{"operation":"document","citation":"0900006480e90e4d","title":"PHMSA Draft Environmental Assessment","source_type":"rulemaking","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":null,"effective_on":null,"summary":"The document describes a PHMSA NEPA analysis of GSPC’s March 24, 2010 special permit request to waive compliance with 49 C.F.R. § 192.611(a) for specified pipeline segments in Mobile County, Alabama, summarizes site conditions and potential environmental and safety considerations, compares two alternatives (grant with conditions vs. denial), and requests public comment. The assessment lists proposed inspection and integrity conditions that PHMSA would consider if granting a permit, presents GSPC justifications (including cost comparisons), and identifies the special permit segments and an associated 23.97-mile inspection area. The scope is limited to the information and analyses contained in the Draft EA and supporting application materials; the summary below cites only text explicitly provided in the supplied passages.","machine_formats":{"json":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e90e4d.json","markdown":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e90e4d.md"},"app_url":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e90e4d","source_url":"https://downloads.regulations.gov/PHMSA-2010-0124-0008/attachment_1.pdf","body":"<<<PAGE 1>>>\n\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nSPECIAL PERMIT\nDRAFT ENVIRONMENTAL ASSESSMENT\nSpecial Permit Requester: Boardwalk Pipeline Partners, operator of\nGulf South Pipeline Company, LP\nPHMSA Docket No.: PHMSA-2010-0124\nLocation of Subject Facilities: Mobile County, Alabama\nDocument Date: September 16, 2010\nContacts: Todd DelVecchio, P.E., Special Permits Coordinator/Environmental Assessment\nEngineer, 202-253-0814, todd.delvecchio@dot.gov\nI. Background\nThe National Environmental Policy Act (NEPA), 42 USC §§ 4321 – 4375, Council on\nEnvironmental Quality regulations, 40 CFR §§ 1500-1508, and DOT Order 5610.1C, require that\nPHMSA analyze a proposed action to determine whether the action will have a significant\nimpact on the human environment. PHMSA analyzes special permit requests for potential risks\nto public safety and the environment that could result from our decision to grant or deny the\nrequest. As part of this analysis, PHMSA evaluates whether a special permit would impact the\nlikelihood of a pipeline failure as compared to the environmental status quo in the absence of the\nspecial permit. We will be denying or granting Gulf South Pipeline Company’s special permit\nrequest because based on our analysis of whether it would be or would not be consistent with\npipeline safety. We developed this assessment to determine the effects of our action on the\nenvironment.\n1\n\n<<<PAGE 2>>>\n\nII. Purpose and Need\nOn March 24, 2010, PHMSA received a request for a special permit from Boardwalk Pipeline\nPartners, operator of Gulf South Pipeline Company (GSPC) for relief from the requirements of\n49 C.F.R. § 192.611(a), concerning maximum allowable operating pressure (MAOP) limitations\nfor pipeline segments located in Mobile, Alabama. The class locations along this pipeline have\nchanged from an original Class 1 to Class 3 locations because of an increase in the population\nwithin the original class location of the pipeline. Section 192.611(a) would require GSPC to take\none or more actions to continue operating the affected segments after a class location change,\nincluding a reduction in operating pressure, or the installation of new pipe. GSPC would like to\ncontinue operating the affected segments at their current MAOPs, despite the fact that those\nsegments have experienced changes in Class Location.\nSpecial Permit Segment(s) Location Information:\nBelow is a summary of the special permit segments which are all located within Mobile\nCounty, Alabama.\nStation Number 318+78 to Station Number 322+ 14 (336 feet)\nStation Number 435+63 to Station Number 454+65 (1,904 feet)\nStation Number 455+85 to Station Number 461+08 (523 feet)\nNote: In addition to the Special Permit Segments, GPSC has identified a \"Special Permit\nInspection Area\" that extends 220 yards outward from the centerlines of the pipeline\nfor a total of approximately 23.97 miles along GPSC 's TPL 880. Specifically, the\nfollowing would constitute the Inspection Area:\nTPL 880 Special Permit Inspection Area: Station 0+00 to Station 1201+68 (23.97\nmiles)\nThis inspection area includes all of the special permit segments proposed under this\npermit.