# U.S. DOT/PHMSA - Direct Assessment Final Rule Environmental Assessment

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- **citation:** 0900006480e84e4c
- **title:** U.S. DOT/PHMSA - Direct Assessment Final Rule Environmental Assessment
- **source type:** rulemaking
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** current
- **official:** true
- **published on:** Not available
- **effective on:** Not available
- **summary:** Final Environmental Assessment Standards for Direct Assessment of Gas and Hazardous Liquid Pipelines U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration FINAL RULE PIPELINE SAFETY: STANDARDS FOR DIRECT ASSESSMENT OF GAS AND HAZARDOUS LIQUID PIPELINES Final Environmental Assessment August 2005 Prepared for: Office of Pipeline Safety Pipeline... Final Environmental Assessment Standards for Direct Assessment of Gas and Hazardous Liquid Pipelines standards and other policies concerning gas pipelines. The THLPSSC is a similar committee that provides advice about hazardous liquid and carbon dioxide pipelines. Each committee has an authorized membership of 15...
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Final Environmental Assessment Standards for Direct Assessment of Gas and Hazardous Liquid Pipelines
U.S. Department of Transportation
Pipeline and Hazardous Materials Safety
Administration
FINAL RULE
PIPELINE SAFETY: STANDARDS FOR DIRECT
ASSESSMENT OF GAS AND HAZARDOUS LIQUID
PIPELINES
Final Environmental Assessment
August 2005
Prepared for:
Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Prepared by:
John A. Volpe National Transportation Systems Center
Research and Innovative Technology Administration

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Final Environmental Assessment Standards for Direct Assessment of Gas and Hazardous Liquid Pipelines
TABLE OF CONTENTS
TABLE OF CONTENTS I
LIST OF ACRONYMS II
1.0 PURPOSE OF AND NEED FOR ACTION 1-1
1.1 INTRODUCTION 1-1
1.2 BACKGROUND 1-2
1.3 PURPOSE OF AND NEED FOR ACTION 1-3
1.4 PUBLIC INVOLVEMENT 1-4
1.5 SCOPE OF ANALYSIS 1-5
2.0 ACTION AND ALTERNATIVE 2-1
2.1 OVERVIEW OF ALTERNATIVES 2-1
2.2 ALTERNATIVES DEVELOPMENT PROCESS 2-1
2.3 NO ACTION ALTERNATIVE 2-1
2.4 ACTION ALTERNATIVE 2-1
2.5 COMPARISON OF THE ALTERNATIVES 2-2
3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 3-1
3.1 AFFECTED ENVIRONMENT 3-1
3.1.1 Physical Environment Affected 3-1
3.2 ENVIRONMENTAL CONSEQUENCES 3-2
3.2.1 Public Health and Safety 3-2
3.2.2 Hazardous Materials Transportation 3-2
3.2.3 Socioeconomics 3-3
3.2.4 Special Areas of Consideration 3-5
3.2.5 Additional Benefits of the Action Alternative 3-6
4.0 LIST OF PERSONS CONSULTED 4-1
5.0 LIST OF PREPARERS AND REVIEWERS 5-1
6.0 REFERENCES 6-1
i

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Final Environmental Assessment Standards for Direct Assessment of Gas and Hazardous Liquid Pipelines
LIST OF ACRONYMS
FR Federal Register
NEPA National Environmental Policy Act
NHPA National Historic Preservation Act
OPS Office of Pipeline Safety
U.S. United States
U.S.C. United States Code
DOT United States Department of Transportation
PHMSA Pipeline and Hazardous Materials Safety Administration
RPSA Research and Special Programs Administration
ii

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Final Environmental Assessment Standards for Direct Assessment of Gas and Hazardous Liquid Pipelines
1.0 PURPOSE OF AND NEED FOR ACTION
1.1 INTRODUCTION
The 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’s (PHMSA) Office of Pipeline Safety (OPS) is the federal safety
authority for the nation's natural gas and hazardous liquid pipelines. The primary mission
of OPS is to ensure the safe, reliable, and environmentally sound operation of the nation's
pipeline transportation system (OPS 2005).
