# PHMSA Environmental Assessment/FONSI

- **operation:** document
- **citation:** 0900006480e91a54
- **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:** The document evaluates a special permit petition from TransCanada (TCPL-ANR) to remain at existing maximum allowable operating pressures on four segments of Line 716 in St. Martin Parish, Louisiana, after class locations changed from Class 1 to Class 3 due to increased nearby population. PHMSA considered granting the permit with conditions but concluded “even with conditions, the issuance of a special permit would be inconsistent with pipeline safety,” and therefore denied the request. PHMSA found known longitudinal seam and other pipe integrity issues on the affected segments that would not be acceptably mitigated by the proposed conditions, and determined that denial would likely lead to pipe replacement or pressure reduction/requalification, producing a net positive safety and environmental outcome. The analysis is limited to the information and materials in the PHMSA docket for PHMSA
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- **source url:** https://downloads.regulations.gov/PHMSA-2009-0055-0014/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-2009-0055
Location of Subject Facilities: St. Martin Parish, Louisiana
Document Date: May 19, 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
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, Pipeline and Hazardous Materials Safety Administration (“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 St. Martin Parish, Louisiana.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 change. TCPL-ANR
1 A description of the pipeline segments can be found in the docket for this Special Permit request (PHMSA-2009-
0055) at www.regulations.gov.
- See PHMSA Special Permit Analysis and Findings, 2.

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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 TransCanda’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 four special permit segments along its natural gas
transmission pipeline system. These four special permit segments are on the 20-inch Line 716
located in St. Martin Parish, Louisiana.
2 The class locations along these pipelines 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-2009-0055, 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, we 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 were 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
known longitudinal weld seam issues with some of the pipe used on TCPL-ANR pipeline
segments, nor would it reduce threats associated with a lack of documentation on pipe
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.
2

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mechanical and chemical properties and girth welds on other pipe segments.4 PHMSA has
specifically recognized the dangers of seam threats in its “Criteria for Considering Class
Location Waiver Requests” (69 FR 38948) and through our experience with numerous
longitudinal seam-related failures.
These seam threats increase the possibility of a failure of the TCPL-ANR segments that would
be subject to a special permit. The threats posed by these pipe seam characteristics are not
acceptable in a populated Class 3 location. 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
0.47 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 longitudinal seam issues with new pipe, and a
reduction in the risk 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 possible longitudinal weld seam and other safety threats.
4 A description of the issues associated with pipe weld seams, mechanical and chemical properties, and girth welds
can be found in the docket. See PHMSA Special Permit Analysis and Findings, PHMSA-2009-0055.
3

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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
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.
4
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