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Fed
eral
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gy
Reg
ulato
ry
Com
mis
sion
5
Tennessee Gas Pipeline Company, L.L.C Docket No. CP14-88-000
National Fuel Gas Supply Corporation Docket No. CP14-100-000
Niagara Expansion and Northern Access 2015 Projects
Environmental Assessment
Cooperating Agency:
New York State Department of Agriculture and Markets
Washington, DC 20426
Office of
Energy Projects
July 2014
FEDERAL ENERGY REGULATORY COMMISSION WASHINGTON, D.C. 20426
OFFICE OF ENERGY PROJECTS
In Reply Refer To:
OEP/DG2E/Gas 2
Tennessee Gas Pipeline Company,
L.L.C.
Docket No. CP14-88-000
National Fuel Gas Supply Corporation
Docket Nos. CP14-100-000
TO THE PARTY ADDRESSED:
The staff of the Federal Energy Regulatory Commission (FERC or Commission)
has prepared this environmental assessment (EA) for the Niagara Expansion and
Northern Access 2015 Projects proposed by Tennessee Gas Pipeline Company, L.L.C
(TGP) and National Fuel Gas Supply Corporation (National Fuel) in the above-
referenced dockets. TGP proposes to lease approximately 158,000 dekatherms per day of
natural gas capacity from National Fuel. Because these projects are related actions, they
have been reviewed in one EA.
The EA assesses the potential environmental effects of the construction and
operation of the Niagara Expansion and Northern Access 2015 Projects in accordance
with the requirements of the National Environmental Policy Act. TGP’s proposed
Niagara Expansion Project involves construction of 3.1 miles of 30-inch-diameter
looping pipeline and modifications at one existing meter station and two existing
compressor stations. National Fuel’s proposed Northern Access 2015 Project involves
construction of one new compressor station, modifications at one existing compressor
station, and modifications at one existing meter station. The FERC staff concludes that
approval of the proposed projects, with appropriate mitigating measures, would not
constitute a major federal action significantly affecting the quality of the human
environment.
The New York State Department of Agriculture and Markets participated as a
cooperating agency in the preparation of the EA. Cooperating agencies have jurisdiction
by law or special expertise with respect to resources potentially affected by the proposal
and participate in the National Environmental Policy Act analysis.
The EA has been placed in the public files of the FERC and is available for
viewing on the FERC’s website at www.ferc.gov using the eLibrary link. A limited
number of copies of the EA are available for distribution and public inspection at:
2
Federal Energy Regulatory Commission
Public Reference Room
888 First Street NE, Room 2A
Washington, DC 20426
(202) 502-8371
Copies of the EA have been mailed to federal, state, and local government
representatives and agencies; elected officials; public interest groups; Native American
tribes; potentially affected landowners and other interested individuals and groups;
newspapers and libraries in the project areas; and parties to this proceeding. Any person
wishing to comment on the EA may do so. Your comments should focus on the potential
environmental effects, reasonable alternatives, and measures to lessen or avoid
environmental impacts. The more specific your comments, the more useful they will be.
To ensure that your comments are properly recorded and considered prior to a
Commission decision on the proposal, it is important that we receive your comments in
Washington, DC on or before August 15, 2014.
For your convenience, there are three methods you can use to submit your
comments to the Commission. In all instances, please reference the project docket
numbers (CP14-88-000 or CP14-100-000) with your submission. The Commission
encourages electronic filing of comments and has dedicated eFiling expert staff available
to assist you at 202-502-8258 or [email protected].
(1) You may file your comments electronically by using the eComment feature,
which is located on the Commission's Internet website at www.ferc.gov under
the link to Documents and Filings. An eComment is an easy method for
interested persons to submit brief, text-only comments on a project;
(2) You may file your comments electronically by using the eFiling feature, which
is located at www.ferc.gov under the link to Documents and Filings. With
eFiling, you can provide comments in a variety of formats by attaching them as
a file with your submission. New eFiling users must first create an account by
clicking on “eRegister.” You will be asked to select the type of filing you are
making. A comment on a particular project is considered a “Comment on a
Filing;” or
(3) You may file a paper copy of your comments at the following address:
3
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE, Room 1A
Washington, DC 20426
Although your comments will be considered by the Commission, simply filing
comments will not serve to make the commentor a party to the proceeding. Any person
seeking to become a party to the proceeding must file a motion to intervene pursuant to
Rule 214 of the Commission's Rules of Practice and Procedures (18 CFR 385.214).1
Only intervenors have the right to seek rehearing of the Commission's decision.
Affected landowners and parties with environmental concerns may be granted
intervenor status upon showing good cause by stating that they have a clear and direct
interest in this proceeding which would not be adequately represented by any other
parties. You do not need intervenor status to have your comments considered.
Additional information about the project is available from the Commission's
Office of External Affairs at (866) 208-FERC or on the FERC website (www.ferc.gov)
using the eLibrary link. Click on the eLibrary link, click on “General Search” and enter
the docket number excluding the last three digits in the Docket Number field (i.e., CP14-
88 or CP14-100). Be sure you have selected an appropriate date range. For assistance,
please contact FERC Online Support at [email protected] or toll free at (866)
208-3676, or for TTY, contact (202) 502-8659. The eLibrary link also provides access to
the texts of formal documents issued by the Commission, such as orders, notices, and
rulemakings.
In addition, the Commission offers a free service called eSubscription which
allows you to keep track of all formal issuances and submittals in specific dockets. This
can reduce the amount of time you spend researching proceedings by automatically
providing you with notifications of these filings, document summaries, and direct links to
the documents. Go to (www.ferc.gov/docs-filing/esubscription.asp).
Kimberly D. Bose
Secretary
1 Interventions may also be filed electronically via the Internet in lieu of paper. See the previous
discussion of filing comments electronically.
i
TABLE OF CONTENTS
A. PROPOSED ACTION ................................................................................................................. 1
1.0 Introduction ............................................................................................................... 1
2.0 Purpose and Need ...................................................................................................... 1
3.0 Proposed Facilities ..................................................................................................... 2
4.0 Public Review and Comment .................................................................................... 5
5.0 Permits, Approvals, and Regulatory Requirements................................................... 5
6.0 Non-Jurisdictional Facilities ...................................................................................... 7
7.0 Construction, Operation, and Maintenance Procedures ............................................ 8
8.0 Land Requirements .................................................................................................... 11
B. ENVIRONMENTAL ANALYSIS ............................................................................................ 13
2.0 Water Resources and Wetlands ................................................................................. 15
2.1 Groundwater .......................................................................................... 15
2.2 Surface Water Resources ....................................................................... 16
2.3 Wetlands ................................................................................................ 17
2.4 Hydrostatic Testing ............................................................................... 18
3.0 Vegetation and Wildlife ............................................................................................. 19
3.1 Vegetation .............................................................................................. 19
3.2 Wildlife .................................................................................................. 19
3.3 Fisheries ................................................................................................. 21
3.4 Special Status Species ........................................................................... 21
4.0 Land Use, Recreation, and Visual Resources ............................................................ 23
5.0 Cultural Resources ..................................................................................................... 25
6.0 Air Quality and Noise ............................................................................................... 28
6.1 Air Quality ............................................................................................. 28
6.2 Noise ...................................................................................................... 38
7.0 Reliability and Safety ................................................................................................ 40
7.1 Safety Standards .................................................................................... 41
7.2 Pipeline Accident Data .......................................................................... 44
7.3 Impact on Public Safety ......................................................................... 46
8.0 Cumulative Impacts ................................................................................................... 47
C. ALTERNATIVES ...................................................................................................................... 57
1.0 No-Action Alternative ............................................................................................... 57
2.0 System Alternatives ................................................................................................... 57
3.0 Alternative Pipeline Routes ....................................................................................... 58
4.0 Aboveground Facility Site Alternatives .................................................................... 58
ii
D. CONCLUSIONS AND RECOMMENDATIONS ................................................................... 59
LIST OF FIGURES AND TABLES
Figure 1 Niagara Expansion Project
Figure 2 Northern Access 2015 Project
Table 1: Federal and State Permits, Approvals, and Consultations for TGP’s
Project .............................................................................................................. 6
Table 2: Federal and State Permits, Approvals, and Consultations for National
Fuel's Project ................................................................................................... 7
Table 3: Additional Temporary Workspaces Within 50 Feet of a Wetland or
Waterbody ....................................................................................................... 9
Table 4: Land Requirements for TGP’s Project ........................................................................ 11
Table 5: Land Requirements for National Fuel's Project .......................................................... 12
Table 6: Waterbodies Impacted by TGP's Niagara Expansion Project ..................................... 16
Table 7: Hydrostatic Test Water Requirements for the Projects ............................................... 18
Table 8: Federally-listed Status Species Potentially Occurring in the Project
Areas .............................................................................................................. 22
Table 9: Summary of Land Use Impacts for TGP’s Project ..................................................... 24
Table 10: Summary of Land Use Impacts for National Fuel's Project ..................................... 24
Table 11: Estimated Construction Emissions ........................................................................... 31
Table 12: Potential-to-Emit Emissions for the Northern Access 2015 Project ......................... 31
Table 13: NAAQS Modeling Results-Hinsdale Compressor Station ....................................... 32
Table 14: NAAQS Modeling Results-Concord Compressor Station ........................................ 33
Table 15: Estimate Operational Noise for the Northern Access 2015 Project .......................... 39
Table 16: Natural Gas Transmission Pipeline Significant Incidents by Cause
1994-20131 .................................................................................................... 45
Table 17: Outside Forces Incidents by Cause1 .......................................................................... 46
Table 18: Injuries and Fatalities- Natural Gas Transmission Pipelines .................................... 46
Table 19: Nationwide Accidental Deaths 1 ............................................................................... 47
Table 20: Existing and Future FERC Jurisdictional Projects Evaluated for
Cumulative Impacts ....................................................................................... 49
Table 21: Existing or Future Non-jurisdictional Projects Evaluated for Potential
Cumulative Impacts ....................................................................................... 51
iii
LIST OF APPENDICES
Appendix A Project Maps
Appendix B List of Preparers
iv
TECHNICAL ABBREVIATIONS AND ACRONYMS
ACHP Advisory Council on Historic Preservation
ADP Allegheny Defense Project
APE area of potential effect
AQCR air quality control regions
ATWS additional temporary workspace
CAA Clean Air Act
Certificate Certificate of Public Convenience and Necessity
CFR Code of Federal Regulations
CH4 methane
CO carbon monoxide
CO2 carbon dioxide
CO2e carbon dioxide equivalents
COE U.S. Army Corps of Engineers
Commission Federal Energy Regulatory Commission
CWA Clean Water Act
dB decibels
dBA decibels on the A-weighted scale
DOT U.S. Department of Transportation
EA environmental assessment
EIS environmental impact statement
EPA U.S. Environmental Protection Agency
ESA Endangered Species Act
ESCAMP National Fuel’s Erosion Sedimentation Control and Agricultural
Mitigation Plan
FERC Federal Energy Regulatory Commission
FWS U.S. Fish and Wildlife Service
GHG greenhouse gas
GWP global warming potential
HAPs hazardous air pollutants
HCA high consequence area
hp horsepower
IPCC Intergovernmental Panel on Climate Change
Ldn day-night sound level
Leq equivalent sound levels
MAOP maximum allowable operating pressure
Memorandum Memorandum of Understanding on Natural Gas Transportation
Facilities
NAAQS National Ambient Air Quality Standards
National Fuel National Fuel Gas Supply Corporation
National Fuel’s Project Northern Access 2015 Project
NCA National Climate Assessment: Climate Change Impacts in the
United States
NPDES National Pollution Discharge Elimination System
NEPA National Environmental Policy Act
v
NESHAP National Emissions Standards for Hazardous Air Pollutants
NGA Natural Gas Act
NHPA National Historic Preservation Act
N20 nitrous oxide
NNSR Nonattainment New Source Review
NOI Notice of Intent to Prepare an Environmental Assessment for the
Proposed Niagara Expansion Project and Northern Access 2015
Project and Request for Comments on Environmental Issues
NO2 nitrogen dioxide
NOX nitrogen oxides
NSA noise sensitive area
NSPS New Source Performance Standards
NYHP New York State Office of Parks, Recreation and Historic
Preservation
NYSDEC New York State Department of Environmental Protection
O3 ozone
OEP Office of Energy Projects
OTR Ozone Transport Region
PADEP Pennsylvania Department of Environmental Protection
PHMSA Pipeline and Hazardous Materials Safety Administration
PHMC Pennsylvania Historical and Museum Commission
Plan Upland Erosion Control, Revegetation, and Maintenance Plan
PM2.5 particulate matter with an aerodynamic diameter less than or
equal to 2.5 microns
PM10 particulate matter with an aerodynamic diameter less than or
equal to 10 microns
PNHP Pennsylvania Natural Heritage Program
PTE potential-to-emit
Procedures Wetland and Waterbody Construction and Mitigation
Procedures
Projects Niagara Expansion and Northern Access 2015 Projects
PSD Prevention of Significant Deterioration
Secretary Secretary of the Commission
SHPO State Historic Preservation Office
SIP State Implementation Plan
SPRP Spill Prevention and Response Procedures
SO2 sulfur dioxide
TGP Tennessee Gas Pipeline Company, L.L.C.
TGP’s Project Niagara Expansion Project
tpy tons per year
UDP Unanticipated Discovery Plan
USGCRP United States Global Change Research Program
VOC volatile organic compounds
1
A. PROPOSED ACTION
1.0 Introduction
The staff of the Federal Energy Regulatory Commission (Commission or FERC)
prepared this environmental assessment (EA) to assess the environmental effects of the
natural gas pipeline facilities proposed by Tennessee Gas Pipeline Company, L.L.C. (TGP)
and National Fuel Gas Supply Corporation (National Fuel). We2 prepared this EA in
compliance with the requirements of the National Environmental Policy Act of 1969 (NEPA),
Title 40 of the Code of Federal Regulations (CFR), Parts 1500–1508 (40 CFR 1500–1508),
and FERC implementing regulations at 18 CFR Part 380.
On February 28, 2014, TGP filed an application for a Certificate of Public
Convenience and Necessity (Certificate) in Docket No. CP14-88-000 under Sections 7(c) and
7(b) of the Natural Gas Act (NGA) and Part 157 of FERC’s regulations. TGP proposes to
construct, own, and operate a new natural gas pipeline loop3
and modify existing compression
and meter station facilities to lease delivery capacity from National Fuel. TGP would lease
140,000 dekatherms per day of firm transportation capacity from National Fuel. Combined
with existing reserved capacity on its system, TGP would be able to transport a total of
158,000 dekatherms per day to its shipper.
On March 7, 2014, National Fuel filed a related application for a Certificate in Docket
No. CP14-100 under Section 7(c) of the NGA and Part 157 of FERC’s regulations. National
Fuel proposes to construct, own, and operate a new compressor station and modify existing
compression and meter station facilities to lease delivery capacity to TGP. Because both
companies would construct facilities that are interdependent, we analyzed them jointly in one
EA.
