# PHMSA Environmental Assessment/FONSI

- **operation:** document
- **citation:** 0900006480e91a3d
- **title:** PHMSA Environmental Assessment/FONSI
- **source type:** rulemaking
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** current
- **official:** true
- **published on:** Not available
- **effective on:** Not available
- **summary:** PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION SPECIAL PERMIT ENVIRONMENTAL ASSESSMENT and FINDING OF NO SIGNIFICANT IMPACT Special Permit Requester: TransCanada Pipelines Limited PHMSA Docket No.: PHMSA-2009-0056 Location of Subject Facilities: Tate County, Mississippi Document Date: June 2, 2010 Contacts: Tewabe Asebe, 202-366-5523, tewabe.asebe@dot.gov I. Background... change. TCPL-ANR would like to continue operating the affected segments at their current MAOPs, despite the fact that those segments have experienced changes in Class Location. PHMSA weighed the alternatives of granting the permit with conditions or denying the permit. PHMSA is denying TransCanada’s special permit...
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- **app url:** https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e91a3d
- **source url:** https://downloads.regulations.gov/PHMSA-2009-0056-0010/attachment_1.pdf
**body:**

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PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
SPECIAL PERMIT
ENVIRONMENTAL ASSESSMENT and FINDING OF NO SIGNIFICANT IMPACT
Special Permit Requester: TransCanada Pipelines Limited
PHMSA Docket No.: PHMSA-2009-0056
Location of Subject Facilities: Tate County, Mississippi
Document Date: June 2, 2010
Contacts: Tewabe Asebe, 202-366-5523, tewabe.asebe@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
Pipeline and Hazardous Materials Safety Administration (“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 are denying
TransCanada’s special permit request because based on our analysis it would not be consistent
with pipeline safety. We developed this assessment to determine the effects of our action on the
environment.
II. Purpose and Need
On February 6, 2009, PHMSA received a special permit petition from TransCanada Pipelines
Limited, operator of American Natural Resources Pipeline (TCPL-ANR), for relief from the
requirements of 49 C.F.R. § 192.611(a), concerning maximum allowable operating pressure
(MAOP) limitations for certain pipeline segments located in Tate County Mississippi.
1 The class
locations along these pipeline segments have changed from an original Class 1 location to a
Class 3 location because of an increase in the population within the original class location of the
pipeline. Section 192.611(a) would require TCPL-ANR to take one or more actions, including a
reduction in operating pressure, the performance of pressure tests to re-qualify MAOP, or the
installation of new pipe, to continue operating the affected segments after a class location
1 A description of the pipeline segments can be found in the docket for this Special Permit request (PHMSA-2009-
0056) at www.regulations.gov.
- See PHMSA Special Permit Analysis and Findings, page 2.