In response to a statutory directive, OPS published a Notice of Proposed Rulemaking
(NPRM) concerning standards that would apply to the use of direct assessment on any
regulated onshore ferrous pipeline (69 FR 61771; Oct. 21, 2004). The proposed
standards were the same as those in effect for gas transmission lines under OPS’ integrity
management regulations. In consideration of public comments and advisory committee
recommendations, OPS has prepared a Final Rule document. The standards included in
the Final Rule are similar to the proposed standards, but they do not apply to gas
distribution lines.
Direct assessment is a process of managing the effects of external corrosion, internal
corrosion, or stress-corrosion cracking on ferrous pipelines. Operators use direct
assessment to evaluate the risks to their pipeline that are associated with corrosion. The
process involves data collection, indirect inspection, direct examination, and evaluation.
Operators use direct assessment not only to find existing corrosion defects but also to
prevent future corrosion problems. Broader application of direct assessment standards
should enhance public confidence in the use of direct assessment to assure pipeline
safety.
The National Environmental Policy Act of 1969 (NEPA)1 and the Council on
Environmental Quality’s (CEQ) implementing regulations2 establish policies and
procedures that ensure environmental information is available to decision makers,
regulatory agencies, and the public before Federal actions are implemented. OPS, with
the cooperation of the U.S. Department of Transportation John A. Volpe National
Transportation Systems Center (Volpe Center), prepared this Final Environmental
Assessment (EA) for the purpose of analyzing the potential environmental impacts
associated with the Final Rule prepared by OPS. This EA follows the procedures
established by the United States Department of Transportation (DOT)3 to implement
NEPA, pursuant to the CEQ regulations.
OPS prepared a Draft EA for the NPRM in September 2004 (OPS 2004a). The
1 42 U.S.C. § 4321 et seq.
2 40 C.F.R. § 1500 et seq.
3 DOT Order 5610.1C, Procedures for Considering Environmental Impacts, 9/18/79, as amended 7/13/82,
7/30/85.
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Final Environmental Assessment Standards for Direct Assessment of Gas and Hazardous Liquid Pipelines
information presented in the Draft EA shows that the proposed direct assessment
standards are not expected to have significant environmental impacts. OPS received no
comments on the Draft EA from the public or its pipeline safety advisory committees.
The information presented in this Final EA also shows that the Final Rule is not expected
to have significant environmental impacts.
1.2 BACKGROUND
Current regulations governing integrity management of gas transmission lines require that
operators using direct assessment to evaluate corrosion risks must carry out that direct
assessment according to particular standards. Congress has recognized the advantages of
using direct assessment on DOT regulated gas, hazardous liquid, and carbon dioxide
pipeline facilities. Section 14 of the Pipeline Safety Improvement Act of 2002 (Pub. L.
107-355; Dec. 17, 2002) directs DOT to issue regulations on using internal inspection,
pressure testing, and direct assessment to manage the risks to gas pipeline facilities in
high-consequence areas. In addition, Section 23 of that statute directs DOT to issue
regulations prescribing standards for inspecting pipeline facilities by direct assessment.
In response to the first statutory directive, DOT’s Research and Special Programs
Administration (RSPA)4 published regulations in 49 CFR Part 192, Subpart O, that
require operators to follow detailed programs to manage the integrity of gas transmission
line segments in high-consequence areas. These regulations also require that if operators
use direct assessment in their integrity management programs, they must carry out the
direct assessment according to the standards in §§ 192.925, 192.927, and 192.929, as
appropriate.5
Each of these standards includes cross-references to the American Society of Mechanical
Engineers’ document, ASME B31.8S-2001, “Managing System Integrity of Gas
Pipelines.” This document describes a comprehensive process to assess and mitigate the
likelihood and consequences of gas pipeline risks. In addition, § 192.925 cross-
references a document published by NACE International, titled NACE Standard
RP0502–2002, “Pipeline External Corrosion Direct Assessment Methodology.” The
NACE document describes a step-by-step process for identifying and addressing external
corrosion activity, repairing defects, and taking remedial action. Other provisions of the
4 The Norman Y. Mineta Research and Special Programs Improvement Act (Pub. L. 108–426, 118;
November 30, 2004) reorganized RSPA into two new DOT administrations: PHMSA and the Research and
Innovative Technology Administration. RSPA’s regulatory authority over pipeline and hazardous
materials safety was transferred to PHMSA.