This EA is an important and integral part of the Commission’s decision on whether to
issue TGP and National Fuel Certificates to construct, own, and operate the proposed
facilities. The principal purposes in preparing this EA are to:
identify and assess potential impacts on the natural and human environment that could
result from implementation of the proposed action;
identify and recommend reasonable alternatives and specific mitigation measures, as
necessary, to avoid or minimize project-related environmental impacts; and
facilitate public involvement in the environmental review process.
2.0 Purpose and Need
The purpose of TGP’s Project is to provide natural gas to the northeastern U.S. and
Eastern Canada. To accomplish this, TGP would lease 140,000 dekatherms per day of natural
gas capacity from National Fuel. TGP and National Fuel indicate that this capacity is needed
2 “We,” “us,” and “our” refer to environmental staff of the Office of Energy Projects.
3 A loop is a pipeline that is constructed adjacent to another pipeline, typically in the same right-of-way,
for the purpose of increasing capacity in this portion of the system.
2
due to increased demand for interstate natural gas transmission in the Northeastern U.S and
Eastern Canada from domestic production areas in Pennsylvania. Combined with the
reserved capacity on TGP’s system, TGP would provide a total of 158,000 dekatherms per
day.
Under section 7(c) of the NGA, the Commission determines whether interstate natural
gas transportation facilities are in the public convenience and necessity and, if so, grants a
Certificate to construct and operate them. The Commission bases its decisions on technical
competence, financing, rates, market demand, gas supply, environmental impact, long-term
feasibility, and other issues concerning a proposed project.
3.0 Proposed Facilities
TGP proposes to construct, own, and operate the Niagara Expansion Project (TGP’s
Project), combined with National Fuel’s proposed Northern Access 2015 Project (National
Fuel’s Project) which would enable it to lease capacity from National Fuel. TGP’s Project
consists of:
3.1 miles of 30-inch-diameter natural gas looping pipeline (Loop 224) along its
existing 200 Line in Chautauqua County, New York;
modifications at exiting Station 219 in Mercer County, Pennsylvania;
modifications, including a new pig4 receiver, at existing Station 224 in
Chautauqua County, New York; and
modifications to its existing Hamburg Meter Station in Erie County, New
York.
National Fuel’s Project consists of the following facilities:
construction of a new 15,400-horsepower (hp) compressor station (Hinsdale
Compressor Station) in Cattaraugus County, New York;
modifications at its existing Concord Compressor Station, including the
addition of 7,700 hp of compression in Erie County, New York; and
modifications at its existing East Eden Meter Station in Erie County, New
York.
Figures 1 and 2 show the locations of the projects. More detailed maps of the proposed
projects are found in Appendix A.
4 A “pig” is a tool that is inserted into and moves through the pipeline, and is used for cleaning the
pipeline, internal inspections, or other purposes.
Figure 1:
Niagara
Expansion
Project
3
4
Figure 2: Northern Access 2015 Project
5
4.0 Public Review and Comment
On April 11, 2014, FERC issued a Notice of Intent to Prepare an Environmental
Assessment for the Proposed Niagara Expansion Project and the Northern Access 2015
Project and Request for Comments on Environmental Issues (NOI). The NOI was mailed to
interested parties, including federal, state, and local officials; agency representatives; Native
American tribes; local libraries and newspapers; and property owners potentially affected by
the proposed facilities. This notice opened the scoping period for 30 days. Written comments
in response to the NOI were received from the New York State Department of Environmental
Conservation (NYSDEC), the Pennsylvania Natural Heritage Program (PNHP), the
Pennsylvania Fish and Boat Commission, and the Allegheny Defense Project (ADP). The
scoping comments we received pertained to cumulative impacts, and impacts on waterbodies,
state-listed species, and air quality. Comments received are addressed in the applicable
sections of the EA.
Request for an Environmental Impact Statement
In addition to the comments on the NOI, the ADP submitted comments on the
Commission’s Notice of Application for both TGP and National Fuel’s Project. ADP states
that the Commission should prepare an environmental impact statement (EIS) that covers all
pending projects related to shale gas extraction, including the TGP and National Fuel projects.
Pursuant to 18 CFR 380.6(a)(3) of the Commission’s regulations, an EIS will normally be
prepared for “major pipeline construction projects under section 7 of the NGA using right-of-
way in which there is no existing natural gas pipeline.” These regulations continue on, at 18
CFR 306(b), to state that “If the Commission believes that a proposed action may not be a
major federal action significantly affecting the quality of the human environment, an EA,
rather than an EIS, will be prepared first. Depending on the outcome of the EA, an EIS may
or may not be prepared.” In preparing this EA, we are fulfilling our obligation under the
NEPA to consider and disclose the environmental impacts of the proposed projects. As stated
in section D, the EA supports a finding of no significant impact; therefore, an EIS is not
required for these projects.
5.0 Permits, Approvals, and Regulatory Requirements
TGP and National Fuel state that they would obtain all necessary federal, state, and
local permits, licenses, and clearances related to construction of the proposed projects. TGP
and National Fuel would provide all relevant permits and approvals to the contractor who
would perform the construction activities associated with the projects; the contractor would be
required to be familiar with and adhere to applicable permit requirements.
Tables 1 and 2 identify the federal and state agencies that have relevant permitting
requirements along with the related permits required for the projects.
6
Table 1: Federal and State Permits, Approvals, and Consultations for TGP’s Project
Permit/Approval Administering Agency Status
Federal
Certificate of Public Convenience and
Necessity
Federal Energy Regulatory Commission
(FERC) Application filed February 28, 2014
Section 7 Endangered Species Act (ESA) U.S. Fish and Wildlife Service (FWS) Informal consultation response received
February 4, 2014
Section 404 of the Clean Water Act
(CWA) Joint Permit Application U.S. Army Corps of Engineers (COE) Application submitted February 2014
New York
Section 106, National Historic Preservation
Act (NHPA)
New York State Historic Preservation
Office (SHPO) Submitted March 2014
Joint Wetlands Permit Application with COE
New York State Department of
Environmental Conservation (NYSDEC)
Application submitted February 2014
Section 401 CWA Water Quality
Certification Previously issued March 19, 2012
State Pollution Discharge Elimination System Storm Water Permit
To be submitted prior to construction
State Pollution Discharge Elimination
System Hydrostatic Testing Permit To be submitted prior to construction
Water Withdrawal Permit To be submitted prior to construction
State-listed Threatened and Endangered
Species Clearance Submitted March 2014
Agricultural construction consultation New York State Department of
Agriculture and Markets Initiated November 2013
Pennsylvania
Request for Determination
Pennsylvania Department of
Environmental Protection (PADEP)
Submitted March 2014
National Pollution Discharge Elimination
System (NPDES) Storm Water Construction Permit
To be submitted prior to construction
State-listed Threatened and Endangered
Species Consultation
Pennsylvania Department of Conservation
and Natural Resources Completed January 14, 2014
State-listed Threatened and Endangered Species Consultation
Pennsylvania Game Commission Completed January 14, 2014
State-listed Threatened and Endangered
Species Consultation Pennsylvania Fish and Boat Commission Completed January 14, 2014
Section 106, National Historic Preservation Act
Pennsylvania Historic and Museum Commission
Submitted March 2014
7
Table 2: Federal and State Permits, Approvals, and Consultations for National Fuel's Project
Permit/Approval Administering Agency Status
Certificate of Public Convenience and Necessity FERC Application filed March 7, 2014
Section 7 Endangered Species Act (ESA) FWS Informal consultation initiated January
22, 2014
Section 404 Clean Water Act Nationwide Permit COE
Anticipated that no Pre-Construction
Notification would be required
because the impacts on wetlands are
less than 0.1 acre.
New York
Section 106, National Historic Preservation Act Office of Parks, Recreation, and Historic
Preservation
Consultation initiated January 13,
2014.
Section 401 Clean Water Act Water Quality
Certification
New York Department of Environmental
Conservation
Anticipated that no Pre-Construction
Notification would be required
because the impacts on Waters of the
U.S. are less than 0.1 acre.
National Pollution Discharge Elimination System
To be submitted prior to construction
State-listed Threatened and Endangered Species
Consultation
Clearance received December 18,
2013
State Facility Air Permit
Modification/Application Application submitted March 2014
6.0 Non-Jurisdictional Facilities
Under Section 7 of the NGA, the Commission is required to consider, as part of its
decision to approve facilities under Commission jurisdiction, all factors bearing on the public
convenience and necessity. Occasionally, proposed projects have associated facilities that do
not come under the jurisdiction of the Commission. These “non-jurisdictional” facilities may
be integral to the need for the proposed facilities, such as a power plant at the end of a
jurisdictional pipeline, or they may be minor, non-integral components of the facilities under
8
the Commission’s jurisdiction. We did not identify any non-jurisdictional facilities associated
with TGP’s or National Fuel’s projects.
7.0 Construction, Operation, and Maintenance Procedures
Both TGP’s and National Fuel’s proposed facilities would be designed, constructed,
tested, operated, and maintained in accordance with the U.S. Department of Transportation’s
(DOT) Minimum Federal Safety Standards presented in 49 CFR Part 192. The DOT’s
regulations are intended to ensure adequate protection for the public and to prevent natural
gas facility accidents and failures. Part 192 specifies material selection and qualification,
minimum design requirements, and protection from internal, external, and atmospheric
corrosion.
National Fuel would implement the construction procedures and mitigation measures
contained in its Erosion Sedimentation Control and Agricultural Mitigation Plan (ESCAMP).
National Fuel’s ESCAMP incorporates the Commission’s Upland Erosion Control,
Revegetation, and Maintenance Plan (Plan) and Wetland and Waterbody Construction and
Mitigation Procedures (Procedures)5. TGP would follow the construction procedures and
mitigation measures in the Commission’s Plan and Procedures with several alternative
measures (TGP’s Plan and Procedures). These alternative measures and site specific
justifications are shown in table 3 below. All of the alternative measures listed in table 3
involve placing an additional temporary workspace within 50 feet of a wetland or waterbody.
We reviewed these site-specific modifications and find that TGP provided sufficient
justification for each alternative measure. Further discussion of these site-specific alternative
measures and wetland and waterbody impacts are discussed in section B.2.
TGP would prepare and implement Spill Prevention and Response Procedures (SPRP)
which will specify measures for the prevention, containment, and clean-up of any accidental
spills of fuels or other hazardous materials. Similarly, National Fuel would implement its
SPRP for its project which we have reviewed and find acceptable.
TGP proposes to begin construction of the Niagara Expansion Project in February
2015 and anticipates placing the facilities in-service by November 1, 2015. For its project,
National Fuel plans to begin construction in the spring of 2015, and place the facilities into
service by November 1, 2015.
Pipeline Construction
TGP would utilize a 95-foot-wide temporary construction right-of-way (except in
wetlands), due to the diameter of the pipe, the steep terrain of the project area, and extra space
needed to safely construct adjacent to the existing 200 Line. This right-of-way width would
accommodate large construction equipment, pipe stringing and set up, welding, the trench,
5 Copies of the Plan and Procedures can be accessed on our website
(http://www.ferc.gov/industries/gas/enviro/guidelines.asp) or obtained through our Office of External
Affairs at 1-866-208-3372.
9
and the temporary storage of excavated topsoil and trench spoils. TGP would use a 75-foot-
wide right-of-way through wetlands. The entire construction right-of-way would be located
within TGP’s existing 150-foot-wide right-of-way easement6; therefore, TGP would not need
to acquire any new easements for construction of the pipeline. The new Loop 224 would be
offset from the 200 Line by 25 feet. During construction, the 25-foot space between the
pipelines would be used for spoil storage.
Additional temporary workspace would be required in agricultural areas where topsoil
segregation is required, at road crossings and some wetland and waterbody crossings, and at
the beginning and terminus of the pipeline.
TGP would maintain a 50-foot-wide permanent easement for Loop 224 during
operation of the project. This permanent right-of-way is located entirely within TGP’s
existing right-of-way. TGP’s Loop 224 would have a uniform design pressure and maximum
allowable operating pressure (MAOP) of 760 pounds per square inch gauge. The pipeline
would be constructed in accordance with DOT regulations and project specifications,
typically with a minimum of 36 inches of ground cover. However, additional cover may be
required at road crossings or other areas as necessary to maintain the integrity of the line.
Table 3: Additional Temporary Workspaces Within 50 Feet of a Wetland or Waterbody
Milepost Workspace Size (acres) Description Justification
3.01-3.03 0.45 Workspace overlaps 0.085 acre
of wetland
Needed to access the tie-in from
the pipeyard
3.01-3.03 0.06 Workspace within 10 feet and
17 feet of two wetlands
Multiple wetlands in the area,
limited space to work on tie-in
3.42-3.44 0.07 Workspace within 27 and 37
feet of two wetlands
Limited space available between
two wetlands
3.48-3.56 0.25 Workspace within 5 feet of
wetland
Limited space available between
two wetlands and waterbody crossing (boring)
3.49-3.56 0.61 Workspace within 5 feet of
wetland
Limited space available between
wetlands with waterbody crossing (boring)
3.53-3.56 0.24 Workspace within 5 feet of a
wetland
Needed for equipment parking,
and pipe and bore staging
3.60-3.62 0.03 Workspace overlaps 0.032 acre
of wetland
Workpace needed for bore pit
for crossing of French Creek
and road crossing
6 Typical right-of-way configurations are shown in TGP’s Resource Report 1 available accession number
20140221-5027.
10
Table 3: Additional Temporary Workspaces Within 50 Feet of a Wetland or Waterbody
Milepost Workspace Size (acres) Description Justification
4.04-4.09 0.27
Workspace within 5 feet of
waterbody (intermittent roadside ditch)
Due to existing wetlands and
waterbodies, area is needed for
bore pit, and construction entrance at public road (Marks
Road)
4.07-4.11 0.24
Workspace adjacent to
waterbody (intermittent roadside
ditch)
Due to existing wetlands and waterbodies, area needed for
bore pit, and construction
entrance at public road (Marks Road)
4.08-4.11 0.21
Workspace within one foot of
waterbody (intermittent roadside
ditch)
Needed for spoil storage and staging
4.08-4.10 0.06
Workspace within one foot of
waterbody (intermittent roadside
ditch)
Needed for spoil storage and staging
4.11-4.14 0.30 Workspace 40 feet of stream (intermittent roadside ditch)
Needed for topsoil storage
4.59-4.62 0.11 Workspace 16 feet from wetland Located at a pipeline crossover
for topsoil storage
6.05-6.14 1.68 Workspace 15 feet from
waterbody (intermittent roadside
ditch)
Needed to access the receiver site at the end of the loop for
spoil storage and pipe staging
Aboveground Facility Construction
The modifications at TGP’s existing Stations 219 and 224, including a pig launcher,
would be located within the existing facilties’ fencelines on land owned by TGP. The
Hamburg Meter Station is also located within the fenceline of Station 224. A pig receiver and
mainline valve would be located at the northern end of Loop 224.
Although the modifications at National Fuel’s Concord Compressor Station would be
expanded outside the fenceline of the station, they would be located immediately north of the
existing station facilities on land owned by National Fuel.