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change. TCPL-ANR would like to continue operating the affected segments at their current
MAOPs, despite the fact that those segments have experienced changes in Class Location.
PHMSA weighed the alternatives of granting the permit with conditions or denying the permit.
PHMSA is denying TransCanada’s special permit request. PHMSA concluded that even with
conditions, the issuance of a special permit would be inconsistent with pipeline safety.
III. Affected Environment
TCPL-ANR’s special permit request concerns a segment of 30-inch Line 1-501 downstream of
Valve 27 in Tate County, Mississippi.2 The class locations along this pipeline have changed
from an original Class 1 location to a Class 3 location, due to an increase in the population near
the pipeline segments. The population figures in the vicinity of the affected segments and other
information about the affected environment are incorporated into this document and can be
found in the docket PHMSA-2009-0056, at www.Regulations.gov.
3
IV. Alternatives Considered and Environmental Impacts of Each Alternative
Alternative 1: Grant Special Permit Request with Conditions
Under this alternative, PHMSA would grant the special permit with certain conditions designed
to reduce the risks associated with permitting TCPL-ANR to continue to operate its pipeline
segments at the existing MAOP in Class 3 locations. TCPL-ANR 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 TCPL-ANR 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.
Some of the conditions that would be imposed, if the permit was granted, would have a positive
impact on the environment because they would provide enhanced safety protections for a number
of pipeline threats. However, on balance, selection of this alternative could have a negative
impact on the environment. This choice would not reduce pipeline safety threats associated with
a pipe toughness4 properties and girth welds on the pipe segment.
2 A Map and description of the environment surrounding the pipeline segments can also be found in the docket. See
page 9 of each of TransCanada’s responses to PHMSA’s environmental questionnaire.
3 See TransCanada’s responses to PHMSA’s environmental questionnaire, page 3.
4 A description of the issues associated with low toughness pipe and girth welds can be found in the docket. See
PHMSA Special Permit Analysis and Findings, PHMSA-2009-0056, page 5.
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Low toughness pipe increases the consequences of a failure of the TCPL-ANR segment that
would be subject to a special permit. The threats posed by low toughness steel characteristics are
not acceptable in a populated Class 3 location. Higher toughness properties are needed for a
ductile fracture arrest and to reduce fracture propagation if the pipe should have a failure, so that
a smaller area would be affected. There is no existing technology to remediate these in service
gas pipelines that would mitigate the safety risks in a Class 3 Location consistent with replacing
the pipe with modern steel pipe, external coatings, field welding, girth weld non-destructive
testing, and in-place hydrostatic testing methods. Gas pipeline failures are a threat to the public
and the environment because they may result in fires or explosions, which can harm the public
and the environment.
Alternative 2: Deny Special Permit Request
Under this alternative, we would deny TCPL-ANR’s special permit request. TCPL-ANR would
not be granted a waiver of compliance with the requirements of § 192.611(a), and would be
required to continue to comply with existing regulations. Current regulations have achieved
excellent safety performance through use of increased safety factors, to compensate for
unknowns or technological limitations associated with historical operation and maintenance
practices, as the population near a natural gas transmission pipeline increases (resulting in Class
Location changes).
Because certain of TCPL-ANR’s pipeline segments are now in Class 3 locations due to an
increase in population in the nearby area, the company would have to reduce the operating
pressure of the Class 3 pipeline segments, perform pressure tests to re-qualify the pipe, or install
new pipe. TCPL-ANR has indicated that if its special permit request is denied it would replace
0.17 miles of pipe in order to address the Class Location change.
Denial of the special permit request (if TCPL-ANR, in fact, chooses not to reduce pressure or re-
qualify pipe MAOP) could lead to the disturbance of soil, vehicle and equipment travel on the
rights-of-way, and other negative environmental impacts associated with pipe replacement.
However, such negative environmental impacts would be limited to the existing rights-of-way
and would be the same impacts that would have likely occurred had TCPL-ANR never applied
for a special permit and had simply complied with the regulations.
PHMSA’s denial would have a positive impact on the environment because it would likely lead
to TCPL-ANR replacing pipe with known low toughness with new pipe, and a reduction in the
risk and consequences of a pipeline failure in populated Class 3 areas. Gas pipeline failures can
lead to fires and explosions and cause harm to the public and the environment. On balance,
PHMSA’s denial of the permit would have a net positive impact because it is likely to lead to
TCPL-ANR replacing the pipe with low toughness and other possible safety threats.
V. Finding of No Significant Impact (FONSI)
PHMSA has carefully analyzed the safety and environmental risks associated with denial of this
special permit. By denying this special permit TCPL-ANR will be required to reduce the
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operating pressure or replace pipe that presents certain safety threats. The net safety and
environmental impact of this denial will be positive. Therefore, we believe there are no
significant environmental impacts associated with the denial of TCPL-ANR’s request.
VI. List of Preparers and Reviewers
Steve Nanney, PHMSA
Jim Curry, PHMSA
Tewabe Asebe, PHMSA
VII. Agencies and Persons Consulted
No other agencies were consulted, but PHMSA considered environmental information and
documents submitted by TCPL-ANR.
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