5 The standard on external corrosion direct assessment (§ 192.925) requires operators to integrate data on
physical characteristics and operating history, conduct indirect aboveground inspections, directly examine
pipe surfaces, and evaluate the effectiveness of the assessment process. Under the standard for direct
assessment of internal corrosion (§ 192.927), operators must predict locations where electrolytes may
accumulate in normally dry-gas pipelines, examine those locations, and validate the assessment process.
The standard for direct assessment of stress-corrosion cracking (§ 192.929) involves collecting data
relevant to stress-corrosion cracking, assessing the risk of pipeline segments, and examining and evaluating
segments at risk.
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Final Environmental Assessment Standards for Direct Assessment of Gas and Hazardous Liquid Pipelines
Part 192 standards ensure that operators use appropriate criteria in making direct
assessment decisions.
In response to the second statutory directive, RSPA published a notice of proposed
rulemaking (NPRM)(69 FR 61771; Oct. 21, 2004). The NPRM proposed standards for
using direct assessment on any onshore ferrous gas pipeline regulated by 49 CFR Part
192 or onshore ferrous hazardous liquid or carbon dioxide pipeline regulated by 49 CFR
Part 195. Under proposed § 192.490, if an operator chooses to use direct assessment to
evaluate the threat of external corrosion, internal corrosion, or stress-corrosion cracking
on a regulated onshore gas pipeline, the direct assessment would have to be done
according to the standards in § 192.925, § 192.927, or § 192.929, as appropriate. For
regulated hazardous liquid and carbon dioxide pipelines, proposed § 195.588 would
require similar action, except compliance with § 192.927, because this internal corrosion
Direct Assessment standard is only suitable for dry gas pipelines.
In § 192.903, PHMSA defines direct assessment as:
…an integrity assessment method that utilizes a process to evaluate certain threats (i.e.,
external corrosion, internal corrosion and stress corrosion cracking) to a covered pipeline
segment’s integrity. The process includes the gathering and integration of risk factor
data, indirect examination or analysis to identify areas of suspected corrosion, direct
examination of the pipeline in these areas, and post assessment evaluation
Direct assessment is a new process. Currently, direct assessment is applied mainly to gas
transmission lines subject to Subpart O of Part 192. However, a few operators have used
direct assessment on hazardous liquid pipelines to meet integrity management
requirements in 49 CFR 195.452. Tests of direct assessment indicate that it is reasonably
reliable. It is reported that those tests have found that direct assessment produces
“…reliable results with a 70 to 80 percent positive predictive capability.”6 In addition to
corrosion, it might be noted, operators can also use direct assessment to evaluate
mechanical damage to pipelines.7
1.3 PURPOSE OF AND NEED FOR ACTION
The purpose of the Final Rule is to increase pipeline safety through broader application of
direct assessment standards currently applicable only to gas transmission lines in high
consequence areas. Congress has recognized the advantages of using direct assessment
on DOT regulated gas, hazardous liquid, and carbon dioxide pipeline facilities and
directed DOT to prescribe standards for its use. Thus, the Final Rule contains standards
that operators must meet if they use direct assessment on certain onshore gas, hazardous
6 Neil G. Thompson, “Appendix E, Gas and Liquid Transmission Pipelines,” Cost of Corrosion, FHWA
Report FHWA-01-156, April 2005, p. E-36, www.corrosioncost.com/home.html.
7 Neil G. Thompson, “Appendix E, Gas and Liquid Transmission Pipelines,” Cost of Corrosion, FHWA
Report FHWA-01-156, April 2005, p. E-35, www.corrosioncost.com/home.html.
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Final Environmental Assessment Standards for Direct Assessment of Gas and Hazardous Liquid Pipelines
liquid, or carbon dioxide pipelines, thereby enhancing the overall safety of pipelines. The
Final Rule amends the Federal pipeline safety regulations by requiring operators using
direct assessment for evaluating corrosion risks to perform that direct assessment
according to particular standards. For gas transmission pipelines, standards are specified
for internal corrosion, external corrosion, and stress-corrosion cracking. For hazardous
liquid pipelines, standards are specified for external corrosion only. These standards are
similar to the standards currently in effect for gas transmission lines in high consequence
areas under the integrity management regulations in 49 CFR Part 192, Subpart O.