The new Hinsdale Compressor Station would be located on a parcel adjacent to
National Fuel’s Line X, an existing pipeline facility, on land that would be purchased from the
current landowners. National Fuel currently has an option to purchase the parcels proposed
for this facility.
At the existing East Eden Meter Station, National Fuel’s proposed modifications
would be located on land owned by both National Fuel and TGP.
11
Pipeyard/Staging Area
TGP proposes to use one temporary pipeyard/staging area near the beginning of Loop
224 during construction. This area would be used for the storage of pipe, equipment, and
materials; temporary field offices; pipe assembly and preparation; and soil storage. Upon
completion of the project, this area would be restored to pre-construction condition or in
accordance with landowner agreements.
Access Roads
TGP would use existing public and private access roads to access the construction
right-of-way and Stations 219 and 224. None of the existing access roads would require
modification or improvements. One new permanent access road would be required at the
terminus of Loop 224 to provide access to the new pig receiver facility.
Existing access roads would be used at National Fuel’s Concord Compressor Station
and East Eden Station for access during project construction. National Fuel would extend the
permanent access road at the Concord Compressor Station to the north of the existing facility,
but within National Fuel’s existing station boundaries. At the new Hinsdale Compressor
Station, a new permanent access road would be required to provide access to the station from
Phillips Road.
Additional Temporary Workspace
Additional temporary workspaces (ATWS) are typically required for pipeline
construction at road, railroad, wetland, and waterbody crossings; and areas that require special
construction techniques such as steep slopes. TGP would require a total of 9.04 acres of
ATWS for its Project. National Fuel does not propose any ATWS for its project.
8.0 Land Requirements
Construction of TGP’s Project would disturb 80.74 acres of land, of which 17.74 acres
would be permanently used for operation. The land requirements for the construction right-
of-way, ATWS, access roads, the pipeyard/staging area and the aboveground facilities are
summarized below in table 4.
Table 4: Land Requirements for TGP’s Project
Facility Construction (acres) Operation (acres)
Loop 224 54.01 15.69
Additional Temporary Workspace 9.04 0.00
Pipeyard/Staging Area 11.78 0.00
12
Table 4: Land Requirements for TGP’s Project
Facility Construction (acres) Operation (acres)
New pig receiver 0.17 0.17
New access road 0.09 0.09
Station 219 4.04 0.00*
Station 224/pig launcher 0.78 0.00*
Hamburg Meter Station 1.03 0.00*
Total 80.74 17.74
* No new land impacts would occur as a result of these facilities which be located within the existing fenceline of TGP’s aboveground
facilities.
Construction of National Fuel’s Project would disturb 39.02 acres of land, of which
17.65 acres would be permanently maintained during operation. The land requirements for
National Fuel’s Project are summarized in table 5 below.
Table 5: Land Requirements for National Fuel's Project
Facility Construction (acres) Operation (acres)
Concord Compressor Station 23.33 7.16
Hinsdale Compressor Station 13.24 9.18
East Eden Station 2.45 0.00*
TOTAL 39.02 17.65
* No new land impacts would occur as a result of these facilities which be located within the existing fenceline of TGP’s aboveground facilities.
13
B. ENVIRONMENTAL ANALYSIS
1.0 Geology and Soils
Geology
TGP’s proposed Loop 224 and its existing Station 224 lie within the Southern New
York Section of the Appalachian Plateaus Physiographic Province. This area is characterized
by steep valley walls with wide ridge tops and flat-bottomed valleys. Surficial materials
consist of Pleiostocene age glacial till underlain by upper Devonian shale, siltstone, and minor
beds of sandstone and sandstone conglomerate. Station 219 is located within the
Northwestern Glacial Section of the Appalachian Plateau Physiographic Province. This area
contains bedrock that is lower Pennsylvanian sandstone and limestone. The Hamburg Meter
Station is located within the Eastern Lake Section of the Central Lowlands Physiographic
Province. This area is characterized by surficial materials consisting of glacial till and
bedrock materials consisting of upper Devonian shale. The shale and siltstones that underlie
the area of Loop 224 have the potential to contain paleontological resources; however, the
potential is low.
TGP does not expect to conduct any blasting for construction of Loop 224 based on its
previous experience constructing in the project area and the soft nature of the bedrock
materials present. Pipeline construction would be completed using mechanical trenching
techniques. Due to the nature of the construction activities at the existing aboveground
facilities, blasting would not be required. In the unlikely event that blasting becomes
necessary, TGP would prepare a blasting plan and conduct blasting in accordance with
applicable federal, state, and local law.
No geologic hazards (e.g., seismic, soil liquefaction, landslides, subsidence) were
identified in the project areas. In addition, no mining operations were identified within the
vicinity of the TGP or National Fuel projects.
We conclude that the projects would have no significant impacts on local geological
conditions and would not be affected by any geologic hazards.
Soils
The existing aboveground facilities would impact previously disturbed and maintained
lands. After construction, all temporary workspaces would be stabilized and revegetated in
accordance with TGP’s Plan and National Fuel’s ESCAMP. Therefore, the impacts on soils
at these facilities would be minor.
Pipeline construction activities would result in temporary soil impacts that have the
potential to adversely affect soils include clearing, grading, trenching, and backfilling.
Potential impacts on soils include erosion due to the action of water, reduction of soil
productivity by mixing topsoil with subsoil, soil compaction and rutting due to heavy
equipment traffic, and contamination from spills. TGP and National Fuel would adhere to the
mitigation measures outlined in their Plan and ESCAMP which would minimize any potential
14
impacts of erosion during construction. These plans include the use of erosion and sediment
control devices such as silt fence, straw bales, and slope breakers.
In addition, TGP and National Fuel would implement their SPRPs which describe the
measures they would implement to prevent and if necessary, contain and control the
inadvertent spill of hazardous materials such as fuels, lubricants, and solvents. We have
reviewed National Fuel’s SPRP and find it acceptable.
Agricultural Land
TGP’s Loop 224 would temporarily impact 54.5 acres of prime farmland soils.
However, after construction, normal farming practices would be allowed to continue.
Therefore, there would be no permanent loss of prime farmland. At the compressor and meter
stations, 1.79 acres of prime farmland soils would be permanently impacted by the
aboveground facilities; however, this acreage is currently within the existing fence line of the
stations and has previously been removed from agricultural use.
Potential impacts on agricultural land include loss of soil fertility, disturbance of soil
surface, excessive soil compaction, the introduction of waste rock, and damage to drain tiles.
Topsoil segregation measures would be used in all actively cultivated lands, pastures, and
hayfields. TGP would segregate the topsoil from the ditch plus spoil side, unless requested by
a landowner or state agency. Topsoil and subsoil would be stored separately as required by
the Commission’s Plan. Agricultural areas would be reseeded in accordance with the
recommendations of the Chautauqua County Soil Conservation District or other applicable
agency.
Given that TGP and National Fuel would implement the construction procedures and
mitigation measures described above, we conclude that the Project would not have a
significant impact on soils.
The NYSDAM provided us with the following recommendations for mitigating the
impact of construction of TGP’s Loop 224 on agricultural lands in New York:
perform full width right-of-way topsoil segregation in active agricultural lands;
acquire the services of an agricultural inspector to oversee construction and restoration
in agricultural areas;
follow the NYSDAM’s Construction, Restoration, and Follow-up Monitoring
Guidelines for Pipeline Right-of-Way Construction Projects (Rev. 2/11); and
follow the NYSDAM’s Fertilizing, Lime, and Seeding Recommendations for the
Restoration of Construction Projects on Farmland in New York State.
15
These mitigation measures vary from what has been proposed by TGP and what our
Plan requires. Therefore, we recommend that:
Prior to construction, TGP should complete its consultation with the
NYSDAM regarding impacts on agricultural lands, and file with the
Secretary documentation of this consultation and any additional
mitigation measures TGP plans to incorporate in its project design.
2.0 Water Resources and Wetlands
2.1 Groundwater
TGP’s proposed Loop 224 and Station 224 are located within the French Creek
Watershed, Station 219 is located within the Shenango Watershed, and the Hamburg Meter
Station is located within the Buffalo-Eighteenmile Watershed. No principal regional aquifers
are located within any of the areas affected by TGP’s Project. In addition, there are no U.S.
Environmental Protection Agency (EPA)-designated sole source aquifers in the areas affected
by TGP’s or National Fuel’s Projects.
TGP and National Fuel reviewed state water well data to determine the location of any
water wells in the vicinity of their projects’ facilities. No domestic water wells were
identified within 400 feet of TGP’s proposed Loop 224, Station 224 or the Hamburg Meter
Station. In addition, the Chautauqua County Health Department did not identify any public
water wells within 400 feet of the pipeline. TGP identified 11 water wells within 400 feet of
its existing Station 219. These wells are designated for various uses including domestic and
commercial. TGP has committed to offer pre- and post-construction wells testing for owners
of wells within 150 feet of its facilities.
National Fuel did not identify any public water supply wells within one mile of its
project. However, the Concord Compressor Station has an existing water well that services
the facility. Two wells were identified on the proposed Hinsdale Compressor Station site.
National Fuel states that these wells could be located within 150 feet of the project facilities
once the final layout of the station is determined. National Fuel would purchase the property
for the compressor station and would then assume ownership of these wells; therefore, we
determined that testing of the wells would not be required.
Construction, operation, and maintenance activities associated with the Project have
the potential to impact groundwater. Short-term effects include alteration of overland flow
and groundwater recharge resulting from clearing of vegetation, grading, and trenching
activities and potential spills and leaks of fuels into shallow groundwater aquifers. TGP has
committed to preparing a SPRP during construction which would specify measures to prevent
and clean up any accidental spills of fuels or hazardous materials. In addition, TGP’s Plan
and Procedures would avoid or minimize impacts on groundwater. National Fuel’s
implementation of its ESCAMP, which incorporates the Commission’s Plan and Procedures
as well as National Fuel’s own best management practices, would also minimize potential
impacts on groundwater.
16
Based on the commitments of TGP and National Fuel discussed above, we conclude
that the Project would not have a significant impact on groundwater resources.
2.2 Surface Water Resources
Based on field surveys of the pipeline route, Loop 224 would cross eight waterbodies
and one additional waterbody would be crossed by an access road. None of TGP’s proposed
aboveground facilities would impact waterbodies. These waterbodies are listed in table 6
below.
TGP would cross three waterbodies using a bore which would avoid direct impacts on
them. A bore crossing involves digging a pit on either side of the waterbody and installing
the pipeline under the waterbody without any disturbance to the waterbody. The remaining
six waterbodies would be crossed using an open-cut construction method. TGP would use a
dry crossing construction technique (e.g., dam and pump or flume) for all waterbodies with a
discernable flow at the time of crossing. A flume crossing involves diverting the flow of
water across the construction work area through one or more flume pipes placed in the
waterbody. The trenchline would be isolated and pumped dry, allowing construction crews to
excavate and install the pipe. The dam and pump crossing involves using pumps and hoses to
move water around the construction area. A prefabricated section of pipe would be promptly
lowered into the trench which would be backfilled with the excavated spoil. Streambanks
would be re-established to pre-construction contours and stabilized.
Two intermittent streams are located at National Fuel’s Concord Compressor Station.
Both of the streams flow under the permanent gravel access road for the facility through
plastic corrugated pipe. Construction activities at the Concord Compressor Station would not
have any new impacts on these streams. Any direct impacts on nearby waterbodies would be
minimized by the use of erosion controls in accordance with National Fuel’s ESCAMP.
A 384-foot-long intermittent stream on the Hinsdale Compressor Station site would be
relocated to the west of the new station. This would be completed in accordance with the
COE’s permit conditions. Construction activities at the Hinsdale Compressor Station would
be conducted in accordance with National Fuel’s ESCAMP. This plan includes measures
such as silt fence and hay bales to prevent off site erosion impacts, including impacts on the
intermittent stream on the site.
Table 6: Waterbodies Impacted by TGP's Niagara Expansion Project
Milepost Type Crossing Width (feet) Crossing method
3.59 Perennial 50 Conventional bore
4.10 Intermittent 5 Conventional bore
4.17 Intermittent 5 Conventional bore
4.63 Perennial 8 Open-cut
4.83 Intermittent 5 Open-cut
5.12 Intermittent 6 Open-cut
17
Table 6: Waterbodies Impacted by TGP's Niagara Expansion Project
Milepost Type Crossing Width (feet) Crossing method
5.61 Intermittent 6 Open-cut
5.88 Intermittent 5 Open-cut
6.14 (Access road #5) Intermittent 1 Open-cut
French Creek (milepost 3.59) was identified as a significant natural community by the
NYSDEC. However, TGP proposes to cross French Creek using a conventional bore method
to avoid impacts on this waterbody.
Impacts on surface waters include an increase in sediment loading and turbidity. This
would primarily result from clearing and grading of the stream banks, installation of the flume
pipes and construction of dams, and loosening of the streambed soil from trenching and
backfilling. These impacts would be temporary and limited to the construction period.
The NYSDEC expressed concerns regarding maintaining stream flows during
construction. As discussed above, TGP and National Fuel would adhere to the requirements
of the Commission’s Procedures which would ensure that stream flows are maintained during
waterbody crossings.
Given TGP’s proposed methods for crossing surface waters and the implementation of
the measures contained in TGP’s Procedures and National Fuel’s ESCAMP, we conclude that
the Project would not have a significant impact on surface waters.
2.3 Wetlands
TGP identified wetlands in the project area using field wetland delineations.
Construction of its project would temporarily impact 3.75 acres of wetlands, of which 0.32
acre would be permanent. The impacts on wetlands from TGP’s project include 2.6 acres of
palustrine emergent wetlands, 0.78 acre of palustrine scrub-shrub wetlands, and 0.15 acre of
palustrine forested wetlands. National Fuel identified wetlands in the project area using field
wetland delineations. Construction of its project would temporarily impact 0.37 acre of
palustrine emergent wetlands, of which 0.07 acre would be permanently affected.
Impacts on wetlands from construction include alteration of wetlands vegetation due
to clearing, the mixing of subsoil and topsoil due to rutting, and compaction of soil.
Construction within wetlands could also impact water quality due to sediment loading or
accidental spills of fuels or chemicals from construction equipment.
TGP would use a 75-foot-wide construction right-of-way in wetlands in accordance
with its Procedures for the wetland crossings to minimize impacts. Other protective measures
include restricting equipment use within wetland areas, cutting vegetation just above ground
level and leaving root systems intact, and installing temporary sediment barriers along
wetland boundaries. The impacts on herbaceous and scrub-shrub wetlands would be
temporary because herbaceous vegetation is likely to fully regenerate within one or two
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growing seasons. Construction of the Project would affect 0.52 acre of forested wetland.
After construction, 0.34 acre of forested wetlands would be allowed to revert to previous use
and 0.18 acre of forested wetlands would be converted and maintained in an herbaceous state.
However, the affected wetlands would continue to provide important ecological functions.
Therefore, we conclude that the Project would not have a significant impact on wetlands.
