PHMSA Draft Environmental Assessment

Page 1PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION SPECIAL PERMIT DRAFT ENVIRONMENTAL ASSESSMENT Special Permit Requester: Boardwalk Pipeline Partners, operator of Gulf South Pipeline Company, LP PHMSA Docket No.: PHMSA-2010-0124 Location of Subject Facilities: Mobile County, Alabama Document Date: September 16, 2010 Contacts: Todd DelVecchio, P.E., Special Permits Coordinator/Environmental Assessment Engineer, 202-253-0814, todd.delvecchio@dot.gov I. Background The National Environmental Policy Act (NEPA), 42 USC §§ 4321 – 4375, Council on Environmental Quality regulations, 40 CFR §§ 1500-1508, and DOT Order 5610.1C, require that PHMSA analyze a proposed 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 evaluates whether a special permit would impact the likelihood of a pipeline failure as compared to the environmental status quo in the absence of the special permit. We will be denying or granting Gulf South Pipeline Company’s special permit request because based on our analysis of whether it would be or would not be consistent with pipeline safety. We developed this assessment to determine the effects of our action on the environment. 1#

Page 2II. Purpose and Need On March 24, 2010, PHMSA received a request for a special permit from Boardwalk Pipeline Partners, operator of Gulf South Pipeline Company (GSPC) for relief from the requirements of 49 C.F.R. § 192.611(a), concerning maximum allowable operating pressure (MAOP) limitations for pipeline segments located in Mobile, Alabama. The class locations along this pipeline have changed from an original Class 1 to Class 3 locations because of an increase in the population within the original class location of the pipeline. Section 192.611(a) would require GSPC to take one or more actions to continue operating the affected segments after a class location change, including a reduction in operating pressure, or the installation of new pipe. GSPC would like to continue operating the affected segments at their current MAOPs, despite the fact that those segments have experienced changes in Class Location. Special Permit Segment(s) Location Information: Below is a summary of the special permit segments which are all located within Mobile County, Alabama. Station Number 318+78 to Station Number 322+ 14 (336 feet) Station Number 435+63 to Station Number 454+65 (1,904 feet) Station Number 455+85 to Station Number 461+08 (523 feet) Note: In addition to the Special Permit Segments, GPSC has identified a "Special Permit Inspection Area" that extends 220 yards outward from the centerlines of the pipeline for a total of approximately 23.97 miles along GPSC 's TPL 880. Specifically, the following would constitute the Inspection Area: TPL 880 Special Permit Inspection Area: Station 0+00 to Station 1201+68 (23.97 miles) This inspection area includes all of the special permit segments proposed under this permit. See appendix A for maps of this area. Regulation Information: GSPC requests the waiving of compliance from the requirements of 49 CFR § 192.611 (a) which requires pressure reduction 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) (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: 2#

Page 3(1) If the segment involved has been previously tested in place for a period of not less than 8 hours: (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 requalification 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. (b) The maximum allowable operating pressure confirmed or revised in accordance with this section, may not exceed the maximum allowable operating pressure established before the confirmation or revision. (c) Confirmation or revision of the maximum allowable operating pressure that is required as a result of a study under § 192.609 must be completed within 24 months of the change in class location. Pressure reduction under paragraph (a) (1) or (2) of this section within the 24-month period does not preclude establishing a maximum allowable operating pressure under paragraph (a)(3) of § 192.611. Justification Discussion: GPSC submitted to PHMSA during the application process several justifications for its seeking of this special permit which are bulleted below: Pipe replacement, however, is costly, disrupts service and the environment, and provides safety benefits only to those located near the line experiencing the class location change. GPSC estimates that the cost of replacing the three pipe segments on TPL 880, which total 2,763 feet, to be $3,233,422. By contrast, the cost for Direct Current Voltage Gradient (DCVG) Testing and Calibration Digs in the Special Permit Segments is estimated to cost $40,000. In summary, the costs of all activities indicated in the Special Permit are approximately $40,000. 3#

Page 4By avoiding pipe excavation and replacement will minimize costs to the operator, avoids delivery interruptions and supply shortages, and averts environmental disturbance. Implementing enhanced inspection and assessment practices throughout the Inspection Area, in lieu of replacing small sections of pipe experiencing the class location change, extend pipeline safety benefits to a much greater area. 4#