The need for this action is derived from the fact that OPS presently has regulations
governing integrity management of gas transmission lines requiring that operators using
direct assessment to evaluate corrosion risks must carry out that direct assessment
according to particular standards. Those regulations are found in 49 CFR Part192. In
response to a statutory directive, OPS is proposing that DOT prescribe similar standards
that operators must meet if they use direct assessment on certain other onshore gas,
hazardous liquid, or carbon dioxide pipelines. Broader application of direct assessment
standards currently in effect should enhance public confidence in the use of direct
assessment to assure pipeline safety, control pipeline corrosion, and possibly reduce the
number of corrosion-caused accidents.
Current standards for gas transmission pipelines are not inherently appropriate only for
gas transmission lines in high consequence areas and the selected standard for hazardous
liquid and carbon dioxide pipelines is needed to provide guidance to operators of these
types of pipelines, since direct assessment is a new process and its use is so far limited
primarily to gas transmission lines subject to Subpart O of Part 192. A further reason for
the Action is that the proposed standards have already undergone public notice and
comment in the gas transmission integrity management proceeding, and they were
generally well received by the gas transmission industry. Finally, the proposed standards
rely heavily on consensus standards published by NACE International and the American
Society of Mechanical Engineers (ASME), two organizations whose standards are widely
used and highly regarded in the pipeline industry.
1.4 PUBLIC INVOLVEMENT
Public involvement is a critical aspect of the NEPA process. As such, OPS must consider
any comments received from the public and any comments and recommendations of
relevant stakeholders. Public comments and advisory committee recommendations have
been addressed in the development of the Final Rule. However, none of the commenters
or committee members spoke directly about the Draft EA that OPS prepared for the
NPRM.
The Technical Pipeline Safety Standards Committee (TPSSC) and the Technical
Hazardous Liquid Pipeline Safety Standards Committee (THLPSSC) considered the
NPRM at meetings in Washington, D.C. on December 14 and 15, 2004. The TPSSC is a
statutorily mandated advisory committee that advises PHMSA on proposed safety
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Final Environmental Assessment Standards for Direct Assessment of Gas and Hazardous Liquid Pipelines
standards and other policies concerning gas pipelines. The THLPSSC is a similar
committee that provides advice about hazardous liquid and carbon dioxide pipelines.
Each committee has an authorized membership of 15 persons, five each representing
government, industry, and the public. Each member is qualified to consider the technical
feasibility, reasonableness, cost-effectiveness, and practicability of proposed pipeline
safety standards. A transcript of each committee’s meeting is available in Docket No.
PHMSA-98-4470.
After careful consideration of the NPRM, the THLPSSC voted unanimously to
recommend the following: (1) adopt a single definition of direct assessment for use inside
and outside high-consequence areas; (2) state direct assessment standards directly in Part
195, rather than by cross-referencing Part 192 standards; (3) for direct assessment of
stress corrosion cracking, consider adopting the NACE consensus standard currently
under development; and (4) amend the integrity management rule (§ 195.452) to allow
use of direct assessment without prior notice.
As a result of its deliberation, the TPSSC voted unanimously that proposed § 192.490
should not be applied to gas distribution lines. It also voted unanimously that the final
rule should distinguish direct assessment from similar methods of assessing corrosion.
This latter recommendation was intended to clarify situations in which operators could
use similar methods without incurring the proposed direct assessment standards.
Comments in response to the NPRM where received from 19 different sources. Only one
commenter, the Cook Inlet Regional Citizens Advisory Council, a monitor of oil terminal
operations, supported the proposed rules without change. The Council welcomed the
additional federal standards because of the need to control pipeline corrosion. The
remaining commenters were primarily concerned about specific issues. Those issues are
presented in the Final Rule, along with OPS’ disposition of the issues and the advisory
committees’ recommendations.
1.5 SCOPE OF ANALYSIS
This Final EA analyzes the potential environmental consequences associated with
implementing the Final Rule. Chapter 1 provides background information regarding the
purpose of and need for the rulemaking. Chapter 2 describes OPS’ federal action and the
No-Action Alternative. Chapter 3 describes the environment affected by the rulemaking,
as well as potential environmental consequences to that affected environment from the
alternatives. This EA will focus only on those resource categories that are of interest to
the public and/or important to the decision: Public Health and Safety, Hazardous
Materials Transportation, Socioeconomics, and other Special Areas of Consideration.