\nSee appendix A for maps of this area.\nRegulation Information:\nGSPC requests the waiving of compliance from the requirements of 49 CFR § 192.611 (a) which\nrequires pressure reduction or pipe replacements to address class location changes when the pipeline\nis not commensurate with the new class location.\nThe following is the text of 49 CFR 192.611 (a)\n(a) If the hoop stress corresponding to the established maximum allowable operating pressure of a segment of\npipeline is not commensurate with the present class location, and the segment is in satisfactory physical\ncondition, the maximum allowable operating pressure of that segment of pipeline must be confirmed or revised\naccording to one of the following requirements:\n2\n\n<<<PAGE 3>>>\n\n(1) If the segment involved has been previously tested in place for a period of not less than 8 hours:\n(i) The maximum allowable operating pressure is 0.8 times the test pressure in Class 2 locations,\n0.667 times the test pressure in Class 3 locations, or 0.555 times the test pressure in Class 4\nlocations. The corresponding hoop stress may not exceed 72 percent of the SMYS of the pipe in\nClass 2 locations, 60 percent of SMYS in Class 3 locations, or 50 percent of SMYS in Class 4\nlocations.\n(ii) The alternative maximum allowable operating pressure is 0.8 times the test pressure in Class 2\nlocations and 0.667 times the test pressure in Class 3 locations. For pipelines operating at\nalternative maximum allowable pressure per § 192.620, the corresponding hoop stress may not\nexceed 80 percent of the SMYS of the pipe in Class 2 locations and 67 percent of SMYS in Class\n3 locations\n(2) The maximum allowable operating pressure of the segment involved must be reduced so that the\ncorresponding hoop stress is not more than that allowed by this part for new segments of pipelines in the\nexisting class location.\n(3) The segment involved must be tested in accordance with the applicable requirements of Subpart J of this\npart, and its maximum allowable operating pressure must then be established according to the following\ncriteria:\n(i) The maximum allowable operating pressure after the requalification test is 0.8 times the test\npressure for Class 2 locations, 0.667 times the test pressure for Class 3 locations, and 0.555 times\nthe test pressure for Class 4 locations.\n(ii) The corresponding hoop stress may not exceed 72 percent of the SMYS of the pipe in Class 2\nlocations, 60 percent of SMYS in Class 3 locations, or 50 percent of SMYS in Class 4 locations\n(iii) For pipeline operating at an alternative maximum allowable operating pressure per § 192.620, the\nalternative maximum allowable operating pressure after the requalification test is 0.8 times the\ntest pressure for Class 2 locations and 0.667 times the test pressure for Class 3 locations. The\ncorresponding hoop stress may not exceed 80 percent of the SMYS of the pipe in Class 2\nlocations and 67 percent of SMYS in Class 3 locations.\n(b) The maximum allowable operating pressure confirmed or revised in accordance with this section, may not\nexceed the maximum allowable operating pressure established before the confirmation or revision.\n(c) Confirmation or revision of the maximum allowable operating pressure that is required as a result of a\nstudy under § 192.609 must be completed within 24 months of the change in class location. Pressure\nreduction under paragraph (a) (1) or (2) of this section within the 24-month period does not preclude\nestablishing a maximum allowable operating pressure under paragraph (a)(3) of § 192.611.\nJustification Discussion:\nGPSC submitted to PHMSA during the application process several justifications for its seeking\nof this special permit which are bulleted below:\nPipe replacement, however, is costly, disrupts service and the environment, and provides\nsafety benefits only to those located near the line experiencing the class location change.\nGPSC estimates that the cost of replacing the three pipe segments on TPL 880, which\ntotal 2,763 feet, to be $3,233,422. By contrast, the cost for Direct Current Voltage\nGradient (DCVG) Testing and Calibration Digs in the Special Permit Segments is\nestimated to cost $40,000. In summary, the costs of all activities indicated in the Special\nPermit are approximately $40,000.\n3\n\n<<<PAGE 4>>>\n\nBy avoiding pipe excavation and replacement will minimize costs to the operator, avoids\ndelivery interruptions and supply shortages, and averts environmental disturbance.