2.4 Hydrostatic Testing
To ensure the integrity of the pipeline facilities before placing them into service, TGP
and National Fuel would conduct hydrostatic testing. Hydrostatic testing involves filling the
pipeline with water, pressurizing it, and then checking for pressure losses due to water
leakage. TGP anticipates obtaining the necessary permits to withdraw water for the
hydrostatic test from French Creek. However, if this is not permitted, TGP would obtain the
hydrostatic test water from a local municipal water source. National Fuel proposes to obtain
its hydrostatic test water from a municipal or private well which would be trucked to the
facilities. In its May 19, 2014 data request response, National Fuel indicated the possibility of
withdrawing water from a stream near the Hinsdale Compressor Station site for
hydrostatically testing that facility. If this option is used, National Fuel would adhere to the
requirements of its ESCAMP, including screening the intake to prevent the entrainment of
fish.
TGP and National Fuel would discharge hydrostatic test water to well vegetated
upland sites in accordance with the requirements of TGP’s Procedures, National Fuel’s
ESCAMP, and any applicable permit conditions. Erosion would be minimized through the
use of energy dispersing devices (such as filter bags and straw bale structures) during
discharges that would disperse and slow the velocity of hydrostatic test water releases. Table
7 identifies which facilities would be hydrostatically tested and summarizes the volumes of
hydrostatic test water that would be required for each facility.
Table 7: Hydrostatic Test Water Requirements for the Projects
Facility Source Volume (gallons) Discharge Location
TGP’s Niagara Expansion Project
Loop 224 French Creek 600,000 Well vegetated upland areas
near mileposts 3.5 and 3.57
National Fuel’s Northern Access 2015 Project
Concord Compressor Station Municipal or Private Well 25,000 Well vegetated upland area at
the compressor station site
Hinsdale Compressor Station Municipal or Private Well, or
Stream 10,000
Well vegetated upland area at the compressor station site
East Eden Station Municipal or Private Well 5,000 Well vegetated upland area at
the meter station site
19
3.0 Vegetation and Wildlife
3.1 Vegetation
TGP’s Loop 224 crosses wetlands and forested, shrub/scrub, agricultural, and
developed lands. Stations 219 and 224 and the Hamburg Meter Station are covered by low-
growing herbaceous vegetation and gravel.
National Fuel’s Concord Compressor Station and East Eden Station sites consist of
low-growing grasses that are maintained by mowing. Vegetation at the Hinsdale Compressor
Station site consists of herbaceous vegetation and some shrubs.
Pipeline construction would impact vegetation by cutting, clearing, and removing
vegetation within the temporary construction right-of-way. The temporary construction right-
of-way is co-located with TGP’s existing 200 Line for its entire length which would minimize
the impacts on vegetation by utilizing the existing operational right-of-way.
After construction is complete, much of the temporary workspace for Loop 224 would
be reseeded and allowed to revert to pre-construction conditions. On Loop 224, 8.43 acres of
forest would be cleared for construction within TGP’s existing 150 foot right-of-way, with a
total of 2.90 acres of forest lost within the permanent right-of-way where ongoing
maintenance during operation would preclude the re-establishment of trees. During operation,
tree species would be allowed to regrow in areas outside of the permanent operation
easement. Impacts on vegetation vary from short-term to long-term, depending on the
vegetation type. The impacts on agricultural land would be short-term because the land could
continue to be used within one to two growing seasons. The impacts on forested lands would
be considered long-term due to the time required to re-establish mature trees.
Given the lack of sensitive vegetation types and TGP’s and National Fuel’s
commitment to restoring areas affected by construction in accordance with TGP’s Plan and
Procedures and National Fuel’s ESCAMP, we conclude that the projects’ impacts on
vegetation would be temporary and adequately reduced with appropriate measures.
3.2 Wildlife
The majority of impacts on wildlife would be associated with Loop 224 and the new
Hinsdale Compressor Station. Most of the aboveground facilities are not extensively utilized
by wildlife due to the existing infrastructure and human activity. Some species that are able
to adapt to these environments such as white-tailed deer and garter snake are common.
Forested areas affected by Loop 224 provide habitat for a variety of bird and large mammal
species including white-tailed deer. In addition, forested areas provide habitat for
invertebrates, amphibians, reptiles, and smaller mammals. Common species include
American toad, spotted salamander, eastern chipmunk, and gray squirrel. The Hinsdale
Compressor Station site is an old successional field consisting of grasses, shrubs, and some
saplings which provide habitat for species such as groundhogs and opossum.
20
Potential impacts on wildlife include habitat removal and construction-related ground
disturbance and noise. In general, construction of the proposed projects is expected to have
minor, short-term impacts on wildlife. During construction, clearing and grading of the
construction workspaces would result in loss of vegetative cover and significant disturbance
to soils. Some non-mobile, small, or nesting individuals could be inadvertently injured or
killed by construction equipment. However, more mobile species such as birds and mammals
would likely relocate to other nearby suitable habitat and avoid the project area due to
construction noise and ground vibrations.
Following construction, wildlife would return to the project areas and resume normal
activities. The temporary disturbance of local habitat is not expected to have population-level
effects on wildlife because much of the project area would return to preconstruction
condition. Long-term impacts from habitat alteration would be minimized by the
implementation of measures contained in TGP’s Plan and National Fuel’s ESCAMP which
ensure that all areas temporarily disturbed by construction would be revegetated. Therefore,
we conclude that the projects would not have a significant impact on wildlife.
Migratory Birds
Migratory birds are species that nest in the United States and Canada during the
summer and make short- or long-distance migrations for the non-breeding season.
Neotropical migrants migrate to and from the tropical regions of Mexico, Central and South
America, and the Caribbean.
Migratory birds, including raptors and non-raptors species, are protected under the
Migratory Bird Treaty Act (16 U.S. Code 703-711). Bald Eagles and Golden Eagles are
additionally protected under the Bald and Golden Eagle Protection Act (16 U.S. Code 668-
668d). The Migratory Bird Treaty Act, as amended, prohibits the taking, killing, possession,
transportation, and importation of migratory birds, their eggs, parts, or nests unless authorized
under a U.S. Fish and Wildlife Service (FWS) permit. Executive Order 13186 directs federal
agencies to avoid and minimize impacts on migratory bird resources when conducting agency
actions; evaluate effects of actions on migratory birds; identify where unintentional take is
likely to have a measurable negative effect on migratory bird populations and avoid or
minimize adverse impacts on migratory birds through enhanced collaboration with the FWS;
and emphasizes species of concern, priority habitats, and key risk factors, and that particular
focus should be given to population-level impacts.
On March 30, 2011, the FWS and FERC entered into a Memorandum of
Understanding Between the Federal Energy Regulatory Commission and the U.S. Fish and
Wildlife Service Regarding Implementation of Executive Order 13186, “Responsibilities of
Federal Agencies to Protect Migratory Birds that focuses on avoiding or minimizing adverse
impacts on migratory birds and strengthening migratory bird conservation through enhanced
collaboration between FERC and the FWS by identifying areas of cooperation. This
voluntary Memorandum of Understanding does not waive legal requirements under the
Migratory Bird Treaty Act, the Endangered Species Act, the Federal Power Act, the NGA, or
any other statutes and does not authorize the take of migratory birds.
21
The primary potential impact on migratory birds from construction of the projects is
the clearing of nesting habitat. TGP plans to complete tree clearing in February 2015, which
is outside of the nesting season for migratory birds (generally April 1-August 31). National
Fuel proposes to begin construction in the spring of 2015. This would allow for clearing of
any potential nesting habitat early in the nesting season; however, the areas affected by
construction of National Fuel’s facilities provide limited habitat for migratory birds.
Some indirect impacts caused by construction activity and noise could occur during
the construction period. Some individuals may leave the project area as construction
activities commence and relocate to available habitat nearby. Vegetation removal would
result in the decrease in the amount of available cover, nesting, and foraging habitat; however,
this impact would not be significant due to the co-location of the majority of the facilities.
Given the timing of construction and the co-location with existing facilities, we
conclude that the projects would not have a significant impact on migratory birds.
3.3 Fisheries
TGP’s Project crosses nine waterbodies, all of which are classifies as warmwater
fisheries. Representative fish species include smallmouth bass, largemouth bass, bluegill,
brown bullhead, and rock bass. As mentioned in section B.2.2, French Creek was identified
as a significant natural community by the NYSDEC. However, due to TGP’s proposal to bore
French Creek, direct impacts would be avoided.
National Fuel’s Concord Compressor Station and East Eden Station do not affect any
waterbodies. In addition, the intermittent stream on the Hinsdale Compressor Station site
does not support any fish species.
The projects would not cross any waterbodies designated as wild and scenic rivers. In
addition, we determined that there are no threatened or endangered species in any of the
waterbodies crossed. TGP would adhere to timing restrictions in accordance with its
Procedures and any applicable agency restrictions. As such, we conclude that the projects
would not have a significant impact on fisheries.
3.4 Special Status Species
Special status species are those species for which state or federal agencies provide an
additional level of protection by law, regulation, or policy. Included in this category are
federally listed species that are protected under the Endangered Species Act (ESA) or are
considered as candidates for such listing by the FWS, federal species of concern, those
species that are state-listed as threatened or endangered, and state species of concern.
Information on the species potentially occurring in the project areas is presented in table 8
below.
22
Table 8: Federally-listed Status Species Potentially Occurring in the Project Areas
Common Name Federal Status
Northern long-eared bat (mammal) Proposed-Endangered
Rayed bean (mussel) Endangered
Clubshell (mussel) Endangered
Federally-listed Species
In accordance with section 7 of the ESA, the FERC, in coordination with the FWS,
must ensure that any federal action authorized, funded, or carried out by the agency does not
jeopardize the continued existence of a federally listed threatened or endangered species or
result in an adverse modification of the designated critical habitat of a federally listed species.
TGP, as a non-federal representative to the FERC, initiated informal consultation with
the FWS to determine if any federally listed species potentially occur within the project area.
The northern long-eared bat, rayed bean, and clubshell, were identified as occurring within
the project area. In correspondence dated January 28, 2014, the FWS requested that tree
clearing be conducted in the winter months to avoid impacts on the northern long-eared bat.
TGP proposes to conduct tree clearing in February, which complies with the FWS’
recommendation. Therefore, we conclude that TGP’s Project is not likely to adversely affect
the northern long-eared bat.
The FWS also indicated that the two mussel species (rayed bean and clubshell) may be
found in French Creek and recommended boring under French Creek to avoid impacts on
these species, which TGP has proposed. However, TGP has proposed to withdraw water from
French Creek for the hydrostatic testing of Loop 224. Due to the presence of federally listed
mussel species in French Creek, we recommend that:
Prior to construction, TGP should provide documentation of FWS
approval for the withdrawal of hydrostatic test water from French Creek
or provide an alternate source of hydrostatic test water.
We conclude that implementation of this recommendation and the other measures
identified by TGP would avoid or minimize impacts on mussel species in French Creek.
Therefore, we conclude that TGP’s Project is not likely to adversely affect the rayed bean and
clubshell.
National Fuel conducted a search of the FWS’ online database to determine if any
federally-listed species would be impacted by its project. In addition, National Fuel contacted
the FWS in a letter dated January 22, 2014. The database identified the northern long-eared
bat, rayed bean, and clubshell as potentially occurring within its project area. Due to the lack
of suitable habitat for these species, we conclude that National Fuel’s Project would have no
effect on the northern long-eared bat, rayed bean, and clubshell.
23
Because of our determination of not likely to adversely affect for the northern long-
eared bat, rayed bean, and clubshell, we are requesting the FWS to consider this EA as our
biological assessment for these proposals and request concurrence within 30 days of issuance
of the EA.
State-listed Species
National Fuel conducted a review of the NYSDEC online database to determine if any
state-listed species would be impacted by its project. No species of concern were identified in
the area of the Concord Compressor Station or the East Eden Station. Five aquatic species
[hellbender (fish), rayed bean (mussel), silver shine (fish), Ohio lamprey (fish), and
pocketbook mussel)] were identified as potentially occurring in the area of the Hinsdale
Compressor Station. However, due to the lack of suitable habitat, these species would not be
impacted by the project.
TGP consulted with the NYSDEC regarding potential impacts on state-listed species.
One species, the state threatened spotted darter, was identified. The spotted darter is only
found within French Creek, which is crossed by Loop 224. As previously discussed, TGP
would cross French Creek using a conventional bore method to avoid impacts on this
waterbody. The PNHP submitted comments dated March 20, 2014 stating that TGP’s Project
would not impact any species under its jurisdiction. In addition, the Pennsylvania Fish and
Boat Commission, in its comments dated January 23, 2014, confirmed that TGP’s Project
would not impact any species under its jurisdiction. TGP’s search of the PNHP online
database indicated that no further review for the Pennsylvania Department of Conservation
and Natural Resources.
Based on the discussion above, we conclude that the TGP and National Fuel projects
would not affect any state-listed species.
4.0 Land Use, Recreation, and Visual Resources
Construction of TGP’s Project would disturb 59.86 acres, of which 20.72 would be
permanent for the operational right-of-way for the pipeline and additional permanent
aboveground facilities. The remainder (18.06 acres) would be restored in accordance with
TGP’s Plan.
No residential or commercial areas, recreational areas or parks were identified in the
vicinity of the projects.
Loop 224 crosses a variety of land uses including agricultural, open land, rangeland,
wetlands, and forested land. Loop 224 would be constructed within TGP’s existing right-of-
way using a 95-foot-wide construction workspace, which includes 25 feet of operational right-
of-way adjacent to the existing 200 Line, 25 feet of new operational right-of-way and 25-45
feet of temporary workspace. The construction right-of-way would be only 75 feet wide in
wetlands. The construction right-of-way would accommodate pipe stringing and welding,
large equipment, the pipeline trench, and temporary storage of topsoil and trench spoil. TGP
proposes to use 9.04 acres as ATWS at wetlands/waterbodies, steep side slopes, and road
24
crossings. While TGP would primarily use existing public roads to access the pipeline route,
five non-public roads (one new, four existing) would be required.
Work at existing stations 219, 224 and the Hamburg Meter Station would impact
industrial land. All temporary workspace and the new aboveground facilities would be
located adjacent to TGP’s existing compressor and meter stations. Table 9 below summarizes
the land use types impacted by the project.
Table 9: Summary of Land Use Impacts for TGP’s Project
Land Use Temporary Impact (acres) Permanent Impact (acres)
Agricultural 29.26 5.65
Industrial 0.19 0.00
Open Land 9.45 5.44
Open Water 0.08 0.02
Rangeland 2.53 0.91
Wetland 4.07 0.77
Forested 8.43 2.90
Total 54.01 15.69
National Fuel’s Project would impact 39.02 acres, of which 17.65 acres would be
permanent for the operation of the aboveground facilities. The remaining 21.37 acres would
be restored in accordance with National Fuel’s ESCAMP.
Construction of the new Hinsdale Compressor Station would impact primarily open
land and a minor amount of wetlands. The modifications at the Concord Compressor Station
and the East Eden Station would impact forested, open land, and industrial land. The land use
impacts associated with National Fuel’s Project are shown in table 10 below.