Chapter 4 lists those agencies and persons with whom OPS consulted during this NEPA
compliance process. Chapter 5 lists the preparers and reviewers of this document.
Finally, Chapter 6 lists references consulted during the development of this document.
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Final Environmental Assessment Standards for Direct Assessment of Gas and Hazardous Liquid Pipelines
2.0 ACTION AND ALTERNATIVE
2.1 OVERVIEW OF ALTERNATIVES
This Chapter presents the NEPA alternatives for the proposed regulations. The No
Action alternative is used in the NEPA analysis to define existing conditions of the
natural and man-made environments. The Action Alternatives define those alternative
approaches that the federal agency is considering for an agency action.
2.2 ALTERNATIVES DEVELOPMENT PROCESS
OPS’ authority to issue safety standards for the design, construction, operation,
replacement, and maintenance of gas and hazardous liquid pipelines is found in 49 U.S.C.
60102(a). OPS considered two alternatives to respond to Section 23 of the Pipeline
Safety Improvement Act of 2002 (Pub. L. 107-355; Dec. 17, 2002), Congress’ second
directive in that Act relating to direct assessment: (1) No Action, and (2) Action – apply
existing direct assessment standards to certain other regulated pipelines besides gas
transmission pipelines in high consequence areas.
2.3 NO ACTION ALTERNATIVE
Under the No Action alternative the existing regulations would remain in place. Thus, no
additional regulations are needed given that OPS has already issued regulations that
prescribe standards for the use of direct assessment. This alternative was rejected,
however, because the existing regulations are limited to gas transmission lines in high
consequence areas. They do not cover all pipelines that fall under Congress’ second
directive. Therefore, the No Action Alternative does not meet the purpose and need of
the regulation. However, as the No Action Alternative represents the current conditions,
it will be used as the baseline for analyzing the implications of the Action.
2.4 ACTION ALTERNATIVE
The Action alternative was selected because (1) the existing standards for gas
transmission pipelines are not inherently appropriate only for gas transmission lines in
high consequence areas and (2) the existing standards have proved satisfactory in
practice. A further reason for choosing the second alternative is that the existing
standards have already undergone public notice and comment in the gas transmission
integrity management proceeding, and they were generally well received by the gas
transmission industry. Finally, the existing standards rely heavily on consensus standards
published by NACE International and the American Society of Mechanical Engineers
(ASME), two organizations whose standards are widely used and highly regarded in the
pipeline industry.
The Action alternative covers gas transmission pipelines (including those gas gathering
lines subject to Federal safety regulation) and hazardous liquid and carbon dioxide
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Final Environmental Assessment Standards for Direct Assessment of Gas and Hazardous Liquid Pipelines
pipelines. Although in the NPRM this alternative covered gas distribution pipelines,
these lines are excluded from the Final Rule. The principal features of the Final Rule
include (1) incorporating by reference NACE Standard RP0502-2002 “Pipeline External
Corrosion Direct Assessment Methodology” (2002); (2) adding a new § 192.490, which
covers direct assessment for gas transmission and gathering lines; (3) adding a new
§ 192.588, which covers direct assessment for hazardous liquid and carbon dioxide
pipelines; and (4) amending § 192.452 to remove the requirement that operators give
OPS 90 days’ notice before using direct assessment to assess the integrity of hazardous
liquid and carbon dioxide pipelines.
Under the Final Rule, if an operator chooses to use direct assessment to evaluate the
threat of external corrosion, internal corrosion, or stress-corrosion cracking on a regulated
onshore ferrous gas transmission line, the direct assessment would have to be done
according to the existing standards in §§ 192.925, 192.927, or 192.929, as appropriate.
These standards do not apply to methods associated with direct assessment, such as close
interval surveys, voltage gradient surveys, or examination of exposed pipelines, when
used separately from the direct assessment process.