\nImplementing enhanced inspection and assessment practices throughout the Inspection\nArea, in lieu of replacing small sections of pipe experiencing the class location change,\nextend pipeline safety benefits to a much greater area.\n4\n\n<<<PAGE 5>>>\n\nIII. Site Description\nTo begin a map of the special permit pipeline segments are attached in Appendix A of this\ndocument. The site description will now be described in the following areas, below with a\ndescription of the area in each.\nClass Location Information:\nGSPC stated in their application that there are approximately 45 residences and 2 businesses\nwithin the special permit segment areas. The number of people affected is approximately 153.\nThis area has gone through a change in population density which has increased the class\ndesignation to class 3 locations.\nSurface Waters:\nThe following text to describe this sub-section was directly taken from GSPC’s application:\nThe first segment is approximately 336 feet in length and does not cross\nany wetlands or bodies of water, including lakes. This pipeline special\npermit segment is located within an upland forested area, where the\nelevation dips south, southeast to an unnamed tributary of Hammer Creek.\nThe pipeline right-of-way in this area is maintained in an herbaceous state\nand is abutted on both sides by upland forest.\nThe second special permit segment is approximately 1,904 feet in length\nand crosses one riparian wetland area associated with one water body. The\nremainder of this section is within a residential area and land mowed and\nmaintained as pasture. No lakes are crossed or otherwise impacted by this\npipeline segment. The wetland and water body are associated with Fowl\nRiver and its basin. The pipeline right-of-way is currently maintained in an\nherbaceous state. The small wetland area crossed by this special permit\nsegment is approximately 412 feet in length.\nThe third special permit segment is approximately 523 feet in length and\ncrosses no wetlands or water bodies, including lakes. The majority of this\nspecial permit segment is located within a mowed and maintained pasture.\nThis special permit segment slopes gradually to the south, southeast to the\nFowl River basin. This pipeline segment is abutted to the west by a thin\ntree line.\nPotable (Drinking) Water Sources:\nThe following text to describe this sub-section was directly taken from GSPC’s application:\n5\n\n<<<PAGE 6>>>\n\nThe Sand and Gravel Aquifer underlies an area of about 6,500 square miles in\nsouthwestern Alabama including both locations of the Project. All of the\nsubsequent information concerning the Sand and Gravel Aquifer was supplied\nby the United States Environmental Protection Agency (USEP A, 2006). The\naquifer supplies most of the water used by small communities in the rural\nparts of Mobile County, Alabama; however the city of Mobile is supplied by\nsurface water. Approximately 150 million gallons per day (mgd) was\nwithdrawn from the Sand and Gravel Aquifer by all uses during 1985. Mobile\nCounty accounted for approximately 20 percent of the total usage Sand and\nGravel Aquifer.\nThe Sand and Gravel Aquifer consists largely of inter-bedded layers of sand\nand gravel. Clay beds and lenses are common in the aquifer and form local\nconfining beds. Movement of groundwater is generally coastward. The\naquifer ranges in age from middle Miocene to Holocene that were mostly\ndeposited in a deltaic environment. Water in the Sand and Gravel Aquifer is\nsuitable for drinking in most areas.\nGSPC does not anticipate any impacts to domestic water wells because no\nwells are believed to exist on or close to the project area. Based on a review\nof the Region 4 Sole Source Aquifer map, there are no EPA-designated sole\nsource aquifers in Alabama.\nSoils and Vegetation:\nThe following text to describe this sub-section was directly taken from GSPC’s application:\nThe Special Permit Segments are located in stable soil. The terrain throughout\nthe entire Special Permit Segments and Inspection Areas is a gradually\nsloping land and the soils are stable, falling into the \"probable acceptance\"\ncategory. The area is not prone to significant earthquakes, risk of flooding,\nsubsidence or landslides. Attachment B shows the proximity of dwellings and\nother populated areas to the pipeline right of way and the location of road\ncrossings.