Table 10: Summary of Land Use Impacts for National Fuel's Project
Land Use Temporary Workspace (acres) Permanent Workspace (acres)
Forested 1.21 0.00
Open Land 30.68 11.39
Industrial 6.69 6.19
Wetlands 0.44 0.07
Visual Resources
The majority of the proposed facilities are co-located with existing infrastructure.
During construction, the expansion of this infrastructure would be the most noticeable due to
the increased activity, construction equipment, and ground disturbance. Construction would
have some minor and temporary visual impacts; however, the right-of-way and temporary
workspaces would be restored immediately after construction. In addition, the visual impacts
25
of most of the aboveground facilities, although permanent, would be minor due to their co-
location with other facilities.
The potential for visual impacts during operation of the projects would be limited to
the Hinsdale Compressor Station because it is a new facility. Although there are some trees
surrounding the parcel, this facility would be visible from the adjacent roadways (west, east,
and south) and some homes (southwest). However, the site for this facility is adjacent to an
existing pipeline right-of-way, a major highway, and railroad. Because of the amount of
existing infrastructure in the project area, the Hinsdale Compressor Station is not expected to
have a significant impact on the landscape.
5.0 Cultural Resources
Section 106 of the National Historic Preservation Act (NHPA), as amended, requires
the Commission to take into account the effects of its undertakings (including the issuance of
Certificates) on properties listed or eligible for listing on the National Register of Historic
Places, and to afford the Advisory Council on Historic Preservation (ACHP) an opportunity to
comment on the undertaking. TGP and National Fuel provided us with information, analyses,
and recommendations necessary to complete the process of complying with Section 106, as
allowed by the ACHP’s implementing regulations at 36 CFR Part 800.2(a)(3), and outlined in
our Guidelines for Reporting on Cultural Resources Investigations for Pipeline Projects
(Office of Energy Projects Cultural Resources Guidelines, December 2002, as specified in 18
CFR Part 380.12(f)).
Consultations
We sent copies of our NOI for this project to a wide range of stakeholders, including
the ACHP, U.S. Department of the Interior National Park Service, New York State Office of
Parks, Recreation and Historic Preservation (NYHP), Pennsylvania Historical and Museum
Commission (PHMC), and Indian tribes that may have an interest in the project area. The
NOI contained a paragraph about Section 106 of the NHPA, and stated that we use the notice
to initiate consultations with the State Historic Preservation Officer (SHPO) 7
, and to solicit
their views and those of other government agencies, interested Indian tribes, and the public on
the project’s potential effects on historic properties.
Federally Recognized Indian Tribes
TGP contacted 15 federally recognized Indian tribes regarding the project in letters
dated December 27, 2013. These tribes were the Absentee-Shawnee Tribe of Oklahoma, the
Cayuga Nation, the Delaware Nation of Oklahoma, the Delaware Tribe of Indians, the Eastern
Shawnee Tribe of Oklahoma, the Oneida Nation, Oneida Tribe of Indians in Wisconsin,
Onondaga Indian Nation, the Saint Regis Mohawk Tribe, the Seneca Nation of Indians, the
Seneca-Cayuga Tribe of Oklahoma, the Shawnee Tribe of Oklahoma, the Stockbridge-
Munsee Band of the Mohicans, Tonawanda Seneca Nation, and the Tuscarora Nation. In a
7 The SHPO is represented by the NYHP in New York and by the PHMC in Pennsylvania.
26
letter dated January 8, 2014, the Delaware Tribe of Indians responded that they looked
forward to the results of the archaeology survey and requested to be notified if an
unanticipated discovery was encountered. In a response dated January 10, 2014 the Eastern
Shawnee of Oklahoma did not object to the project and requested to be notified if an
unanticipated discovery was encountered.
National Fuel contacted two federally recognized Indian tribes regarding the project.
Letters were sent to the Tonawanda Band of Seneca Indians of New York dated January 13,
2014, and May 16, 2014. Also the Seneca Nation of Indians was contacted in a letter dated
May 15, 2014. No response letters have been filed.
Other Consulting Parties
TGP also contacted the Cherokee Nation of New Jersey, Nanticoke Lenni-Lenape of
New Jersey, Powhatan Renape Nation in a letter dated December 27, 2013. No responses
have been filed.
Survey Results
TGP’s cultural resource survey consisted of reviewing approximately 153 acres. The
direct APE for the project is about 54 acres and consists of the proposed loop corridor,
temporary workspaces, access roads and pipeyard. The indirect APE is considered the line-
of-site visibility to the project’s surroundings and that consisted of a 0.5-mile radius of the
project. Two cultural resources were identified during the survey. The resources encountered
were one prehistoric lithic area (NE-E71) whose period of use is unknown and a
multicomponent site of unknown prehistoric occupation and a historic era residence. Neither
of the resources was recommended for further testing and both were considered ineligible for
listing on the National Register of Historic Places. We agree.
National Fuel’s survey consisted of reviewing approximately 47 acres. The APE for
the project is about 39 acres and consists of the proposed temporary workspaces at the
Concord and Hinsdale Compressor stations. Although cultural resources were encountered,
no archaeological sites or historic structures were identified during the investigations.
However, alluvial deposits are present within the proposed Hindale Compressor project area.
Archaeological deep testing was recommended if the area could not be avoided.
State Historic Preservation Officers
TGP submitted a letter dated November 11, 2013, to the New York SHPO, to inform
them of its project. The SHPO responded in an email dated November 17, 2013, providing
cultural resources information in the area of potential effects (APE). In a letter dated
February 7, 2014, TGP submitted a survey report to the SHPO for review and comment. In a
response dated March 1, 2014, the New York SHPO stated that TGP’s Project would have no
effect on historic properties
TGP submitted a letter dated January 14, 2014, to the Pennsylvania SHPO, to inform
them of its project and requested to utilize the Categorical Clearance Agreement between
27
TGP and the Pennsylvania SHPO. The Pennsylvania SHPO responded in a letter dated
January 17, 2014, stating there were no historic properties within the APE.
National Fuel submitted a letter dated January 13, 2014, to the New York SHPO, to
inform them of its project. In a letter dated February 24, 2014, National Fuel provided the
cultural resources survey report to the SHPO for review and comments. The SHPO
responded, in an email dated April 18, 2014, that they had no further concerns with the
Concord Compressor Station APE or the East Eden Meter Station. However, National Fuel
would need to demonstrate that construction at Hinsdale Compressor Station would not be
below 1 meter within the 6 acre parcel noted as Archaeologically Sensitive Deep Holocene
Alluvium within the survey report. In an email dated May 6, 2014, National Fuel could not
demonstrate limited depth disturbance and proposed to conduct archaeological deep testing.
Unanticipated Discovery Plans
TGP included unanticipated discovery plans (UDP) for New York and Pennsylvania
as Appendix 4D attached to the Environmental Reports included with its application to the
FERC. Revised UDPs were filed on May 19, 2014 and sent to the appropriate SHPO for
review and comments in letters dated April 30, 2014. TGP has not filed the comments of the
New York or Pennsylvania SHPO on the UDP; however, we found the plans acceptable.
National Fuel included an UDP as Appendix 4C attached to the Environmental
Reports included with its application to the FERC. A revised UDP was filed on May 19,
2014, and sent to the SHPO for review and comment in letters dated May 16, 2014. National
Fuel has not filed the comments of the SHPO on the UDP; however, we found the plan
acceptable.
Compliance with the National Historic Preservation Act
TGP consulted with the New York and Pennsylvania SHPO regarding the potential
effects to cultural resources. The SHPOs did not object to the APE and concurred that no
historic properties would be affected.
No traditional cultural properties or properties of religious or cultural importance to
Indian tribes have been identified by TGP, its consultants, the SHPOs, or the tribes contacted
by the applicant. The FERC staff and the New York and Pennsylvania SHPO agree that the
project would have no effects on historic properties.
For National Fuel’s Project, compliance with section 106 of the NHPA has not been
completed. To ensure that the FERC’s responsibilities under NHPA and its implementing
regulations are met, we recommend that:
National Fuel should not begin construction of facilities and/or use of any staging,
storage, or temporary work areas and improved access roads until:
a. National Fuel files with the Secretary of the Commission (Secretary):
28
i. remaining cultural resources survey reports and addendums;
ii. site evaluation reports and avoidance/treatment plans, as required;
and
iii. comments on the cultural resources reports, addendums and plans
from the New York SHPO;
b. the ACHP is afforded an opportunity to comment if historic properties
would be adversely affected; and
c. the FERC staff reviews and the Director of the Office of Energy Projects
(OEP) approves the cultural resources reports and plans, and notifies
National Fuel in writing that treatment plans/mitigation measures
(including archaeological data recovery) may be implemented and/or
construction may proceed.
All materials filed with the Commission containing location, character, and
ownership information about cultural resources must have the cover and any
relevant pages therein clearly labeled in bold lettering: “CONTAINS
PRIVILEGED INFORMATION - DO NOT RELEASE.”
6.0 Air Quality and Noise
6.1 Air Quality
Air quality can be affected by both construction and operation of the proposed
facilities. The EPA has established National Ambient Air Quality Standards (NAAQS) for
criteria pollutants for the purpose of protecting human health (primary standards) and public
welfare (secondary standards). The EPA set NAAQS for the following air contaminants
designated as “criteria pollutants”: nitrogen dioxide (NO2), carbon monoxide (CO), ozone
(O3), sulfur dioxide (SO2), lead, particulate matter with an aerodynamic diameter less than or
equal to 10 microns (PM10), and particulate matter with an aerodynamic diameter less than or
equal to 2.5 microns (PM2.5). These NAAQS reflect the relationship between pollutant
concentrations and health and welfare effects, and are supported by sound scientific evidence.
The states implement and enforce the NAAQS through State Implementation Plans (SIP),
which must be approved by the EPA. The state of New York implements its SIP through the
NYSDEC. Pennsylvania implements its SIPs through the Pennsylvania Department of
Environmental Protection (PADEP).
Air quality control regions (AQCR) are areas established for air quality planning
purposes in which SIPs describe how ambient air quality standards would be achieved and
maintained. AQCRs were established by the EPA and local agencies, in accordance with
section 107 of the Clean Air Act of 1970 and its amendments (CAA), as a means to
implement the CAA and comply with the NAAQS through SIPs. The CAA is the basic
federal statute governing air pollution. AQCRs are intra- and interstate regions such as large
metropolitan areas where improvement of the air quality in one portion of the AQCR requires
emission reductions throughout the AQCR. Each AQCR, or portion thereof, is designated
29
based on compliance with the NAAQS. AQCR designations fall under three categories as
follows: “attainment” (areas in compliance with the NAAQS), “non-attainment” (areas not in
compliance with the NAAQS), or “unclassifiable/ attainment” (areas that cannot be classified
on the basis of available information as meeting or not meeting the NAAQS). Areas in
nonattainment with the NAAQS for any criteria pollutant are held to more restrictive air
emissions limits when determining whether the facility is a major source under federal
programs.
An Ozone Transport Region (OTR) is a region where the transfer of air pollutants
from one or more states contributes significantly to a violation of the NAAQS in one or more
other states.8 The Northeast OTR is comprised of eleven northeastern states, including New
York and Pennsylvania. Ozone forms when there is a reaction between nitrogen oxides (NOx)
and volatile organic compounds (VOC); as a result, O3 formation cannot be directly
controlled. Limiting NOx and VOC emissions would result in a lower potential for O3
formation.
In New York, Cattaraugus and Chautauqua Counties are within AQCR 164 - Southern
Tier West Intrastate AQCR and Erie County is within AQCR 162 - Niagara Frontier
Intrastate. In Pennsylvania, Mercer and Potter Counties are in AQCR 178 –
Northwest Pennsylvania Intrastate.9 All counties associated with the Projects are in
attainment with the NAAQS, with the exception of Erie and Chautauqua Counties,
which are in nonattainment for the 8-hour O3 standard. In addition, because the
projects would be constructed in the Northeast OTR, all counties are considered to be
in moderate nonattainment with the NAAQS for O3. Facilities in nonattainment areas
are held to more restrictive air permitting standards.
State Air Quality Regulations
Title 6, Chapter III, Subchapter B, Part 257 of the New York Codes, Rules and
Regulations outline air quality standards that are applicable to the proposed projects. New
York State has adopted the NAAQS, although it maintains a more stringent standard of 0.050
parts per million for the annual averaging period for NO2. The state of New York has a
construction and operation permit required for minor sources of air emissions. Applicability
for this permit, the State Facility Permit, is found under Part 201-5 of the New York Codes,
Rules, and Regulations.
Pennsylvania has also adopted the NAAQS, but maintains additional air quality
standards under Title 25 of the Pennsylvania Code. 25 PA 123.1 outlines fugitive emissions
regulations. For accepted fugitive emissions activities/sources, which include construction of
buildings, clearing of land, and stockpiling of material, this section states that the following
requirements must be met: 1) the emissions are of minor significance with respect to causing
air pollution; and 2) the emissions are not preventing or interfering with the attainment or
maintenance of an ambient air quality standard.
8 Title 42 of the United States Code, Chapter 85, Part D, Subpart 1, Section 7506(a).
9 This data is provided in 40 CFR 81, Subpart C, Section 107 – Attainment Status Designations.
30
Air Quality Construction Impacts and Mitigation
Emissions associated with construction activities generally include exhaust from
construction equipment, fugitive dust associated with vehicle movement at the project sites,
and fugitive dust associated with trenching, backfilling, and other earth-moving activities.
Exhaust emissions would depend on the equipment used and the hp-hours of operation. The
quantity of fugitive dust emissions would depend on the moisture content and texture of the
soils that would be disturbed.
Construction of the Northern Access 2015 and Niagara Expansion Projects would last
approximately 12 and 9 months, respectively.
In order to minimize fugitive dust emissions, National Fuel would implement dust
suppression techniques such as watering unpaved surfaces, enforcing vehicle speed
restrictions, and using gravel or asphalt at site exit points to remove dirt from construction
vehicles’ tires or tracks. In addition, National Fuel would comply with Title 6 of the New
York Codes, Rules, and Regulations, Subpart 217-3 – Idling Prohibition for Heavy Duty
Vehicles. This rule prohibits idling for more than 5 minutes and would reduce fugitive
exhaust emissions. The Hinsdale Compressor Station would be a minor source of air
emissions. However, National Fuel would be required to obtain a State Facility Permit for the
station, which covers construction and operation of the proposed facility.
In Pennsylvania, TGP would be subject to 25 PA 123.1. In order to comply with state
fugitive dust regulations, TGP has committed to implementing mitigation measures such as:
watering disturbed surfaces during land clearing and grading activities; using water or other
chemical suppressant on unpaved roads, soil stockpiles, and other dust surfaces; and promptly
removing dirt tracked onto paved roads.
Emissions from construction equipment exhaust would be temporary in nature. Once
construction activities in the project area are completed, fugitive dust and construction
vehicle/equipment emissions associated with the pipeline and compressor station construction
would subside. Therefore, we believe that emissions associated with the construction phase
of the projects would not result in a significant impact on air local quality.