Page 5III. Site Description To begin a map of the special permit pipeline segments are attached in Appendix A of this document. The site description will now be described in the following areas, below with a description of the area in each. Class Location Information: GSPC stated in their application that there are approximately 45 residences and 2 businesses within the special permit segment areas. The number of people affected is approximately 153. This area has gone through a change in population density which has increased the class designation to class 3 locations. Surface Waters: The following text to describe this sub-section was directly taken from GSPC’s application: The first segment is approximately 336 feet in length and does not cross any wetlands or bodies of water, including lakes. This pipeline special permit segment is located within an upland forested area, where the elevation dips south, southeast to an unnamed tributary of Hammer Creek. The pipeline right-of-way in this area is maintained in an herbaceous state and is abutted on both sides by upland forest. The second special permit segment is approximately 1,904 feet in length and crosses one riparian wetland area associated with one water body. The remainder of this section is within a residential area and land mowed and maintained as pasture. No lakes are crossed or otherwise impacted by this pipeline segment. The wetland and water body are associated with Fowl River and its basin. The pipeline right-of-way is currently maintained in an herbaceous state. The small wetland area crossed by this special permit segment is approximately 412 feet in length. The third special permit segment is approximately 523 feet in length and crosses no wetlands or water bodies, including lakes. The majority of this special permit segment is located within a mowed and maintained pasture. This special permit segment slopes gradually to the south, southeast to the Fowl River basin. This pipeline segment is abutted to the west by a thin tree line. Potable (Drinking) Water Sources: The following text to describe this sub-section was directly taken from GSPC’s application: 5#

Page 6The Sand and Gravel Aquifer underlies an area of about 6,500 square miles in southwestern Alabama including both locations of the Project. All of the subsequent information concerning the Sand and Gravel Aquifer was supplied by the United States Environmental Protection Agency (USEP A, 2006). The aquifer supplies most of the water used by small communities in the rural parts of Mobile County, Alabama; however the city of Mobile is supplied by surface water. Approximately 150 million gallons per day (mgd) was withdrawn from the Sand and Gravel Aquifer by all uses during 1985. Mobile County accounted for approximately 20 percent of the total usage Sand and Gravel Aquifer. The Sand and Gravel Aquifer consists largely of inter-bedded layers of sand and gravel. Clay beds and lenses are common in the aquifer and form local confining beds. Movement of groundwater is generally coastward. The aquifer ranges in age from middle Miocene to Holocene that were mostly deposited in a deltaic environment. Water in the Sand and Gravel Aquifer is suitable for drinking in most areas. GSPC does not anticipate any impacts to domestic water wells because no wells are believed to exist on or close to the project area. Based on a review of the Region 4 Sole Source Aquifer map, there are no EPA-designated sole source aquifers in Alabama. Soils and Vegetation: The following text to describe this sub-section was directly taken from GSPC’s application: The Special Permit Segments are located in stable soil. The terrain throughout the entire Special Permit Segments and Inspection Areas is a gradually sloping land and the soils are stable, falling into the "probable acceptance" category. The area is not prone to significant earthquakes, risk of flooding, subsidence or landslides. Attachment B shows the proximity of dwellings and other populated areas to the pipeline right of way and the location of road crossings. Wildlife: The following text to describe this sub-section was directly taken from GSPC’s application: The primary wildlife habitat occurring within, and in the vicinity of the Special Permit Inspection and Area includes agricultural and residential land, and forested areas. These land types may provide habitat for wildlife species including hawks, white tailed deer, raccoons, bobcats, coyotes, migratory bird species, and turkeys. Project impacts on wildlife are expected to be minor because similar vegetation cover, forage and land types are relatively abundant in the project areas. Further, issuance of this Permit will not result in modifications to any habitat, impacts to wetland or water bodies, and no effects on fishery resources or essential fish habitat (EFH). 6#

Page 7No areas within these pipeline special permit segments are designated as sensitive wildlife habitat. The proposed special permit segments doe not cross any land administered by federal, state, or local agencies, or nongovernmental organizations that could provide sensitive wildlife habitat. No lands enrolled in the Conservation Reserve Program (CRP) or the Wetland Reserve Program (WRP), both administered by the Natural Resource Conservation Service (NRCS), will be affected by the special permit segments. Geologic Hazards: The following text to describe this sub-section was directly taken from GSPC’s application: Although earthquakes occur in Alabama, many are too small to be felt by people and most are unlikely to do serious damage (Alabama Geological Survey, 1999). The great majority of earthquakes occur in the northern half of Alabama, and based on historical records through 2003, none have occurred in Mobile County. The largest earthquake reported in Alabama occurred in October 1916 in northern Shelby County. This earthquake had an intensity of VII on the Modified Mercalli Scale. The largest instrumentally recorded earthquake was a Richter magnitude 4.9 on October 24, 1997 in Escambia County. There are no surface faults mapped in Mobile County (Geological Survey of Alabama, 1971). Therefore, based on the relatively low historic seismic activity and the low level of ground motion predicted for the project area, it is unlikely that a damaging earthquake will occur in any of the pipeline segments. No soils with a severe erosion potential were identified within the project area. All of the soil series impacted by the Project exhibit slight erosion potential. According to the soil survey reports, there are no indications of rock within the upper five feet of ground surface. Other geological hazards include landslides, karst topography, subsidence and shallow bedrock. GSPC is not aware of any shallow bedrock or karst topography in the vicinity of this Permit, nor has it documented landslides or ground subsidence in the vicinity of the special permit segments. Socioeconomic Impacts: The following text to describe this sub-section was directly taken from GSPC’s application: All special permit segments activities will be conducted within the boundaries of the previously disturbed pipeline right-of-way. On an annual basis GSPC submits a written request to the Alabama SHPO for categorical exclusion for activities to be undertaken within its existing, previously disturbed ROW to ensure compliance with the National Historic Preservation Act of 1966, as amended (NHPA). Section 106 requires federal agencies or their applicants to take into account the effects of their undertakings on historic structural and archaeological properties. The Alabama SHPO concurred with its categorical 7#

