U.S. DOT/PHMSA - Draft Environmental Assessment for TransCanada Pipelines Limited

Page 1PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION SPECIAL PERMIT DRAFT ENVIRONMENTAL ASSESSMENT SP Requester: TransCanada Pipelines Limited – ANR Pipeline Company1 PHMSA Docket No. PHMSA-2010-0192 Location: St. Martin Parish, Louisiana Document Date: December 7, 2010 Contact: Todd DelVecchio, P.E., Special Permit Coordinator/Environmental Assessment Engineer, 202-253-0814, todd.delvecchio@dot.gov I. Background This draft Environmental Assessment (EA) was prepared in accordance with DOT Order 5610.1C, the National Environmental Policy Act (NEPA), 42 USC §§ 4321 – 4375, and the Council on Environmental Quality regulations, 40 CFR §§ 1500-1508. NEPA requires that federal agencies analyze a proposed federal action to determine whether the action will have a significant impact on the human environment. PHMSA analyzes special permit requests for potential risks to public safety and the environment that could result from our decision to grant or deny the request. As part of this analysis, PHMSA looks at whether a special permit would impact the likelihood and consequences of a pipeline failure as compared to the status quo in the absence of the special permit. PHMSA may grant the special permit request, grant the request with additional conditions, or deny the request. We developed this assessment to determine the effects of our decision, if any, on the environment. Pursuant to 49 USC § 60118(c) and 49 CFR § 190.341, PHMSA may only grant special permit requests that are not inconsistent with pipeline safety. PHMSA will impose conditions in the special permit if we conclude they are necessary for safety, environmental protection, or are otherwise in the public interest. If PHMSA determines that a special permit would be inconsistent with pipeline safety or is not justified, the application will be denied. 1 ANR Pipeline Company is a subsidiary of the TransCanada Corporation.#

Page 2II. Purpose and Need On June 9, 2010, the Pipeline and Hazardous Materials Safety Administration (PHMSA) received a special permit petition from TransCanada Pipelines Limited – ANR Pipeline Company (TCPL-ANR) for relief from the requirements of 49 CFR 192.611(a) for a pipeline segment that experienced class location changes. The proposed special permit would apply to an area of the TCPL-ANR mainline, between Station 584+66 ft in St. Martin Parish, Louisiana (Milepost: 54.05) and Station 616+15 ft in St. Martin Parish, Louisiana (Milepost: 54.61). This represents 3149 ft of pipe which is the special permit segment. The special permit inspection area, a much broader area than the special permit segment, is defined as the pipeline that begins at Mile Post 29.02 at Valve Site 2 (V3 427+75 feet) on Loop 1-716 in Iberia Parish, Louisiana. The special permit inspection area extends through Valve Site 3 to Mile Post 43.03 where the ANR pipeline lateral naming convention changes from Loop 1-716 to Loop 2-716 in St. Martin Parish, Louisiana. The special permit inspection area continues along Loop 2-176 to Valve Site 4 at Mile Post 55.52 where the ANR pipeline lateral naming convention reverts back to Loop 1-176, also in St. Martin Parish, Louisiana. The special permit inspection area continues along Loop 1-176 and concludes at Valve Site 5 at Mile Post 70.78 (V5 00+00 feet) in St. Landry Parish, Louisiana. The total length of the special permit inspection area is approximately 41.76 miles and includes the special permit segment. This is graphically illustrated on the lower diagram within Figure 1. TCPL-ANR specifically requested a special permit (waiver) from the requirements of 49 CFR 192.611(a), which requires pressure reduction, pressure testing or pipe replacements to address class location changes when the pipeline is not commensurate with the new class location. The following is the text of 49 CFR 192.611(a). §192.611(a) Change in class location: Confirmation or revision of maximum allowable operating pressure. (a) If the hoop stress corresponding to the established maximum allowable operating pressure of a segment of pipeline is not commensurate with the present class location, and the segment is in satisfactory physical condition, the maximum allowable operating pressure of that segment of pipeline must be confirmed or revised according to one of the following requirements: (1) If the segment involved has been previously tested in place for a period of not less than 8 hours: 2#

