depending on their operational needs. If this is the case, a slight increase in construction and excavation activities could occur. The minor increase in activities was expected to have negligible construction impacts. Therefore, secondary impacts to historic and cultural resources as a result of pipe replacement-related construction are expected to be minor. Any impacts would be mitigated by the fact that most activities for routine pipeline repair and maintenance involve excavating and backfilling around existing pipelines, and initial pipeline construction would have revealed most archeological artifacts. Additionally, ground excavation would typically not impact historic structures such as buildings. Thus, the proposed action does not have the potential to cause adverse effects on historic properties or cultural resources.#

Passage 37Section 4(f) of the DOT Act requires agencies within the DOT to make special effort to preserve the natural beauty of historic sites and public parks and recreation lands; if a transportation program requires the use of public land in a public park, the program must include all possible planning to minimize harm to the park or historic area. The proposed action does not include the use of any land from, or in close proximity to, a public park, recreation area, wildlife and waterfowl refuge, or historic site, because of an activity such as construction, of a new building. As such, there will not be a 4(f) statement prepared for this proposed rulemaking.#

Passage 38LIST OF PERSONS AND AGENCIES CONSULTED Multiple stakeholder groups, along with the public, were consulted during the alternatives development process for the modification of the regulations as detailed in the NPRM. In summary, the stakeholder groups included the following:#

Passage 39American Gas Association Arkema, Inc. City of Mesa, Arizona Continental Industries, Inc. Gas Piping Technology Committee Gas Technology Institute Nicor Technologies Palermo Plastics Pipe Consulting Puget Sound Energy R.W. Lyall & Company, Inc.#

Passage 40LIST OF PREPARERS AND REVIEWERS This EA was prepared and reviewed by staff and specialists within PHMSA and the Environmental Engineering Division within the Volpe National Transportation Systems Center (Research and Innovative Technology Administration).#

Passage 41REFERENCES Arkema 2006. Petition of Arkema Inc. to Amend Title 49 Code of Federal Regulations Section 192.123. Arkema, Inc. HYPERLINK "http://dmses.dot.gov/docimages/pdf96/393219_web.pdf" http://dmses.dot.gov/docimages/pdf96/393219_web.pdf (accessed June 11, 2007).#

Passage 42Gas Research Institute (GRI) 1988. Technical Reference on the Physical, Mechanical, and Chemical Properties of PA11 Pipe Materials for Us in Gas Distribution Systems Operating at Higher Pressures and Temperatures. GRI-99/0039. Prepared by Nicor Technologies. Naperville, IL: GRI.#

Passage 43Gas Research Institute (GRI) 2000. Evaluation of PA11 Piping for Use in Gas Distribution Systems Operating at High Pressures and Temperatures. GRI00/0050. Prepared by Nicor Technologies. Naperville, IL: GRI.#

Passage 44Gas Technology Institute (GTI) 2005. Utility Participation In PA11 Evaluation Project. GRI 05/0195. Des Plaines, IL: GTI.#

Passage 45Pipeline and Hazardous Materials Safety Administration (PHMSA) 2005. Pipeline Statistics. HYPERLINK "http://ops.dot.gov/stats/stats.htm" http://ops.dot.gov/stats/stats.htm (accessed June 7, 2007).#

Passage 46Pipeline and Hazardous Materials Safety Administration (PHMSA) 2007a. About PHMSA. HYPERLINK "http://www.phmsa.dot.gov/about/index.html" http://www.phmsa.dot.gov/about/index.html (accessed June 11, 2007).#

Passage 47Pipeline and Hazardous Materials Safety Administration (PHMSA) 2007b. Notice of Proposed Rulemaking (Draft). Pipeline Safety: Polyamide-11 (Pa-11) Plastic Pipe Design Pressures. Docket No. PHMSA-2005-21305, Notice 2. Washington, D.C.: PHMSA.#

Passage 48Pipeline and Hazardous Materials Safety Administration (PHMSA) 2007c. Pipeline Basics. HYPERLINK "http://primis.phmsa.dot.gov/comm/PipelineBasics.htm" http://primis.phmsa.dot.gov/comm/PipelineBasics.htm (accessed June 8, 2007).#

Passage 49Pipeline and Hazardous Materials Safety Administration (PHMSA) 2007d. Regulatory Assessment with Regulatory Flexibility Analysis and Paperwork Reduction Act Analysis (Draft). Notice of Proposed Rulemaking – Pipeline Safety: Polyamide- 11 (PA-11) Plastic Pipe Design Pressures. Docket No. PHMSA-2005-21305. Washington, D.C.: PHMSA.#

Passage 50Pipeline and Hazardous Materials Safety Administration (PHMSA) 2007e. Personal electronic mail from Richard Sanders, PHMSA, to Paul Zebe, Volpe Center, on June 3, 2007.#

Passage 51Standard dimension ratio: The ratio of the average specified outside diameter of a pipe to the minimum specified wall thickness, corresponding to a value from a common numbering system that was derived from the American National Standards Institute preferred number series 10. 42 U.S.C. § 4321 et seq. 40 C.F.R. § 1500 et seq. DOT Order 5610.1C, Procedures for Considering Environmental Impacts, 9/18/79, as amended 7/13/82, 7/30/85. As specified in 49 CFR Part 192, A Class 3 location is any class location unit that has 46 or more building intended for human occupancy; or, an area where the pipeline lies within 100 yards of either a building or a small, well-defined outside area (such as a playground, recreation area, outdoor theater, or other place of public assembly) that is occupied by 20 or more persons on at least 5 days a week for 10 weeks in any 12-month period. As specified in 49 CFR Part 192, A Class 4 location is any class location unit where buildings with four or more stories above ground are prevalent. These estimates are based on information provided to PHMSA in the gas distribution and transmission system annual reports submitted for 2005. In 2005, gas transmission systems had 32,737 miles of pipeline in Class 3 locations and 1,391 miles of pipeline in Class 4 locations. Gas gathering systems had 2,477 miles of pipeline in Class 3 locations and 12 miles of pipeline in Class 4 locations. 36 CFR 800.16(y): “Undertaking means a project, activity, or program funded in whole or in part under the direct or indirect jurisdiction of a Federal agency, including those carried out by or on behalf of a Federal agency; those carried out with Federal financial assistance; and those requiring a Federal permit, license, or approval.”#