Page 8exclusion for work within existing ROW and stated that "no known historic properties will be affected by this undertaking." The proposed work associated with this Special Permit will have no impact on Native Americans or any land owned or otherwise administered by Native American tribes. 8#

Page 9IV. Alternatives Considered and Environmental Impacts of Each Alternative Alternative 1: Grant the Request with Conditions. Under this alternative, we would grant the special permit with certain conditions designed to reduce the risks associated with permitting GSPC to continue to operate its pipeline segments at the existing MAOP in Class 3 locations. GSPC would be required to take action to reduce risks associated with pipe coating, cathodic protection, damage prevention, and weld seam and girth weld integrity. As PHMSA has done in past class location special permits, we would condition a special permit on GSPC performing close interval surveys to determine the effectiveness of its cathodic protection systems; performing a pipeline coating survey and repairing damage; performing stress corrosion cracking surveys; improving damage prevention programs; performing engineering analysis of longitudinal pipe seams and remediating any threats; performing pipeline inspections with instrumented in-line inspection (ILI) tools and repairing any anomalies, etc. Human Safety Factors Analysis: The changing of a class location does come with some inherent human safety factors however; they can be mitigated with increased pipeline integrity procedures. This will aid to the longevity and overall safety of the pipeline. With class location waivers the applicant is seeking to get a waiver from PHMSA’s regulations which limit the pressures based on inhabitants within the pipeline area. Even though the applicant does not have direct control of such development which may change the class location of the pipeline the applicant is still responsible for making sure that the class location regulations are met at all times and were they cannot logically and conditionally they will go through a special permit process such as this. To the increased pipeline integrity measures proposed by GSPC and normally imposed by PHMSA during a class location special permit. There appears to be enough of a factor of safety to logically see no or very little change to the human safety risks to this request. Environmental Aspects Analysis: By granting this request and stepping up pipeline integrity measures as identified in the conditions sections there appears to be very little impacts or risks to the environment within the special permit areas. Below is an examination of each environment area from the site description in terms of this alternative. Land Use: There appears to be no greater risk to land use for no planned increase development of the affected area is know at the current time; furthermore with the GSPC offered conditions an increased factor of safety for land use will be accomplished with 9#

Page 10the inspection of the entire pipeline corridor instead of just the affected special permit segments. In this instance, the special permit conditions would require GSPC to inspect and provide enhanced integrity assessments on 23.97 miles of pipeline. These measures would result in safety benefits to more than 376 single family dwellings and18 businesses. Wetlands: There will be no greater risk to wetlands than a no-build alternative for there will be minimal if no excavations within wetland foreseen. If however there are excavations within a wetland or other environmentally sensitive area applicable Federal and State laws and agencies shall be contacted and coordinated with to ensure proper excavation permitting. Drinking Water: GSPC identified no areas of this special permit in the ROW of this pipeline. 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. Further permitting of soil conservation are to be handled at a federal/state/local authority. Wildlife Habitats: From the data collected as part of this permit it appears that are no sensitive wildlife areas within the ROW. Areas with wildlife however may be affected temporarily as testing and inspection processes take place. Other risks to existing habitat within the ROW are limited to this ROW. Any catastrophic failure would negatively impact wildlife within the potential impact radius (PIR) however as stated in other areas here these risks appear to be lessened with the proposed initial conditions. Cultural Recourses: There were no significant cultural resource impacts to this permit. Socioeconomic Impacts: There were no significant cultural resource impacts to this permit. Typical PHMSA Special Permit Conditions In summary, these conditions may include requirements that GSPC perform the following work which are typical with this type of request for a special permit: Subsequent re-inspections will be performed using in-line inspection at intervals as specified by 49 CFR Part 192, Subpart O reassessment intervals. 10#