Page 3(i) The maximum allowable operating pressure is 0.8 times the test pressure in Class 2 locations, 0.667 times the test pressure in Class 3 locations, or 0.555 times the test pressure in Class 4 locations. The corresponding hoop stress may not exceed 72 percent of the SMYS of the pipe in Class 2 locations, 60 percent of SMYS in Class 3 locations, or 50 percent of SMYS in Class 4 locations. (ii) The alternative maximum allowable operating pressure is 0.8 times the test pressure in Class 2 locations and 0.667 times the test pressure in Class 3 locations. For pipelines operating at alternative maximum allowable pressure per § 192.620, the corresponding hoop stress may not exceed 80 percent of the SMYS of the pipe in Class 2 locations and 67 percent of SMYS in Class 3 locations. (2) The maximum allowable operating pressure of the segment involved must be reduced so that the corresponding hoop stress is not more than that allowed by this part for new segments of pipelines in the existing class location. (3) The segment involved must be tested in accordance with the applicable requirements of Subpart J of this part, and its maximum allowable operating pressure must then be established according to the following criteria: (i) The maximum allowable operating pressure after the requalification test is 0.8 times the test pressure for Class 2 locations, 0.667 times the test pressure for Class 3 locations, and 0.555 times the test pressure for Class 4 locations. (ii) The corresponding hoop stress may not exceed 72 percent of the SMYS of the pipe in Class 2 locations, 60 percent of SMYS in Class 3 locations, or 50 percent of SMYS in Class 4 locations. (iii) For pipeline operating at an alternative maximum allowable operating pressure per § 192.620, the alternative maximum allowable operating pressure after the qualification test is 0.8 times the test pressure for Class 2 locations and 0.667 times the test pressure for Class 3 locations. The corresponding hoop stress may not exceed 80 percent of the SMYS of the pipe in Class 2 locations and 67 percent of SMYS in Class 3 locations. If granted, this special permit would allow TCPL-ANR to continue to operate the special permit segment at its current maximum allowable operating pressure (MAOP) of 1050 psig. 3#

Page 4III. Site Description The proposed special permit would apply to an area of the ANR lateral loop, between Station 584+66 ft in St. Martin Parish, Louisiana (Milepost: 54.02) and Station 616+15 ft in St. Martin Parish, Louisiana (Milepost: 54.61). TCPL-ANR provided a description of the environmental resources in the vicinity of the right-of-way of the special permit segments. TCPL-ANR’s description is included as Appendix A. IV. Alternatives Considered and Environmental Impacts of Each Alternative Alternative 1: Grant the Request with Conditions Under this alternative, PHMSA would grant a special permit to TCPL_ANR to continue to operate the special permit segment at its current maximum allowable operating pressure (MAOP) of 1050 psig. If this special permit is issued it would be conditioned upon measures that PHMSA believes are in the public interest and would reduce the risks associated with allowing TCPL_ANR to operate under the special permit. Potential conditions are evaluated for environmental impacts in the Special Permit Conditions Section of this EA. i. Potential Safety Risks Resulting Grant of the Special Permit. The safety risk with respect to this request for a special permit focuses on the integrity of the pipeline with respect to the increased population in the event of a catastrophic failure of the pipeline in this special permit segment. Though the potential impact radius (PIR) has not increased, the effects on the increased population around the pipe must be addressed. A PIR is a measurement in feet to which an area could be affected if a explosion failure were to occur. The measurement is from the centerline of the pipeline out in every direction. The current PIR for this pipeline is calculated using a PIR calculation from ASME B318S Managing System Integrity of Gas Pipelines, version 2004, section 3 consequences, incorporated by reference by PHMSA 192 regulations. The formula and resulting calculation is as follows: (see appendix B for a more in depth discussion of PIR). r = radius of the impact circle (ft), otherwise known as the PIR d = outside diameter of the pipeline (in); (30”) p = pipeline segment’s maximum allowable operating pressure (MAOP), psig (1050psig) Note: the coefficient for natural gas is 0.69 4#