\nWildlife:\nThe following text to describe this sub-section was directly taken from GSPC’s application:\nThe primary wildlife habitat occurring within, and in the vicinity of the\nSpecial Permit Inspection and Area includes agricultural and residential land,\nand forested areas. These land types may provide habitat for wildlife species\nincluding hawks, white tailed deer, raccoons, bobcats, coyotes, migratory bird\nspecies, and turkeys. Project impacts on wildlife are expected to be minor\nbecause similar vegetation cover, forage and land types are relatively\nabundant in the project areas. Further, issuance of this Permit will not result\nin modifications to any habitat, impacts to wetland or water bodies, and no\neffects on fishery resources or essential fish habitat (EFH).\n6\n\n<<<PAGE 7>>>\n\nNo areas within these pipeline special permit segments are designated as\nsensitive wildlife habitat. The proposed special permit segments doe not cross\nany land administered by federal, state, or local agencies, or nongovernmental\norganizations that could provide sensitive wildlife habitat. No lands enrolled\nin the Conservation Reserve Program (CRP) or the Wetland Reserve Program\n(WRP), both administered by the Natural Resource Conservation Service\n(NRCS), will be affected by the special permit segments.\nGeologic Hazards:\nThe following text to describe this sub-section was directly taken from GSPC’s application:\nAlthough earthquakes occur in Alabama, many are too small to be felt by\npeople and most are unlikely to do serious damage (Alabama Geological\nSurvey, 1999). The great majority of earthquakes occur in the northern half of\nAlabama, and based on historical records through 2003, none have occurred\nin Mobile County. The largest earthquake reported in Alabama occurred in\nOctober 1916 in northern Shelby County. This earthquake had an intensity of\nVII on the Modified Mercalli Scale. The largest instrumentally recorded\nearthquake was a Richter magnitude 4.9 on October 24, 1997 in Escambia\nCounty. There are no surface faults mapped in Mobile County (Geological\nSurvey of Alabama, 1971).\nTherefore, based on the relatively low historic seismic activity and the low\nlevel of ground motion predicted for the project area, it is unlikely that a\ndamaging earthquake will occur in any of the pipeline segments. No soils\nwith a severe erosion potential were identified within the project area. All of\nthe soil series impacted by the Project exhibit slight erosion potential.\nAccording to the soil survey reports, there are no indications of rock within\nthe upper five feet of ground surface. Other geological hazards include\nlandslides, karst topography, subsidence and shallow bedrock. GSPC is not\naware of any shallow bedrock or karst topography in the vicinity of this\nPermit, nor has it documented landslides or ground subsidence in the vicinity\nof the special permit segments.\nSocioeconomic Impacts:\nThe following text to describe this sub-section was directly taken from GSPC’s application:\nAll special permit segments activities will be conducted within the boundaries\nof the previously disturbed pipeline right-of-way. On an annual basis GSPC\nsubmits a written request to the Alabama SHPO for categorical exclusion for\nactivities to be undertaken within its existing, previously disturbed ROW to\nensure compliance with the National Historic Preservation Act of 1966, as\namended (NHPA). Section 106 requires federal agencies or their applicants to\ntake into account the effects of their undertakings on historic structural and\narchaeological properties. The Alabama SHPO concurred with its categorical\n7\n\n<<<PAGE 8>>>\n\nexclusion for work within existing ROW and stated that \"no known historic\nproperties will be affected by this undertaking.\"\nThe proposed work associated with this Special Permit will have no impact\non Native Americans or any land owned or otherwise administered by Native\nAmerican tribes.\n8\n\n<<<PAGE 9>>>\n\nIV. Alternatives Considered and Environmental Impacts of Each Alternative\nAlternative 1: Grant the Request with Conditions.\nUnder this alternative, we would grant the special permit with certain conditions designed to\nreduce the risks associated with permitting GSPC to continue to operate its pipeline segments at\nthe existing MAOP in Class 3 locations. GSPC would be required to take action to reduce risks\nassociated with pipe coating, cathodic protection, damage prevention, and weld seam and girth\nweld integrity. As PHMSA has done in past class location special permits, we would condition a\nspecial permit on GSPC performing close interval surveys to determine the effectiveness of its\ncathodic protection systems; performing a pipeline coating survey and repairing damage;\nperforming stress corrosion cracking surveys; improving damage prevention programs;\nperforming engineering analysis of longitudinal pipe seams and remediating any threats;\nperforming pipeline inspections with instrumented in-line inspection (ILI) tools and repairing\nany anomalies, etc.