Onshore hazardous liquid and carbon dioxide pipelines are covered by § 195.588. That
section focuses exclusively on direct assessment for external corrosion. Operators
undertaking direct assessment for external corrosion must follow the requirements of
NACE Standard RP0502-2002. Under § 195.588, operators must develop and implement
an external corrosion direct assessment (ECDA) plan that covers pre-assessment, indirect
examination, direct examination, and post assessment. The requirement specified in
§ 195.588 does not apply to methods associated with direct assessment, such as close
interval surveys, voltage gradient surveys, or examination of exposed pipelines, when
used separately from the direct assessment process.
2.5 COMPARISON OF THE ALTERNATIVES
This section compares the potential consequences of the Action Alternative and the No
Action Alternative. Even though the No Action Alternative does not meet the purpose
and need established by OPS for this regulation, it was analyzed to provide a baseline
against which to compare the Action Alternative.
Table 2-1 presents a comparison of the environmental and socioeconomic consequences
of the Action Alternative and No-Action Alternative. It lists several impact categories for
which there exists a potential for a positive or negative indirect impact from the
alternatives. Without certain key pieces of information and a costly quantitative analysis,
it is impossible to accurately quantify most of these impacts, though qualitative rationale
is offered in this document. Nevertheless, it is evident from Table 2-1 that the
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.
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Final Environmental Assessment Standards for Direct Assessment of Gas and Hazardous Liquid Pipelines
Table 2-1. Environmental Consequences of Alternatives
Impact Category No Action Alternative Action Alternative
Public Health and
Safety
The No Action Alternative would
not change the current and
projected status of public health
and safety.
The Action alternative is expected to make pipeline
operations safer by helping to reduce the number of
incidents due to corrosion on onshore gas and
hazardous liquid pipelines. Therefore, the Action
alternative would result in a net reduction in the level
of public health and safety impacts.
Hazardous
Materials
Transportation
The No Action Alternative would
not change the current and
projected status of hazardous
materials transportation. Potential
impacts to the natural and human
environment would continue to
occur.
The Action alternative is expected to increase
pipeline safety through the broader application of
direct assessment standards, potentially resulting in a
reduction in corrosion-caused incidents gas and
hazardous liquid pipelines. Therefore, the Action
would result in a net reduction in the level of impacts
from hazardous materials transportation.
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.
The Action alternative would result in a benefit to
socioeconomic resources from increased pipeline
safety, and associated reductions in incident property
damage and public health and safety related costs.
Additional “Special Areas of Consideration”
Endangered
Species
Potential impacts to endangered
species would continue to occur.
However, since the rate of pipeline
incidents is small, these impacts
are expected to be minor.
Since the Action alternative could reduce the
likelihood of hazardous liquid spills or natural gas
leaks related to pipeline incidents, it may result in a
minor benefit to endangered species that could be
negatively impacted by spills or leaks if they were
located in areas in the vicinity of a pipeline.
Resources
protected by the
NHPA
Potential impacts to NHPA
resources would continue to occur.
However, since the rate of pipeline
incidents is small, these impacts
are expected to be minor.
However, based on the lack of
national data on pipelines in the
vicinity of historical structures, it is
impossible to estimate the extent of
potential impacts.
Since the Action alternative could reduce the
likelihood of hazardous liquid spills or natural gas
leaks related to pipeline incidents, it may result in a
minor benefit to historical and cultural resources that
could be negatively impacted by spills or leaks if
they were located in areas in the vicinity of a
pipeline. However, based on the lack of national
data on pipelines in the vicinity of historical
structures, it is impossible to estimate the extent of
potential benefits.
Wetlands
Potential impacts to wetlands
would continue to occur.
However, since the rate of pipeline
incidents is small, these impacts
are expected to be minor.
Since the Action alternative could reduce the
likelihood of hazardous liquid spills or natural gas
leaks related to pipeline incidents, it may result in a
minor benefit to wetlands that could be negatively
impacted by spills or leaks if they were located in
areas in the vicinity of a pipeline.
Section 4(f)
resources
Potential impacts to Section 4(f)
resources would continue to occur.
However, since the rate of pipeline
incidents is small, these impacts
are expected to be minor.
However, based on the lack of
national data on pipelines in the
vicinity of 4(f) resources, it is
impossible to estimate the extent of
potential impacts
Since the Action alternative could reduce the
likelihood of hazardous liquid spills or natural gas
leaks related to pipeline incidents, it may result in a
minor benefit to Section 4(f) resources that could be
negatively impacted by spills or leaks if they were
located in areas in the vicinity of a pipeline.