General Conformity
The General Conformity Rule, codified in Title 40 CFR Part 51, subpart W and Part
93, subpart B, requires a federal agency to demonstrate that every action it undertakes,
approves, permits, or supports will conform to the appropriate SIP. The General Conformity
Rule is applicable to construction and/or operation emissions that occur in a nonattainment
area. A conformity determination must be conducted by the lead federal agency if a federal
action’s construction and operational activities are likely to result in generating direct and
indirect emissions that would exceed the conformity threshold levels. According to the
conformity regulations, emissions from sources that are subject to any non-attainment new
source review (NNSR) or Prevention of Significant Deterioration (PSD) permitting/licensing
(major or minor) are exempt and are deemed to have conformed.
31
Portions of the projects would be located in ozone nonattainment areas, specifically
Erie and Chautauqua Counties. Because operational air emissions would be covered under
federal or state permit programs, they are exempt. The only emissions subject to General
Conformity would be construction emissions. Construction emissions for the Northern
Access 2015 and Niagara Expansion Projects are shown in table 11. The General Conformity
de minimis levels for NOx and ozone are 100 tons per year (tpy) and 50 tpy, respectively [40
CFR 93.153(b)(1)]. Therefore, construction emissions for both Projects would be below the
General Conformity applicability thresholds and a conformity analysis is not required.
Table 11: Estimated Construction Emissions
Criteria Pollutants (tpy) GHGs (CO2e)
PM10 PM2.5 NOx CO VOC CO2 N2O CH4
Northern Access 2015
Project 1.85 0.84 14.97 4.85 1.22 322.70 5.60 2.60
Niagara Expansion
Project 2.00 0.20 15.00 5.00 1.30 978.00 0.30 0.10
CO2 = carbon dioxide
CO2e = carbon dioxide equivalents
GHG = greenhouse gas
CH4 = methane
N2O = nitrous oxide
Air Quality Operation Impacts and Mitigation
Air emissions would result from operation of the proposed units at the Hinsdale and
Concord Compressor Stations. Table 12 displays the potential-to-emit (PTE) emissions of
criteria pollutants and hazardous air pollutants (HAPs) for each station. The PTE emissions
represent the maximum capacity of a stationary source to emit any air pollutant, although
actual operational emissions may be less.
Table 12: Potential-to-Emit Emissions for the Northern Access 2015 Project
Proposed Emission Sources
Potential Emissions (tpy)
NOx CO VOC PM10/2.5 SO2 HAPs Formal-
dehyde GHG (CO2e)
Hinsdale Compressor Station
Proposed Emissions 55.2 72.2 7.5 9.9 1.9 0.6 0.4 76,277
Concord Compressor Station
Existing Emissions 81 141 8 16 0 27 20 45,117
Proposed Emissions (Modification) 28 36 2.0 5.0 1.0 1.0 1.0 34,740
Total 108 177 10 21 1.0 28 21 79,768
Federal Air Quality Regulations: Major-Source Thresholds
32
Table 12: Potential-to-Emit Emissions for the Northern Access 2015 Project
Proposed Emission Sources
Potential Emissions (tpy)
NOx CO VOC PM10/2.5 SO2 HAPs Formal-
dehyde GHG (CO2e)
Greenhouse Gas Mandatory
Reporting - - - - - - - 25,000
PSD
(Significant Emission Rate)
250
(40)
250
(100)
250
(40)
250
(15)
250
40
250
(40) -
100,000 or
75,0002
Nonattainment New Source
Review1 100 100 50 100 100 100 - N/A
Title V 100 100 50 100 100 100 252 100,000
1: PSD de minimis levels are 250 for unlisted sources; however, in Ozone Transport Regions or marginal/moderate nonattainment areas,
this level is reduced.
2: PSD de minimis GHG level for new sources is 100,000 tpy and for existing source modifications is 75,000 tpy. 2: 25 tpy for all HAPs combined.
Tables 13 and 14 show the emissions from the Hinsdale and Concord Compressor
Stations and provides a comparison to the NAAQS. Based on this information, the
compressor stations would not cause an exceedance of the NAAQS.
Table 13: NAAQS Modeling Results-Hinsdale Compressor Station
Pollutant Averaging Period
Maximum Modeled
Concentration(1)
Background
Concentration (2)
Modeled +
Background NAAQS
(µg/m3)
(µg/m3) (µg/m3) (µg/m3)
CO 1-Hour 791.60 421.46 1,213.06 10,000
8-Hour 371.83 421.46 793.29 40,000
NO2 1-Hour 128.72 26.32 155.04 188
Annual 1.45 7.46 8.91 100
PM2.5 24-Hour 2.56 20.00 22.56 35
Annual 0.31 7.11 7.42 12
PM10 24-Hour 5.87 31.67 37.54 150
SO2
1-Hour 5.25 32.31 37.56 196
3-Hour 5.00 43.66 48.66 1300
24-Hour 1.10 14.85 15.95 365
Annual 0.07 4.26 4.33 80
(1) 1-hour and 8-hour CO - highest 2nd-highest maximum concentration; 1-hour NO2 – 98% percentile (highest 8th-highest) of daily
distribution of maximum 1-hour modeled concentrations; Annual NO2 – maximum annual concentration; 24-hour PM10 - highest 6th-highest 24-hour concentration over 5-year period; PM2.5 – 24-hour PM2.5 - 98th percentile of maximum 24-hour concentrations; Annual
PM2.5 – highest 5-year average annual concentration; and 1-hour SO2 – 99% percentile (highest 4th-highest) of daily distribution of
maximum 1-hour modeled concentrations. µg/m3 means micrograms per cubic meter.
(2) All pollutants but PM10 were obtained from the Pinnacle State Park monitor. PM10 concentrations are from the Montoursville, PA
monitor, the closest active monitor to the Hinsdale station. For all pollutants but NO2, average background concentrations were
determined by averaging 2010-2012 values. The Pinnacle State Park monitor did not have 2012 NO2 values so 2009-2011 values were used instead.
33
Table 14: NAAQS Modeling Results-Concord Compressor Station
Pollutant Averaging
Period
Maximum Modeled
Concentration(1) (µg/m3)
Background
Concentration(2)
(µg/m3)
Modeled +
Background (µg/m3)
NAAQS
(µg/m3)
CO 8-hour 229.72 421.46 651.18 10000
1-hour 368.92 421.46 790.38 40000
NO2
1-hour 161.35 26.32 187.67 188
Annual 7.16 7.46 14.62
99.64
PM2.5
Annual 2.40 7.11 9.51 12
Annual 2.40 7.11 9.51 15
24-hr 8.67 20.00 28.67 35
PM10 24-hr 21.31 31.67 52.98 150
SO2 1-hour 0.47 32.31 32.78 196
3-hour 0.48 43.66 44.14 1300
(1) 1-hour and 8-hour CO - highest 2nd-highest maximum concentration; 1-hour NO2 – 98% percentile (highest 8th-highest) of daily
distribution of maximum 1-hour modeled concentrations; Annual NO2 – maximum annual concentration; 24-hour PM10 - highest
6th-highest 24-hour concentration over 5-year period; PM2.5 – 24-hour PM2.5 - 98th percentile of maximum 24-hour concentrations; Annual PM2.5 – highest 5-year average annual concentration; and 1-hour SO2 – 99% percentile (highest 4th-
highest) of daily distribution of maximum 1-hour modeled concentrations. µg/m3 means micrograms per cubic meter.
(2) Background concentrations for CO, NO2, PM2.5, and SO2 based on air quality monitoring data from the NYSDEC Pinnacle State
Park monitoring station. Average values were taken from 2010-2012 data for CO, PM2.5, and SO2 and 2009-2011 for NO2. Background concentrations for PM10 are based on data from the Montoursville, PA monitoring station.
Federal Air Quality Regulations
During operation, the Hinsdale and Concord Compressor Stations would emit
quantities of regulated air pollutants and would be subject to federal and state air quality
regulations that are driven by the CAA. The provisions of the CAA that are potentially
relevant to this project are discussed below.
Greenhouse Gases
On December 7, 2009, the EPA defined air pollution to include six of the greenhouse
gases (GHG): carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O),
hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride.10
GHGs occur in the
atmosphere both naturally and as a result of human activities, such as the burning of fossil
fuels. These gases are the integral components of the atmosphere’s greenhouse effect that
warms the earth. The most abundant GHGs are water vapor, CO2, CH4, and N2O. No
fluorinated gases would be emitted during construction or operation of the Projects. GHG
Emissions are typically estimated as carbon dioxide equivalents (CO2e). GHGs are ranked by
their global warming potential (GWP), which is the potential of each gas to increase heating
10
See volume 74 of the Federal Register, page 66,496.
34
in the atmosphere. The GWP is a ratio relative to CO2 that is based on the GHG’s ability to
absorb solar radiation as well as the residence time within the atmosphere and is expressed as
a multiple of the GWP of CO2. Based on EPA guidelines, CO2 has a GWP of 1, CH4 has a
GWP of 25, and N2O has a GWP of 298.11
During construction and operation of the projects,
GHGs would be emitted from non-electrical construction equipment and any compressors,
line heaters, and generators. Table 12 summarizes the estimated PTE for GHG emissions for
the Hinsdale and Concord Compressor Stations.
On September 22, 2009, the EPA issued the final Mandatory Reporting of Greenhouse
Gases Rule. It requires reporting of GHG emissions from suppliers of fossil fuels and
facilities that emit greater than or equal to 25,000 metric tons12
of GHG per year. The
combustion-related GHG emissions from operation of the Northern Access 2015 Project
would exceed 25,000 metric tons per year; therefore National Fuel would be required to report
GHG emissions under the Mandatory Greenhouse Gas Reporting Rule.
On May 13, 2010, the EPA tailored the applicability criteria for stationary sources and
modification projects, resulting in the PSD GHG Tailoring Rule.13
However, on June 23,
2014, the Supreme Court ruled that the EPA cannot require PSD permitting based solely on
GHG emissions, striking down a portion of the rule. For disclosure, the new Hinsdale
Compressor Station would not emit GHGs above 100,000 tpy and, therefore, would not have
been subject to the PSD Tailoring Rule for GHGs. In addition, the modifications at the
Concord Compressor Station would not result in a net increase of 75,000 tpy of GHG
emissions; therefore, the Concord Compressor Station would not have been subject to the
PSD Tailoring Rule.
New Source Review – Prevention of Significant Deterioration
PSD federal review regulations are part of the New Source Review program. PSD
regulations are intended to protect the national public health and welfare as well as preserve
the existing air quality in areas of special national or regional scenic, natural, recreational, or
historic value where regulated pollutant levels are in compliance with the NAAQS. PSD
regulations impose specific limits on the amount of pollutants that new major sources or
major modifications at existing stationary sources may contribute to existing air quality levels.
In addition, for existing PSD sources, modifications that exceed the PSD significant-
emissions-increase rates are subject to PSD regulations. For natural gas compressor stations,
the PSD regulations define a major source as any source that emits or has the potential-to-emit
any regulated pollutant equal to or greater than 250 tpy. We received a comment from the
NYSDEC regarding consultation for modifications at the East Eden Meter Station. The
NYSDEC states that these modifications could potentially require a New Source Review and
11
On November 29, 2013, the EPA issued its final rule updating the global warming potential for
greenhouse gases (78 FR 71904). The final rule can be found at http://www.gpo.gov/fdsys/pkg/FR-
2013-11-29/pdf/2013-27996.pdf.
12 A metric ton is 2,205 pounds, or approximately 1.1 tons.
13 75 FR 31,514
35
require an air permit. In its application and May 27, 2014 response to the NYSDEC, National
Fuel states that it would not construct air emissions sources at the East Eden Meter Station
and it discussed the modifications at this station with the NYSDEC. In addition, National
Fuel provided additional information to the NYSDEC as indicated in its May 27th
response.
Nonattainment New Source Review
NNSR regulations apply to new major sources or major modifications at existing
major sources located in nonattainment areas. In addition, NNSR thresholds apply to
facilities within OTRs. Each Project would be constructed within the Northeast OTR;
therefore, emissions associated with the projects may be subject to NNSR. For NNSR, the
applicability threshold is 100 tpy for all criteria pollutants, except 50 tpy for VOCs. For
existing major sources, the EPA has established significant emissions rates as shown in table
12.
Emissions of criteria pollutants for the Hinsdale Compressor Station are below 100 tpy
and would not be subject to NNSR. Modifications at the Concord Compressor Station would
be below the significant emissions rate thresholds. Therefore, the Hinsdale and Concord
Compressor Stations would not be subject to NNSR.
New Source Performance Standards
New Source Performance Standards (NSPS), codified at 40 CFR 60, establish
emission limits and requirements for monitoring, reporting, and record keeping for specific
emission source categories. NSPS apply to new, modified, or reconstructed sources. Subpart
KKKK, Standards of Performance for Stationary Combustion Turbines, would apply to the
Hinsdale and Concord Compressor Stations’ turbines because the heat input at peak load
would be greater than 10 million British thermal units per hour. New turbines firing natural
gas fuel with maximum heat input ratings between 50 and 805 million British thermal units
per hour must comply with a NOx emission standard of 25 parts per million at 15 percent
oxygen. The turbines would be required to meet specific emission limits, and performance
testing, monitoring, recordkeeping, and reporting requirements would apply. In addition,
National Fuel would be required to comply with New York State opacity requirements.
Subpart JJJJ would apply to the new emergency generator at the Hinsdale Compressor
Station and the replacement generator at the Concord Compressor Station as each would be
greater than 130 hp. National Fuel would comply with the emissions limits and requirements
under subpart JJJJ.
Title V Operating Permit
The Title V Operating Permit Program, as described in 40 CFR 70, requires major
sources of air emissions and certain affected non-major sources to obtain a federal operating
permit. The major source emissions thresholds for determining the need for a Title V
Operating Permit are shown in table 12. The Concord Compressor Station is currently a
major source under Title V and would remain so as a result of the project. Emissions from the
Hinsdale Compressor Station would be below Title V thresholds.
36
National Emissions Standards for Hazardous Air Pollutants
National Emissions Standards for Hazardous Air Pollutants (NESHAP) apply to major
sources of HAPs. A major source under NESHAP is defined as a source with PTE emissions
exceeding 25 tpy for all HAPs or 10 tpy for individual HAPs. The Hinsdale Compressor
Station would not qualify as major source under NESHAP; therefore, it would not be subject
to NESHAP regulations. The Concord Compressor Station is an existing major source for
HAPs. NESHAP subpart ZZZZ could potentially apply to the emergency generators
proposed at the Hinsdale and Concord Compressor Stations. However, subpart ZZZZ
requirements would be met by complying with NSPS Subpart JJJJ.
Climate Change
Climate change is the modification of climate over time, whether due to natural causes
or as a result of human activities. Climate change cannot be represented by single annual
events or individual anomalies. For example, a single large flood event or particularly hot
summer is not an indication of climate change. However, unusually frequent or severe
flooding, or several consecutive years of abnormally hot summers over a large region may be
indicative of climate change. GHG emissions associated with operation of the Northern
Access 2015 Project is estimated at 111,017 tons of CO2e.