Page 11Any anomalies detected during these in-line inspections will be remedied in accordance with 49 CFR Part 192, Subpart O, GSPC Integrity Management Program and the conditions of the special permit. Close interval survey (CIS) and direct current voltage gradient (DCVG) will be performed on the special permit pipeline segments within the proposed inspection area in order to ensure cathodic protection (CP) is at acceptable levels along the pipeline. Areas of low CP potentials will be remedied in accordance with the special permit conditions. A depth of cover survey will be performed within the special permit segment utilizing electronic depth equipment, or equivalent. Remedial actions and/or additional preventive and mitigative measures will be implemented in the special permit segment that do not meet minimum cover criteria specified by § 192.327. Stress corrosion cracking direct assessment will be performed on the special permit segments within the proposed special permit area. GSPC proposes to perform monthly aerial patrols, weather permitting, in the inspection area containing the special permit segment. Directly above is a list of typical conditions associated with this type of permit a full set of conditions can be found within the finalized special permit in a section call the Special Permit Analysis and Findings. GSPC Offered Conditions GSPC has offered several conditions to help mitigate risk associated with this permit. Below is a list of the condition(s) and a brief analysis of them. Monthly aerial or foot patrols, weather permitting, to observe surface conditions on and adjacent to the pipeline right-of-way for indication of leaks, third party construction , exposed pipe, erosion or other facts that affect the safety and operation of the pipeline. An increased inspection area of the entire pipeline instead of only focusing on the pipeline segments affected by this permit. The frequency of this surveillance of the pipeline does exceed the requirement under 49 CRF Part 192. Also the breath of which GSPC chooses to include in their monthly patrols will aid the integrity of the pipeline. 11#

Page 12All conditions listed above are in the direct interest to the public safety of the special permit segment area. Each condition exceeds what is normally required as part of PHMSA’s regulations and enforces a greater level of safety to both the public and the environment. Lastly the implementation of these conditions would be a net positive when compared to using current regulations. Alternative 2: Deny the Request. Under this alternative, we would deny GSPC’s special permit request. GSPC would not be granted a waiver of compliance with the requirements of 192.611a, and would continue to be required to comply with existing regulations. Potential Safety Risks of Denial If the permit was denied, pipeline construction and replacement of the special permit pipeline segments would need to be accomplished. There would be no risk to this option beyond what risks are posed by following PHMSA regulations. However when one can exceed PHMSA’s regulations verses follow them it does pose a greater risk even though the factor of safety is already met. Potential Environmental Impacts of Denial The denial of the permit and construction of new pipeline would pose a greater risk to the environment and more steps would need to be taken to ensure that the construction would remediate any environmental disturbance or damage. 12#

Page 13V. Request for Comments PHMSA will carefully analyze the safety and environmental risks associated with the request special permit. To assist PHMSA in its analysis, PHMSA requests comments from the public on this Draft Environmental Assessment including information relevant to whether the special permit would have any significant environmental impacts, and if so, whether any conditions could be imposed to mitigate such impact. VI. List of Preparers Todd DelVecchio, P.E., PMP, PHMSA, USDOT Jim Curry, PHMSA, USDOT Brianne Kurdock, PHMSA, USDOT VII. Agencies and Persons Consulted No other agencies were consulted, but PHMSA considered environmental information and documents submitted by APE. 13#

Page 14Appendix A Figure 1 "PRELIMINARY NOT FOR CONSTRUCTION" CLS 1 TO 3 TO STA 322+00 FROM STA 318+78 CLS 2 TO 3 FROM STA 322+00 TO STA 322+14 FRÓM STA 318+78 TO STA 322+14 INDEX 880 Proposed Special Permit Segment Legend - REPLACEMENT GULF SOUTH TRANSMISSION PIPELINE HCA STRUCTERES GIS CLASS CLASS - HOHWAYS STREETS 1" = 200' MAP M1 TPL 880 GULF SOUTH 14#

Page 15Appendix A Continued Figure 2 "PRELIMINARY NOT FOR CONSTRUCTION CLS 1 TO 3 TO STA 461+08 FROM STA 460+70 INDEX 880 CLS 2 TO 3 Proposed Special Permit Segment FROM STA 455+85 FROM STA 455+85 TO STA 461+08 TO STA 460+70 CLS 2 TO 3 INDEX 880 FROM STA 435+63 TO STA 454+65 Proposed Special Permit Segment FROM STA 420+12 TO STA 458+52 HCA IN WAIVER Legend A NPACEMENT GIS CLAS: MAP M2 1" = 200° TPL 880 BOO GULF SOUTH 15#