However, based on the lack of national data on
pipelines in the vicinity of 4(f) resources, it is
impossible to estimate the extent of potential
benefits.
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Final Environmental Assessment Standards for Direct Assessment of Gas and Hazardous Liquid Pipelines
Since the Action alternative affects only those operators that voluntarily use direct
assessment and because it largely involves processes of data collection and evaluation,
OPS has determined that it is unlikely to significantly affect the quality of the human
environment. The primary benefit of the Final Rule is to promote acceptable, reliable,
and uniform practices for using direct assessment to evaluate the threat of corrosion on
onshore gas and hazardous liquid pipelines. Such practices have the potential to reduce
incidents due to corrosion and to increase the public’s confidence in operators’ safety
programs. Thus, the benefits of the Action alternative will include a potential reduction
in the consequences of pipeline incidents (i.e., a reduction in the deaths, injuries, property
damage, and lost product directly attributable to pipeline incidents). It will also include
other savings, such as those related to increasing the operational life of pipe, and avoiding
economic consequences of accident-induced supply restrictions, legal costs, and reduced
emergency response costs.
A further benefit involves the Federal policy that encourages agencies to adopt consensus
standards that meet regulatory needs rather than develop new prescriptive Federal
regulations. Two consensus standards form the basis for activities required by the Final
Rule. Thus, the Final Rule would benefit the public by furthering the Federal policy on
use of consensus standards.
Additional benefits could result from the Action alternative that are difficult to quantify,
but which OPS believes to be significant. Foremost among these is improved public
confidence in the use of direct assessment to assure pipeline safety. Public confidence in
pipeline safety has been shaken by major incidents in recent years. These incidents have
generated concerns among public interest groups, the National Transportation Safety
Board, and the Congress, and have prompted OPS to issue several new regulations. The
public is concerned about the possibility of pipeline incidents that could cause them
harm. OPS believes that the Action Alternative and other agency activities will continue
to improve the confidence of the public living, working, and congregating near pipelines
that their safety is being assured. Furthermore, OPS expects that the Action alternative
may have a positive net benefit for pipeline operators, public safety, and the environment.
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Final Environmental Assessment Standards for Direct Assessment of Gas and Hazardous Liquid Pipelines
3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL
CONSEQUENCES
The alternatives considered in this document relate to direct assessment, a process of
managing the effects of external corrosion, internal corrosion, and stress-corrosion
cracking on ferrous pipelines. To assist OPS in understanding the potential
environmental impacts of the alternatives, this chapter describes the environmental
resources of the U.S. particular to the Action alternative. The resources that may be
affected by the alternatives are presented and described, along with a description of the
regulatory framework where relevant. This chapter also addresses the potential
environmental consequences associated with No Action (current conditions) and Action
Alternatives. In general, transportation affects a range of environmental resources
through the construction of the transportation network, the improvement of facilities and
infrastructure, and their operation.
Since the proposed regulation affects all regulated natural gas transmission pipelines and
gathering lines and regulated hazardous liquid and carbon dioxide pipelines, the affected
environment is the land area in the U.S. in which these pipelines are located. 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, and Other Special Areas of Consideration.
3.1 AFFECTED ENVIRONMENT
As the Action and No Action alternatives relate to the regulation of the safety of about
two million miles of gas and hazardous liquid pipelines, the actual physical environment
that may be affected includes the environmental and socioeconomic resources in the
vicinity of those pipelines.
3.1.1 Physical Environment Affected
The physical environment potentially affected by the Final Rule 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 covered by the Final Rule.
Because the pipelines subject to the Final Rule may contain hazardous materials, these
resources within the physical affected environment, as well as public health and safety,
may be affected by gas and hazardous pipeline incidents such as spills and leaks.
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Final Environmental Assessment Standards for Direct Assessment of Gas and Hazardous Liquid Pipelines
Depending on the size of the spill or gas leak, and the nature of the impact zone, the
environmental impacts vary from deaths and injuries to property and environmental
damage. Incidents on pipelines often 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 to the
physical environment are examined in Section 3.2.