The Intergovernmental Panel on Climate Change (IPCC) is the leading international,
multi-governmental scientific body for the assessment of climate change. The United States
is a member of the IPCC and participates in the IPCC working groups. The leading United
States scientific body on climate change is the United States Global Change Research
Program (USGCRP). Thirteen federal departments and agencies14
participate in the
USGCRP, which began as a presidential initiative in 1989 and was mandated by Congress in
the Global Change Research Act of 1990.
The USGCRP have recognized that:
• Globally, anthropogenic GHGs have been accumulating in the atmosphere since the
beginning of the industrial era causing recent global warming;
• combustion of fossil fuels (coal, petroleum, and natural gas), combined with
agriculture and clearing of forests is primarily responsible for the accumulation of
GHG;
• the anthropogenic GHG emissions are the primary contributing factor to recent climate
change; and
• impacts extend beyond atmospheric climate change alone, and include changes to
water resources, transportation, agriculture, ecosystems, and human health.
14
The EPA, Department of Energy, Department of Commerce, Department of Defense, Department of
Agriculture, Department of the Interior, Department of State, DOT, Department of Health and Human
Services, National Aeronautics and Space Administration, National Science Foundation, Smithsonian
Institution, and Agency for International Development.
37
The USGCRP issued its assessments and findings in its Third National Climate
Assessment: Climate Change Impacts in the United States (NCA), in May 2014. The NCA
summarizes the impacts climate change has already had on the United States and what
projected impacts climate change may have in the future. The report includes a breakdown of
overall impacts by resource and impacts described for various regions of the United States.
Climate change has modified the regional environment in the continental Northeast
and is projected to cause additional changes. The Third NCA identifies climate change
impacts that have occurred along coastal regions in the Northeast. Previous impacts on
historical baseline climate and as well as projected climate change impacts that could affect
the project area are identified below:
• Between 1895 and 2011, average temperatures in the northeast have risen
approximately 2° F;
• since 1991, precipitation in the northeast increased by about 8 percent;
• there has been a 71 percent increase in the amount of precipitation falling during very
heavy events;
• seasonal drought risk is expected to increase in summer and fall as higher
temperatures result in greater evaporation and earlier snow melt;
• communities are affected by heat waves and coastal flooding due to sea level rise and
storm surge;
• an increase of 1 to 2 weeks in the frost-free season would occur;
• from 2010 to 2050, forested land cover is expected to decline
• there will be more days that reach temperatures above 90° F;
• agricultural production are likely to be adversely affected as favorable climates shift;
• the oceans are currently absorbing a portion of the CO2 emitted to the atmosphere
annually and are becoming more acidic as a result, leading to concerns about potential
impacts on marine ecosystems;
• coastal waters have risen about 2°F in several regions and are likely to continue to
warm; and
• infrastructure will be increasingly compromised by climate-related hazards, including
sea level rise and coastal flooding, and intense precipitation events.
We received a comment from the ADP regarding global climate change impacts
resulting from increased natural gas extraction. FERC does not regulate natural gas
production; however, natural gas production operations must comply with the corresponding
state’s SIP, which is approved by the EPA. In Pennsylvania and New York, production
activities are regulated by the PADEP and NYSDEC, respectively. As previously discussed,
the EPA has established emissions limits for reporting and control of GHG emissions.
Natural gas production facilities must comply with all applicable portions of these regulations.
38
The Northern Access 2015 and Niagara Expansion Projects will each have GHG emissions
levels below federal major-source thresholds. Although the Project emissions would
contribute to the overall amount of atmospheric GHG, it is impossible to quantify the impacts
that the emissions of GHG from construction and operation of the Projects would have on
climate change. It is also impossible to quantify the impacts specifically attributable to
natural gas production.
6.2 Noise
Construction and operation of the Projects would affect the local noise environment.
Two measurements used by federal agencies to relate the time-varying quality of
environmental noise to its known effects on people are the equivalent sound level (Leq) and
the day-night sound level (Ldn). The Leq is an A-weighted sound level containing the same
sound energy as instantaneous sound levels measured over a specific time period. Noise
levels are perceived differently, depending on length of exposure and time of day. The Ldn
takes into account the duration and time the noise is encountered. Late night through early
morning (10:00 p.m. to 7:00 a.m.) noise exposures are penalized +10 decibels (db) to account
for people’s greater sensitivity to sound during nighttime hours. An Ldn of 55 dB on the A-
weighted scale (dBA) is equivalent to a continuous Leq noise level of 48.6 dBA.
The EPA has indicated that an Ldn of 55 dBA protects the public from indoor and
outdoor activity interference. We have adopted this criterion and use it to evaluate the
potential noise impact from operation of compressor facilities. There are no state noise
ordinances applicable to the proposed projects. There are no state or local noise regulations
applicable to the Projects.
Construction Activities
Construction activities associated with each project would be performed with standard
heavy equipment such as track-excavators, backhoes, bulldozers, dump trucks, and cement
trucks. The most prevalent sound source during construction would be the internal
combustion engines used to power the construction equipment. Construction activities would
temporarily increase ambient sound levels in the immediate vicinity of the compressor station
construction sites while pipeline construction for each project would be transitory in nature.
Construction of the Northern Access 2015 and Niagara Expansion Projects would be limited
to daytime hours and would not affect nighttime noise levels; therefore, no significant
construction noise impacts are anticipated.
Compressor Station Operation
As previously discussed, our noise criterion limits the noise attributable to full-load
operation of the proposed compressor stations at the nearest noise-sensitive areas (NSAs) to
55 dBA. The Niagara Expansion Project includes modification of existing aboveground
facilities; however, there would be no new permanent noise sources. Therefore, there would
be no operational noise associated with proposed facilities.
39
National Fuel’s noise consultants, Hoover and Keith, conducted an acoustical analysis
for the Concord Compressor Station and East Eden Meter Station on December 16, 2013 and
for the Hinsdale Compressor Station on December 18, 2013. The estimated noise attributable
to operation of each facility is shown in table 15.
Table 15: Estimate Operational Noise for the Northern Access 2015 Project
NSAs
Distance to Center of
Proposed Unit(s)
(feet/direction)
Calc'd Ambient
Noise (Ldn,
dBA)1
Est'd Noise of
Proposed
Facilities at Full
Load
(Ldn, dBA)
Station Noise +
Ambient Noise
(Ldn, dBA)2
Potential
Increase
(dB)
Hinsdale Compressor Station
NSA #1 1,050 N-NE
49.8 46.3 51.4 1.6
NSA #2 1,075
SW 55.3 46.1 55.8 0.5
NSA #3 2,000 E-SE
57.1 39.5 57.2 0.1
NSA #4 2,650
NE 49.9 36.5 50.1 0.2
NSA #5 1,975 NW
49.8 39.7 50.2 0.4
Concord Compressor Station
NSA #1 2,500
SW to SE 36.5 34.2 38.5 2.0
NSA #2 4,600
W to NW 29.3 27.9 31.7 2.4
NSA #3 3,400
SE to NE 32.9 30.9 35.0 2.1
East Eden Meter Station
NSA #1 275 SW
51.1 43.4 51.8 0.7
NSA #2 400
S to SE 58.6 39.0 58.6 0.0
1. For the Concord Compressor Station, the ambient noise is the noise generated by the existing station. 2. For the Concord Compressor Station, station plus ambient noise is the total station noise (proposed + existing).
The noticeable noise increase threshold for humans is about 3 dBA; 5 dBA is clearly
noticeable different increase in noise, while an increase of 10 dBA is perceived to be a
doubling of noise. As shown in table 15, noise increases from the Hinsdale and Concord
Compressor Stations and the East Eden Meter Station range from 0 dBA to 2.4 dBA and
would not be perceptible. The existing ambient noise in the vicinity of the East Eden Meter
Station is above 55 dBA at NSA 2, however, there would be no increase in noise at this NSA
and Hoover and Keith indicate that the meter station was not audible at NSAs 1 and 2 during
measurement. At the proposed Hinsdale Compressor Station site, NSAs 2 and 3 currently
experience ambient noise levels above 55 dBA. However, the noise attributable to the station
is estimated to be well below 55 dBA and the NSAs would not experience a noticeable
increase in noise.
National Fuel has committed to implementing noise-abatement measures, as
recommended by Hoover and Keith, Inc., which includes: installing exhaust silencers or
mufflers on the exhaust of the turbines; acoustically insulating the exhaust pipes of the
40
turbines from the compressor building wall to the exhaust muffler flange; installing a
filter/silencer on the airtake of the turbines; and enclosing the turbines in an acoustically
insulated building.
National Fuel’s estimated noise levels would meet our criterion; however, to ensure
that the noise attributable to operation of the Hinsdale and Concord Compressor Stations
would not exceed reasonable levels at nearby residences, we recommend that National Fuel
should file noise surveys with the Secretary no later than 60 days after placing the
Hinsdale and Concord Compressor Stations in service. If full load condition noise
surveys are not possible, National Fuel should provide interim surveys at the maximum
possible load and provide a full load survey within 6 months. If the noise attributable to
the operation of all of the equipment at the Hinsdale or Concord Compressor Stations
under interim or full load conditions exceeds an Ldn of 55 dBA at any nearby NSAs,
National Fuel should file a report on what changes are needed and should install the
additional noise controls to meet the level within 1 year of the in-service date. National
Fuel should confirm compliance with the above requirement by filing a second noise
survey with the Secretary no later than 60 days after it installs the additional noise
controls.
Because the existing noise level at the East Eden Meter Station would result in noise
levels above 55 dBA, we recommend that National Fuel should file a noise survey with the
Secretary no later than 60 days after placing the modified facilities at the East Eden
Meter Station in service. If the noise attributable to the operation of the modified
equipment at the meter station at maximum flow conditions exceeds predicted noise
levels at any nearby noise-sensitive areas, National Fuel should file a report on what
changes are needed and should install the additional noise controls to meet the level
within 1 year of the in-service date. National Fuel should confirm compliance with the
above requirement by filing a second noise survey with the Secretary no later than 60
days after it installs the additional noise controls.
Based on the estimated sound levels, adherence to local noise regulations, and our
recommendation, we believe that the noise attributable to operation of the Hinsdale and
Concord Compressor Stations and East Eden Meter Station would not cause a significant
impact on the noise environment in the project area.
7.0 Reliability and Safety
The transportation of natural gas by pipeline involves some incremental risk to the
public due to the potential for accidental release of natural gas. The greatest hazard is a fire or
explosion following a major pipeline rupture.
Methane, the primary component of natural gas, is colorless, odorless, and tasteless. It
is not toxic, but is classified as a simple asphyxiate, possessing a slight inhalation hazard. If
breathed in high concentration, oxygen deficiency can result in serious injury or death.
Methane has an auto-ignition temperature of 1,000 degrees Fahrenheit and is flammable at
concentrations between 5.0 percent and 15.0 percent in air. An unconfined mixture of
41
methane and air is not explosive, however it may ignite and burn if there is an ignition source.
A flammable concentration within an enclosed space in the presence of an ignition source can
explode. It is buoyant at atmospheric temperatures and disperses rapidly in air.
7.1 Safety Standards
The DOT is mandated to provide pipeline safety under Title 49, U.S.C. Chapter 601.
The DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) administers
the national regulatory program to ensure the safe transportation of natural gas and other
hazardous materials by pipeline. It develops safety regulations and other approaches to risk
management that ensure safety in the design, construction, testing, operation, maintenance,
and emergency response of pipeline facilities. Many of the regulations are written as
performance standards which set the level of safety to be attained and allow the pipeline
operator to use various technologies to achieve safety. PHMSA ensures that people and the
environment are protected from the risk of pipeline incidents. This work is shared with state
agency partners and others at the federal, state, and local level.
The DOT provides for a state agency to assume all aspects of the safety program for
intrastate facilities by adopting and enforcing the federal standards. A state may also act as
DOT's agent to inspect interstate facilities within its boundaries; however, the DOT is
responsible for enforcement actions.
The DOT pipeline standards are published in Parts 190-199 of Title 49 of the CFR.
Part 192 specifically addresses natural gas pipeline safety issues.
Under a Memorandum of Understanding on Natural Gas Transportation Facilities
(Memorandum) dated January 15, 1993, between the DOT and the FERC, the DOT has the
exclusive authority to promulgate federal safety standards used in the transportation of natural
gas. Section 157.14(a)(9)(vi) of the FERC's regulations require that an applicant certify that it
will design, install, inspect, test, construct, operate, replace, and maintain the facility for
which a Certificate is requested in accordance with federal safety standards and plans for
maintenance and inspection. Alternatively, an applicant must certify that it has been granted a
waiver of the requirements of the safety standards by the DOT in accordance with section 3(e)
of the Natural Gas Pipeline Safety Act. The FERC accepts this certification and does not
impose additional safety standards. If the Commission becomes aware of an existing or
potential safety problem, there is a provision in the Memorandum to promptly alert DOT.
The Memorandum also provides for referring complaints and inquiries made by state and
local governments and the general public involving safety matters related to pipelines under
the Commission's jurisdiction.
The FERC also participates as a member of the DOT's Technical Pipeline Safety
Standards Committee which determines if proposed safety regulations are reasonable,
feasible, and practicable.
The pipeline and aboveground facilities associated with the Northern Access 2015 and
Niagara Expansion Projects must be designed, constructed, operated, and maintained in
42
accordance with the DOT Minimum Federal Safety Standards in 49 CFR 192. The
regulations are intended to ensure adequate protection for the public and to prevent natural
gas facility accidents and failures. The DOT specifies material selection and qualification;
minimum design requirements; and protection from internal, external, and atmospheric
corrosion.
The DOT also defines area classifications, based on population density in the vicinity
of the pipeline, and specifies more rigorous safety requirements for populated areas. The
class location unit is an area that extends 220 yards on either side of the centerline of any
continuous 1-mile length of pipeline. The four area classifications are defined below:
Class 1 Location with 10 or fewer buildings intended for human occupancy.
Class 2 Location with more than 10 but less than 46 buildings intended for
human occupancy.
Class 3 Location with 46 or more buildings intended for human occupancy or
where the pipeline lies within 100 yards of any building, or small well-
defined outside area occupied by 20 or more people on at least 5 days a
week for 10 weeks in any 12-month period.
Class 4 Location where buildings with four or more stories aboveground are
prevalent.
Class locations representing more populated areas require higher safety factors in
pipeline design, testing, and operation. For instance, pipelines constructed on land in Class 1
locations must be installed with a minimum depth of cover of 30 inches in normal soil and 18
inches in consolidated rock. Class 2, 3, and 4 locations, as well as drainage ditches of public
roads and railroad crossings, require a minimum cover of 36 inches in normal soil and 24
inches in consolidated rock.