\nHuman Safety Factors Analysis:\nThe changing of a class location does come with some inherent human safety factors\nhowever; they can be mitigated with increased pipeline integrity procedures. This will\naid to the longevity and overall safety of the pipeline. With class location waivers the\napplicant is seeking to get a waiver from PHMSA’s regulations which limit the pressures\nbased on inhabitants within the pipeline area. Even though the applicant does not have\ndirect control of such development which may change the class location of the pipeline\nthe applicant is still responsible for making sure that the class location regulations are met\nat all times and were they cannot logically and conditionally they will go through a\nspecial permit process such as this.\nTo the increased pipeline integrity measures proposed by GSPC and normally imposed\nby PHMSA during a class location special permit. There appears to be enough of a factor\nof safety to logically see no or very little change to the human safety risks to this request.\nEnvironmental Aspects Analysis:\nBy granting this request and stepping up pipeline integrity measures as identified in the\nconditions sections there appears to be very little impacts or risks to the environment\nwithin the special permit areas. Below is an examination of each environment area from\nthe site description in terms of this alternative.\nLand Use: There appears to be no greater risk to land use for no planned increase\ndevelopment of the affected area is know at the current time; furthermore with the GSPC\noffered conditions an increased factor of safety for land use will be accomplished with\n9\n\n<<<PAGE 10>>>\n\nthe inspection of the entire pipeline corridor instead of just the affected special permit\nsegments.\nIn this instance, the special permit conditions would require GSPC to inspect and provide\nenhanced integrity assessments on 23.97 miles of pipeline. These measures would result\nin safety benefits to more than 376 single family dwellings and18 businesses.\nWetlands: There will be no greater risk to wetlands than a no-build alternative for there\nwill be minimal if no excavations within wetland foreseen. If however there are\nexcavations within a wetland or other environmentally sensitive area applicable Federal\nand State laws and agencies shall be contacted and coordinated with to ensure proper\nexcavation permitting.\nDrinking Water: GSPC identified no areas of this special permit in the ROW of this\npipeline.\nSoils and Vegetation: Any areas of excavation would be limited and confined to the\nexisting ROW and filling of any excavation will be done with in-situ soils. Further\npermitting of soil conservation are to be handled at a federal/state/local authority.\nWildlife Habitats: From the data collected as part of this permit it appears that are no\nsensitive wildlife areas within the ROW. Areas with wildlife however may be affected\ntemporarily as testing and inspection processes take place. Other risks to existing habitat\nwithin the ROW are limited to this ROW. Any catastrophic failure would negatively\nimpact wildlife within the potential impact radius (PIR) however as stated in other areas\nhere these risks appear to be lessened with the proposed initial conditions.\nCultural Recourses: There were no significant cultural resource impacts to this permit.\nSocioeconomic Impacts: There were no significant cultural resource impacts to this\npermit.\nTypical PHMSA Special Permit Conditions\nIn summary, these conditions may include requirements that GSPC perform the following\nwork which are typical with this type of request for a special permit:\nSubsequent re-inspections will be performed using in-line inspection at intervals as\nspecified by 49 CFR Part 192, Subpart O reassessment intervals.\n10\n\n<<<PAGE 11>>>\n\nAny anomalies detected during these in-line inspections will be remedied in\naccordance with 49 CFR Part 192, Subpart O, GSPC Integrity Management Program\nand the conditions of the special permit.\nClose interval survey (CIS) and direct current voltage gradient (DCVG) will be\nperformed on the special permit pipeline segments within the proposed inspection\narea in order to ensure cathodic protection (CP) is at acceptable levels along the\npipeline. Areas of low CP potentials will be remedied in accordance with the special\npermit conditions.