Page 5, therefore r = 0.69 * 30” * square root of 1050psig = 670.8feet In order to comply with 49 CFR § 192.611, approximately 0.06 miles of pipe would require replacement to address this class location change. This replacement pipe would provide additional protection for only 28 single family dwellings. In its request, TCPL- ANR stated that the implementation of enhanced integrity management in lieu of pressure reduction, hydrostatic testing or pipe replacement provides a superior level of safety than that offered by the requirements of 49 CFR Part 192.611. By implementing the provisions of this special permit petition, including performing in-line inspection, additional safety benefit will be provided to approximately 41.76 miles of pipeline which encompasses approximately 464 single family dwellings and 5 multiple occupancy buildings. Furthermore, adhering to 49 CFR Part 192 Subpart O requirements for re- assessment and implementing additional preventive and mitigative measures described in this petition will provide ongoing safety benefits to this area. TCPL-ANR would incur significant costs to replace the pipe in the class location change area. More important than the total cost is the effectiveness of the expenditures and their impact on pipeline safety. In the special permit application, TCPL-ANR has already committed to inspect and provide enhanced integrity assessments (including ongoing and future work) for approximately 41.76 miles of pipeline. If the pipe in the special permit segment were replaced, additional protection would only be provided for 0.06 miles of pipeline. ii. Potential Environmental Risks Resulting From a Grant of the Special Permit. As with any class location waiver when one is considering operating a pipeline above the pressures allowed within the originally approved class designation, the risk of environmental impacts should be examined and addressed as they relate to humans, animals and the environment. This analysis focuses on the following categories: Nearby Population: There appears to be little impact to land use by this alternative since all work under this permit will occur within the existing ROW. The PIR has not increased on account of the change in population density. The increase in population density is minimal and the increase can be mitigated with conditions. For instance, increased surveillance and detailed analysis and remediation of the existing pipeline could reduce the risk associated with failure of the pipeline. 5#

Page 6Surface Waters: Any negative effect to surface waters due to an increased risk of a pipeline failure would be temporary in nature and do not pose a long-term problem to such areas. However if this special permit is granted, it is likely that TCPL_ANR would be required to investigate these areas further and work with local authorities to address any abnormalities. Potable Water Sources: TCPL_ANR identified no potable water areas affected by the special permit segment. A confirmation of this information will be addressed in the special permit if granted. Soils and Vegetation: Any areas of excavation would be limited and confined to the existing ROW and filling of any excavation will be done with in-situ soils. Wildlife: Risks to existing habitat within the ROW are limited to this ROW. Any catastrophic failure would negatively impact wildlife within the PIR however these risks could be lessened by proposed conditions. Geologic Hazards: There appears to be no impact to geologic hazards. Socioeconomic Impacts: From the data collected TCPL_ANR appears to have no negative affect to socioeconomic impacts in general or on Native Americans, due to the nature of the work of this permit limited to its ROW. Any other socioeconomic impacts such as temporary traffic management plans due to the ROW intersecting with roadways shall be handled with local and state authorities when encountered to impact traffic on any state or local roadway. iii. Special Permit Conditions If a special permit is granted, PHMSA would place conditions in the permit that would require TCPL_ANR to comply with numerous conditions designed to address safety and environmental issues that are in the public interest. Most Class Location special permits require operators to locate and remediate certain pipeline safety threats, including, but not limited to, threats associated with: pipe coating quality, cathodic protection, third party damage, weld seam and girth weld integrity, pipe steel anomalies, and material and structures either along or near the pipeline that could cause the cathodic protection system to be ineffective. If the permit application is granted, conditions may include requirements that TCPL_ANR perform the following work: 6#

Page 7Conduct a close interval survey to determine the effectiveness of the cathodic protection system within the special permit segments. Remediate all areas with inadequate cathodic protection. Conduct a coating survey to determine the quality of the pipe coating. Remediate ineffective coating areas in the special permit segments. Conduct stress corrosion cracking surveys on the pipeline in the special permit segments to ensure that the pipe steel is not cracking due to the effects of high and near neutral pH SCC. Incorporate the latest methods of damage prevention, such as the best practices of the Common Ground Alliance (CGA), into the damage prevention program in the special permit segments. Identify, control and mitigated any interference currents from electric transmission lines and other interfering structures in the special permit segments. Conduct surveys and install grounding systems where required. Analyze pipeline field coated girth welds that could have shielding coatings that could cause corrosion of the pipe steel in the special permit segments. Expose and evaluate corrosion indications on shielding or unknown coatings as indicated from in-line inspection logs. Repair anomalies and dents on the pipeline according to the special permit repair criteria for special permit segments. Clear all shorted casing (either metallic or electrolytic) at all road crossings and railroad crossings in the special permit segments. Perform periodic close interval surveys and in-line inspection surveys on the special permit segments at the applicable reassessment intervals. In its application, TCPL_ANR has also proposed to voluntarily perform additional work including specific alternative integrity management activities to mitigate the integrity threats applicable to this pipeline segment. PHMSA will consider and evaluate whether to include these conditions in the special permit. 1. The special permit area will be subject to the requirements of TCPL’s Integrity Management Program and 49 CFR 192, Subpart O. TCPL-ANR maintains a comprehensive corrosion control program comprising annual test lead surveys and diagnostic testing. This is supplemented with high-resolution in-line inspection surveys (magnetic flux leakage and geometry). 2. TCPL-ANR will perform a depth of cover survey in the special permit area within one year of receiving the special permit. TCPL-ANR will review the survey results and design and implement appropriate mitigation. 3. A CIS in the inspection area and DCVG survey in the special permit area will be conducted within one year of being granted the special permit. 7#