3.2 ENVIRONMENTAL CONSEQUENCES
3.2.1 Public Health and Safety
No-Action Alternative
Under the No-Action Alternative, OPS would no additional regulations would be
established given that OPS has already issued regulations that prescribe standards for the
use of direct assessment. Therefore, the No Action Alternative would not change the
current and projected status of public health and safety.
Action Alternative
The Action alternative may make pipeline operations safer by helping to reduce the
number of incidents due to corrosion if operators choose to use direct assessment. In
addition, it may increase pipeline safety through the broader application of direct
assessment standards, potentially resulting in a reduction in fatalities and injuries
attributable to pipeline incidents. Therefore, the Action alternative may result in a net
reduction in the level of public health and safety impacts when compared to those under
the No Action alternative. It may also result in additional benefits, such as those related
to making future maintenance easier, with potential public health and safety benefits.
OPS cannot, however, say with certainty that implementing this Final Rule will avoid
fatalities or injuries, but it is possible. Therefore, it is possible that the Action Alternative
would result in a minor positive impact to public health and safety.
3.2.2 Hazardous Materials Transportation
OPS recognizes that pipeline incidents can result in fatalities and injuries, and lost gas,
hazardous liquids, and carbon dioxide. Such incidents can impact the physical
environment (i.e., air, water, biological, and historical resources) around the pipeline if
the material being transported within the pipelines leaks or spills into that environment.
No-Action Alternative
Under the No-Action Alternative, the rate of pipeline incidents will not change, as no
new regulations would be implemented. Therefore, the No Action Alternative would not
change the current and projected status of hazardous materials transportation. Potential
impacts to the natural and human environment would continue to occur.
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Action Alternative
The Action alternative may increase pipeline safety through the broader application of
direct assessment standards, potentially resulting in a reduction in fatalities and injuries
attributable to pipeline incidents. It is possible that the Action Alternative would result in
a reduction in the number and frequency of corrosion incidents on onshore gas and
hazardous liquid pipelines. Therefore, the Action alternative may result in a net
reduction in the level of impacts from hazardous materials transportation when compared
to those under the No Action alternative.
3.2.3 Socioeconomics
As part of the rulemaking action, the costs and benefits of the Final Rule have been
assessed. The economic analysis is summarized in the final Regulatory Evaluation (OPS
2004b). This final EA will, in analyzing the alternatives, analyze the socioeconomic
impact of the Action.
No-Action Alternative
Under the No-Action Alternative, no change in the costs resulting from pipeline incidents
would occur, as there would be no changes to the existing regulations.
Action Alternative
In its Final Rule, Standards for Direct Assessment of Gas and Hazardous Liquid
Pipelines, PHMSA is amending 49 CFR Part 192 by adding § 192.440 mandating direct
assessment standards for external, internal, and stress-crack corrosion for operators of gas
transmission pipelines, and amending 49 CFR Part 195 by adding § 195.588 mandating a
direct assessment standard for external corrosion for operators of hazardous liquid and
carbon dioxide pipelines. In the remainder of this section, the impacted industry will be
identified, and then the economic impact of the rule will be considered.
The Final Rule applies to direct assessments for external, internal, or stress corrosion
performed on gas transmission and gathering pipelines subject to Federal pipeline safety
regulation. It also applies to direct assessments for external corrosion performed on
hazardous liquid and carbon dioxide pipelines. The operators of natural gas transmission
and gathering pipelines are generally large firms, as are the operators of hazardous liquid
and carbon dioxide pipelines. Table 3-1 shows the salient characteristics of the pipelines
impacted by the Final Rule.
The Action alternative will impact natural gas transmission pipeline operators choosing
direct assessment as their approach for evaluating corrosion and hazardous liquid pipeline
operators choosing direct assessment as their approach for evaluating external corrosion.
The expected impact of direct assessment would be identification of present corrosion
risks and prevention of future risks. It may make pipeline operations safer by helping to
reduce the number of incidents due to corrosion and incident consequences when
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Standards for Direct Assessment of Gas and Hazardous Liquid Pipelines
corrosion incidents occur. The use of direct assessment by pipeline operators is
1 new approach, and its use at present is limited. Since the use of direct assessment i
oluntary. Other approaches for evaluating corrosion exist. Direct assessment is, in fact
voluntary, the Final Rule is not expected to have any measurable costs or benefits.
Table 3-1: 
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