\nA depth of cover survey will be performed within the special permit segment utilizing\nelectronic depth equipment, or equivalent. Remedial actions and/or additional\npreventive and mitigative measures will be implemented in the special permit\nsegment that do not meet minimum cover criteria specified by § 192.327.\nStress corrosion cracking direct assessment will be performed on the special permit\nsegments within the proposed special permit area.\nGSPC proposes to perform monthly aerial patrols, weather permitting, in the\ninspection area containing the special permit segment.\nDirectly above is a list of typical conditions associated with this type of permit a full set of\nconditions can be found within the finalized special permit in a section call the Special\nPermit Analysis and Findings.\nGSPC Offered Conditions\nGSPC has offered several conditions to help mitigate risk associated with this permit.\nBelow is a list of the condition(s) and a brief analysis of them.\nMonthly aerial or foot patrols, weather permitting, to observe surface conditions\non and adjacent to the pipeline right-of-way for indication of leaks, third party\nconstruction , exposed pipe, erosion or other facts that affect the safety and\noperation of the pipeline.\nAn increased inspection area of the entire pipeline instead of only focusing on the\npipeline segments affected by this permit.\nThe frequency of this surveillance of the pipeline does exceed the requirement under 49 CRF\nPart 192. Also the breath of which GSPC chooses to include in their monthly patrols will aid the\nintegrity of the pipeline.\n11\n\n<<<PAGE 12>>>\n\nAll conditions listed above are in the direct interest to the public safety of the special permit\nsegment area. Each condition exceeds what is normally required as part of PHMSA’s\nregulations and enforces a greater level of safety to both the public and the environment. Lastly\nthe implementation of these conditions would be a net positive when compared to using current\nregulations.\nAlternative 2: Deny the Request.\nUnder this alternative, we would deny GSPC’s special permit request. GSPC would not be\ngranted a waiver of compliance with the requirements of 192.611a, and would continue to be\nrequired to comply with existing regulations.\nPotential Safety Risks of Denial\nIf the permit was denied, pipeline construction and replacement of the special permit pipeline\nsegments would need to be accomplished. There would be no risk to this option beyond what\nrisks are posed by following PHMSA regulations. However when one can exceed PHMSA’s\nregulations verses follow them it does pose a greater risk even though the factor of safety is\nalready met.\nPotential Environmental Impacts of Denial\nThe denial of the permit and construction of new pipeline would pose a greater risk to the\nenvironment and more steps would need to be taken to ensure that the construction would\nremediate any environmental disturbance or damage.\n12\n\n<<<PAGE 13>>>\n\nV. Request for Comments\nPHMSA will carefully analyze the safety and environmental risks associated with the request\nspecial permit. To assist PHMSA in its analysis, PHMSA requests comments from the public on\nthis Draft Environmental Assessment including information relevant to whether the special\npermit would have any significant environmental impacts, and if so, whether any conditions\ncould be imposed to mitigate such impact.\nVI. List of Preparers\nTodd DelVecchio, P.E., PMP, PHMSA, USDOT\nJim Curry, PHMSA, USDOT\nBrianne Kurdock, PHMSA, USDOT\nVII. Agencies and Persons Consulted\nNo other agencies were consulted, but PHMSA considered environmental information and\ndocuments submitted by APE.\n13\n\n<<<PAGE 14>>>\n\nAppendix A Figure 1\n\"PRELIMINARY NOT FOR CONSTRUCTION\"\nCLS 1 TO 3\nTO STA 322+00\nFROM STA 318+78\nCLS 2 TO 3\nFROM STA 322+00\nTO STA 322+14\nFRÓM STA 318+78 TO STA 322+14\nINDEX 880\nProposed Special Permit Segment\nLegend\n- REPLACEMENT\nGULF SOUTH TRANSMISSION PIPELINE\nHCA\nSTRUCTERES\nGIS CLASS\nCLASS\n- HOHWAYS\nSTREETS\n1\" = 200'\nMAP M1\nTPL 880\nGULF SOUTH\n14\n\n<<<PAGE 15>>>\n\nAppendix A Continued Figure 2\n\"PRELIMINARY NOT FOR CONSTRUCTION\nCLS 1 TO 3\nTO STA 461+08\nFROM STA 460+70\nINDEX 880\nCLS 2 TO 3\nProposed Special Permit Segment\nFROM STA 455+85\nFROM STA 455+85 TO STA 461+08\nTO STA 460+70\nCLS 2 TO 3\nINDEX 880\nFROM STA 435+63 TO STA 454+65\nProposed Special Permit Segment\nFROM STA 420+12\nTO STA 458+52\nHCA IN WAIVER\nLegend\nA NPACEMENT\nGIS CLAS:\nMAP M2\n1\" = 200°\nTPL 880\nBOO\nGULF SOUTH\n15","truncated":false,"body_characters":25733}