Page 84. During excavations, TCPL-ANR will confirm the cathodic protection potential of the pipelines; measure depth of cover; examine the coating; examine the pipe for orientation of the seam, condition of the longitudinal seam, and visually inspect for corrosion pitting or crack-like features. Furthermore, the pipe with disbonded coating shall be examined for the presence of stress corrosion cracking. 5. ANR Line 2-716 mainline valves within the inspection area are equipped with valve actuators. Each actuator works on a rate of pressure drop sensor to trigger the automatic closure in the event of a rupture. 6. These activities and devices will provide a degree of risk reduction equivalent to and greater than that provided by the replacement of pipeline in the affected area. 7. TCPL-ANR anticipates PHMSA may issue additional conditions for the special permit area when the special permit is granted and will comply with the applicable conditions. Enhancements to the operations and maintenance requirements under the proposed special permit will reduce the overall risk of incident occurrence. Since the overall risk of a pipeline failure will be reduced, there is an improvement in human safety if the special permit is granted. The overall environmental impacts would remain the same or be reduced if the proposed special permit is granted with conditions since implementing the special permit would require TCPL-ANR to perform specific integrity assessments and take specific actions to remediate pipeline integrity concerns. Under this alternative, there is the potential that remediation efforts will affect public infrastructure or environmentally sensitive areas, but this cannot be determined until the integrity assessments have been performed. TCPL-ANR would be required to comply with all laws and regulations when performing any of the activities required by the proposed special permit, including consultations with appropriate environmental agencies, procuring all required environmental permits and implementing all appropriate environmental mitigation measures. Alternative 2: Reduce the MAOP If PHMSA denied the request for a special permit, TCPL-ANR would be required to reduce the MAOP for the special permit segment from its current maximum allowable operating pressure (“MAOP”) of 1050 psig to a MAOP of 875 psig, which would reduce the capacity of this portion of the TCPL- ANR pipeline system below its Federal Energy Regulatory Commission (“FERC”) certificated capacity. Certainly, this alternative creates less of an environmental concern than replacing the pipe eliminating the need for excavation and construction but under this alternative, TCPL-ANR would be unable to deliver its contractual commitment to its customers. 8#

Page 9Alternative 3: Deny the Request PHMSA could deny the request for a special permit which would require TCPL-ANR to replace the pipe in the class location change area. If the special permit segment were replaced, the area would incur increased environmental impacts due to excavation, post- construction compaction of soils, and an impacted right-of-way during construction. Any excavation through a surface water would also be negatively impacted and need remediation. There are often significant disturbances to surface water bodies such as wetlands, streams and other water surface features during construction of a pipeline. These disturbances are not limited to trenching large excavation areas, building temporary construction staging areas, and changing the topology of the right of way , etc. All of which can be mitigated however natural features and disturbances to the ecology of the local environment in most cases takes time to recover completely even with mitigation. Furthermore wildlife can be temporarily impacted during construction activities. V. Request for Comment PHMSA is soliciting public comment on the potential environmental impacts of this special permit application by posting notice of the availability of this Draft EA in the Federal Register. At the conclusion of the public comment period, we will consider any comments received and finalize the EA to either include a finding of no significant impact (FONSI) or take other action in accordance with NEPA. VI. List of Preparers Todd DelVecchio, P.E., PHMSA, USDOT Steve Nanney, PHMSA, USDOT VII. Agencies and Persons Consulted PHMSA considered environmental information and documents submitted by TCPL- ANR. 9#

