# PHMSA Draft Environmental Assessment

- **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:** Not available
- **effective on:** Not available
- **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.
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PIPELINE 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.
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II. 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:
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(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.
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By 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.
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III. 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:
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The 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).
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No 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
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exclusion 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.
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IV. 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
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the 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.
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Any 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.
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All 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.
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V. 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.
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Appendix 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
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Appendix 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
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