Page 10Figure 1: Special Permit Area Stations v';:1 ti.,,! 1 ,1 L""""'Y ~ "'''' o .. on_ SJ W.1- >- ..... ~, "n" s:. " ... .., J x ~; .. . .~ ,:" 14 , "" '<" un, " . ' ~ n J , ~,,, , ro " " ~ S - • • 0 0 " • , • " " , " " " " " " , , , 3.14 9 n , , , , , V5 V . V3 V2 0 , 0 I : ] 0 , 0 .c .c ." m ~ u'> " " - " <O m,," m • • <E> ........ 11 ;: J. N;; • - 0 • • -ii:l!zg • • "0 , -~ - . [l! • .:J • • • ., -::J - .:J ~ ... ;t " " ~l ... l . ~ --------------.--- line 2-716 --------.-----.-.---- ~ . -- l ine 1- 7 16 ~ .. Line 1 -7 16 Line -7 16 V5 00+00 " linb 1-71 6 V 4.21+75 " 41.76 m! Inspection Area 16. 17 mi Sp,tial P,rmit Alta 25 mi •#

Page 11Figure 2: Special Permit Area Map ) \ , , , , i r , r.j /' r I \" - _I , t \ -' I '-, I J- ~, L~ . NIR ~Itf .. Loop 1·116 SptciII P ...... AI ... _ V4 58.406$ftlO V4 "6+15 11 ~ IVN _ Line ' .lllVSo.oo It 1OV34n.n It ., ' , . J -- • - . .. "... • •• ' TO 11#

Page 12Appendix A The following is a description of the right-of-way in the vicinity of the special permit segments that was obtained from an environment questionnaire from TCPL-ANR. Nearby Population: Figure 2, attached, is a state map showing the general location of the special permit segment. There are 28 single family dwellings in the vicinity of the special permit segment. Surface Waters: There is a stream located within the special permit segment located at Valve Section 4, station 593+98 ft (Milepost: 54.20). There are wetlands located from Valve Section 4, Station 584+66 ft (Milepost: 54.02) to Valve Section 4, Station 586+92 ft (Milepost: 54.06). There are also wetlands located from Valve Section 4, Station 612+95 ft (Milepost: 54.55) to Valve Section 4, Station 616+15 ft (Milepost: 54.61). Potable Water Sources: There are no known drinking aquifers in the vicinity of the proposed special permit segment. Soils and Vegetation: Soils at the special permit segment of Line 2-716 include Dundee series situated on 0% to 1% slopes, Tensas series situated on 0% to 1% slopes, and Loreauville series situated on 0% to 1% slopes. The vegetation in the vicinity of the segment on 2-716 is mainly agriculture fields and forested wetland. Wildlife: United States Fish and Wildlife Service (USFWS) Threatened and Endangered Species in St. Martin Parish, Louisiana includes the Pallid Sturgeon (Scaphirhynchus albus). The special permit area does not have the appropriate conditions for the Pallid Sturgeon. Geologic Hazards A Phase I Geohazards Assessment study has been conducted on parts of the TCPL-ANR pipeline system. The inspection area is included in the study. Of the hazards considered, there are no landslide hazards, potential low2 liquefaction and low3 shaking hazard for seismic activity (moderate4 fault hazard due to Gulf Coast Normal faults), potential low5 hazard - Karst area for subsidence hazard, potential moderate6 to high7 collapsible and 2 Areas of alluvial or lacustrine soil meeting one of the following criteria: < 0.1 g peak ground acceleration or groundwater deeper than about 9 meters. 3 < 0.15 g peak ground acceleration 4 Geomorphic lineaments observed on aerial photographs, or during aerial reconnaissance, that are within active tectonic regions; areas mapped as “Gulf Coast normal faults” in the Quaternary Fault and Fold database 5 Areas mapped as being underlain by potentially karstic or pseudokarstic formations (e.g. limestone or gypsum); areas between 500 to 2,000 meters of mapped salt dome center 6 Linear Extensibility Percent (shrink-swell potential) between 3 and 6 7 Linear Extensibility Percent (shrink-swell potential) greater than 6#

Page 13expansive soil hazard and potential moderate8 to high9 risk of meteorological hazard within the inspection area. Although there is a potential for geotechnical activity, there is no immediate risk to the integrity of the pipeline within the inspection area. Socioeconomics and Native Americans: There will be no socioeconomic impacts or special impacts on Native Americans. 8 Areas with greater than 0.25 tornado days per year 9 Offshore areas or areas within 20 miles of coastline of Gulf of Mexico (hurricanes) 13#

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