Class locations also specify the maximum distance to a sectionalizing block valve
(e.g., 10.0 miles in Class 1, 7.5 miles in Class 2, 4.0 miles in Class 3, and 2.5 miles in Class
4). Pipe wall thickness and pipeline design pressures; hydrostatic test pressures; MAOP;
inspection and testing of welds; and frequency of pipeline patrols and leak surveys must also
conform to higher standards in more populated areas.
Preliminary class locations for the Niagara Expansion Project have been developed
based on the relationship of the pipeline centerline to other nearby structures and manmade
features. TGP’s Loop 224 would consist of about 3 miles of Class 1 pipe, which represents
100 percent of the route. If a subsequent increase in population density adjacent to the right-
of-way results in a change in class location for the pipeline, TGP would reduce the MAOP or
replace the segment with pipe of sufficient grade and wall thickness, if required to comply
with the DOT requirements for the new class location.
The DOT Pipeline Safety Regulations require operators to develop and follow a
written integrity management program that contain all the elements described in 49 CFR
43
192.911 and address the risks on each transmission pipeline segment. The rule establishes an
integrity management program which applies to all high consequence areas (HCA).
The DOT has published rules that define HCAs where a gas pipeline accident could do
considerable harm to people and their property and requires an integrity management program
to minimize the potential for an accident. This definition satisfies, in part, the Congressional
mandate for DOT to prescribe standards that establish criteria for identifying each gas
pipeline facility in a high-density population area.
The HCAs may be defined in one of two ways. In the first method an HCA includes:
current class 3 and 4 locations,
any area in Class 1 or 2 where the potential impact radius15
is greater than 660
feet and there are 20 or more buildings intended for human occupancy within
the potential impact circle16
, or
any area in Class 1 or 2 where the potential impact circle includes an identified
site.
An identified site is an outside area or open structure that is occupied by 20 or more
persons on at least 50 days in any 12-month period; a building that is occupied by 20 or more
persons on at least 5 days a week for any 10 weeks in any 12-month period; or a facility that
is occupied by persons who are confined, are of impaired mobility, or would be difficult to
evacuate.
In the second method, an HCA includes any area within a potential impact circle
which contains:
20 or more buildings intended for human occupancy, or
an identified site.
Once a pipeline operator has determined the HCAs along its pipeline, it must apply the
elements of its integrity management program to those segments of the pipeline within HCAs.
The DOT regulations specify the requirements for the integrity management plan at
section 192.911. The pipeline integrity management rule for HCAs requires inspection of the
pipeline HCAs every 7 years. TGP has not identified any HCAs along the proposed pipeline
route.
The DOT prescribes the minimum standards for operating and maintaining pipeline
facilities, including the requirement to establish a written plan governing these activities.
Each pipeline operator is required to establish an emergency plan that includes procedures to
minimize the hazards of a natural gas pipeline emergency. Key elements of the plan include
procedures for:
15
The potential impact radius is calculated as the product of 0.69 and the square root of: the MAOP of the
pipeline in psig multiplied by the square of the pipeline diameter in inches. 16
The potential impact circle is a circle of radius equal to the potential impact radius.
44
receiving, identifying, and classifying emergency events, gas leakage, fires,
explosions, and natural disasters;
establishing and maintaining communications with local fire, police, and
public officials, and coordinating emergency response;
emergency system shutdown and safe restoration of service;
making personnel, equipment, tools, and materials available at the scene of an
emergency; and
protecting people first and then property, and making them safe from actual or
potential hazards.
The DOT requires that each operator establish and maintain liaison with appropriate
fire, police, and public officials to learn the resources and responsibilities of each organization
that may respond to a natural gas pipeline emergency, and to coordinate mutual assistance.
The operator must also establish a continuing education program to enable customers, the
public, government officials, and those engaged in excavation activities to recognize a gas
pipeline emergency and report it to appropriate public officials. National Fuel and TGP
would provide the appropriate training to local emergency service personnel before the
pipeline facilities are placed in service.
7.2 Pipeline Accident Data
The DOT requires all operators of natural gas transmission pipelines to notify the DOT
of any significant incident and to submit a report within 20 days. Significant incidents are
defined as any leaks that:
caused a death or personal injury requiring hospitalization; or
involve property damage of more than $50,000 (1984 dollars)17
.
During the 20 year period from 1994 through 2013, a total of 1,237 significant
incidents were reported on the more than 300,000 total miles of natural gas transmission
pipelines nationwide.
Additional insight into the nature of service incidents may be found by examining the
primary factors that caused the failures. Table 16 provides a distribution of the causal factors
as well as the number of each incident by cause.
The dominant causes of pipeline incidents are corrosion and pipeline material, weld or
equipment failure constituting 48.2 percent of all significant incidents. The pipelines included
in the data set in table 16 vary widely in terms of age, diameter, and level of corrosion control.
Each variable influences the incident frequency that may be expected for a specific segment
of pipeline.
17
$50,000 in 1984 dollars is approximately $115,000 as of March, 2014 (CPI, Bureau of Labor Statistics,
February, 2014)
45
The frequency of significant incidents is strongly dependent on pipeline age. Older
pipelines have a higher frequency of corrosion incidents and material failure, since corrosion
and pipeline stress/strain is a time-dependent process.
Table 16: Natural Gas Transmission Pipeline Significant Incidents by Cause 1994-20131
Cause No. of Incidents Percentage
Corrosion 292 23.6
Excavation2 211 17.0
Pipeline material, weld or equipment failure 304 24.6
Natural force damage 142 11.5
Outside force3 74 6.0
Incorrect operation 33 2.7
All other causes4 181 14.6
TOTAL 1,237 -
1. All data gathered from PHMSA Significant incident files, March 25, 2014. http://primis.phmsa.dot.gov/comm/reports/safety/ 2. Includes third party damage
3. Fire, explosion, vehicle damage, previous damage, intentional damage
4. Miscellaneous causes or unknown causes
The use of both an external protective coating and a cathodic protection system18
,
required on all pipelines installed after July 1971, significantly reduces the corrosion rate
compared to unprotected or partially protected pipe.
Outside force, excavation, and natural forces are the cause in 34.5 percent of
significant pipeline incidents. These result from the encroachment of mechanical equipment
such as bulldozers and backhoes; earth movements due to soil settlement, washouts, or
geologic hazards; weather effects such as winds, storms, and thermal strains; and willful
damage. Table 17 provides a breakdown of outside force incidents by cause.
Older pipelines have a higher frequency of outside forces incidents partly because
their location may be less well known and less well marked than newer lines. In addition, the
older pipelines contain a disproportionate number of smaller-diameter pipelines; which have a
greater rate of outside forces incidents. Small diameter pipelines are more easily crushed or
broken by mechanical equipment or earth movement.
Since 1982, operators have been required to participate in "One Call" public utility
programs in populated areas to minimize unauthorized excavation activities in the vicinity of
pipelines. The "One Call" program is a service used by public utilities and some private
sector companies (e.g., oil pipelines and cable television) to provide preconstruction
information to contractors or other maintenance workers on the underground location of
pipes, cables, and culverts.
18
Cathodic protection is a technique to reduce corrosion (rust) of the natural gas pipeline through the use
of an induced current or a sacrificial anode (like zinc) that corrodes at faster rate to reduce corrosion.
46
Table 17: Outside Forces Incidents by Cause1
1994-2013
Cause No. of Incidents Percent of all Incidents
Third party excavation damage 176 14.2
Operator excavation damage 25 2.0
Unspecified excavation damage/previous damage 10 0.8
Heavy rain/floods 72 5.8
Earth movement 35 2.8
Lightning/temperature/high winds 21 1.7
Natural force (other) 14 1.1
Vehicle (not engaged with excavation) 45 3.6
Fire/explosion 8 0.6
Previous mechanical damage 5 0.4
Fishing or maritime activity 7 0.6
Intentional damage 1 0.1
Electrical arcing from other equipment/facility 1 0.1
Unspecified/other outside force 7 0.6
TOTAL 427 -
1. Excavation, Outside Force, and Natural Force from Table 2-1
7.3 Impact on Public Safety
The service incidents data summarized in table 16 include pipeline failures of all
magnitudes with widely varying consequences.
Table 18 presents the average annual injuries and fatalities that occurred on natural gas
transmission lines for the 5 year period between 2009 and 2013. The majority of fatalities
from pipelines are due to local distribution pipelines not regulated by FERC. These are natural
gas pipelines that distribute natural gas to homes and businesses after transportation through
interstate natural gas transmission pipelines. In general, these distribution lines are smaller
diameter pipes and/or plastic pipes which are more susceptible to damage. Local distribution
systems do not have large right-of-ways and pipeline markers common to the FERC regulated
natural gas transmission pipelines.
Table 18: Injuries and Fatalities- Natural Gas Transmission Pipelines
Year Injuries Fatalities
2009 11 0
20101 61 10
2011 1 0
2012 7 0
2013 2 0
1. All of the fatalities in 2010 were due to the Pacific Gas and Electric pipeline rupture and fire in San Bruno,
California on September 9, 2010.
The nationwide totals of accidental fatalities from various anthropogenic and natural
hazards are listed in table 19 in order to provide a relative measure of the industry-wide safety
of natural gas transmission pipelines. Direct comparisons between accident categories should
be made cautiously, however, because individual exposures to hazards are not uniform among
all categories. The data nonetheless indicate a low risk of death due to incidents involving
natural gas transmission pipelines compared to the other categories. Furthermore, the fatality
rate is much lower than the fatalities from natural hazards such as lightning, tornados, or
floods.
47
Table 19: Nationwide Accidental Deaths 1
Type of Accident Annual No. of Deaths
All accidents 117,809
Motor Vehicle 45,343
Poisoning 23,618
Falls 19,656
Injury at work 5,113
Drowning 3,582
Fire, smoke inhalation, burns 3,197
Floods2 89
Tractor Turnover3 62
Lightning2 54
Natural gas distribution lines4 14
Natural gas transmission pipelines4 2
1. All data, unless otherwise noted, reflects 2005 statistics from U.S. Census Bureau, Statistical Abstract of the United States: 2010 (129th
Edition) Washington, DC, 2009; http://www.census.gov/statab. 2. NOAA National Weather Service, Office of Climate, Water and Weather Services, 30 year average (1983-2012)
http://www.weather.gov/om/hazstats.shtml
3. Bureau of Labor Statitics, 2007 Census of Occupational Injuries 4. PHMSA significant incident files, March 25, 2014. http://primis.phmsa.dot.gov/comm/reports/safety/, 20 year average.
The available data show that natural gas transmission pipelines continue to be a safe,
reliable means of energy transportation. From 1994 to 2013, there were an average of 62
significant incidents, 10 injuries and 2 fatalities per year. The number of significant incidents
over the more than 303,000 miles of natural gas transmission lines indicates the risk is low for
an incident at any given location. The operation of the Northern Access 2015 and Niagara
Expansion Projects would represent a slight increase in risk to the nearby public.
8.0 Cumulative Impacts
In accordance with NEPA, we evaluated the cumulative impacts of the projects and
other projects in the area. Cumulative impacts result from the incremental effects of two or
more projects occurring in the same general area within a concerted timeframe, regardless of
what agency or person undertakes such other actions. Cumulative impacts may result from
individually minor, but collectively significant, actions that occur in the same general location
over a given period of time or have overlapping impacts. Even though certain activities may
not occur at the same time, their impacts may be of such duration that overlaying the
incremental effects of each could result in a greater cumulative impact. The direct and
indirect impacts of the projects are discussed in other sections of this EA.
The purpose of this cumulative impact analysis is to identify and describe cumulative
impacts that would result from the implementation of multiple projects in the same general
area and timeframe. This cumulative impact analysis generally follows the methodology set
forth in relevant guidance (Council on Environmental Quality 1997; EPA 1999). Under these
guidelines, we looked for commonalities of impacts from other projects and the Project, based
on NEPA documentation, agency an public input, and best professional judgment. An action
must meet the following three criteria to be included in the cumulative impacts analysis:
impact a resource area potentially affected by the proposed project;
cause this impact within all, or part of, the proposed project area; and
48
cause this impact within all, or part of, the time span for the potential impact from
the proposed Project.
The actions considered in our cumulative impact analysis may vary from the project in
nature, magnitude, and duration. These actions are included based on the likelihood of
completion near the proposed construction time span, and only projects with either ongoing
impacts or that are “reasonably foreseeable” future actions were evaluated. Existing or
reasonably foreseeable actions that would be expected to affect similar resources during
similar periods as the projects were considered further. The anticipated cumulative impacts of
the proposed Project and these other actions are discussed below, as well as any pertinent
mitigation actions.
Projects constructed, under construction, or in the vicinity of the proposed projects
could have a cumulative impact on air quality. The ADP asserts that the applicants did not
thoroughly discuss the cumulative impacts associated with their respective projects with
regard to similar projects and shale natural gas extraction. The ADP also expresses concern
with cumulative noise impacts associated with the projects. We discuss the cumulative
effects on air quality and noise below.
8.1 Identified Projects
We identified eighteen other projects in New York and Pennsylvania. Table 20 shows
FERC jurisdictional projects that were evaluated for cumulative impacts and table 21 lists
other, non-jurisdictional construction projects in the vicinity of TGP’s and National Fuel’s
projects. Eight of these projects- TGP’s project modifications pursuant to section 2.55(a) of
18 CFR19
; National Fuel’s Mercer Compression Project; National Fuel’s Line TNY
Replacement; National Fuel’s West Side Expansion and Modernization Project; natural gas
wells in Pennsylvania; Medina sandstone gas wells; the Allegheny Wind Power Project; and
mining activities- were determined to potentially result in cumulative impacts when
considered with TGP and National Fuel’s projects. The additional ten projects listed in the
table lie outside of the region of influence for potential cumulative impacts. However, to
inform the reader of other activities in the larger Pennsylvania and New York region, we are
providing summary information regarding these other projects.
Construction of these eight identified projects would occur within the same counties as
the Niagara Expansion and Northern Access 2015 Projects. TGP’s section 2.55(a) projects
involve minor construction activities at its existing stations in Pennsylvania and New York.
Construction of the Mercer Compression Project is within the same county as Station 219 and
would be completed about 6 months before TGP begins construction at Station 219. National
Fuel’s West Side Expansion and Modernization Project is located in the same county as
TGP’s Station 219 and if approved, would begin construction in November 2014. National
Fuel’s Line TNY Replacement is currently under construction in Erie County. The Medina
sandstone natural gas wells in the vicinity may involve some construction within the vicinity
19
Projects under section 2.55(a) are allowable operation and maintenance activities that can be completed
without any authorization from FERC beyond the Certificate authorizing the construction/operation of
the facilities.
49
of Loop 224 while it is under construction. There is also drilling activity for Marcellus Shale
natural gas reserves currently occurring throughout Pennsylvania; we identified 15 wells in
Mercer County. Mining activities within Cattaraugus County are ongoing. The planned
Allegeheny Wind Power Project in the vicinity of the Hinsdale Compressor Station in
Cattaraugus County is currently under review. With the exception of the Hinsdale
Compressor Station, construction would occur within or immediately adjacent to TGP and
National Fuel’s existing compressor stations and meter stations. In addition, TGP’s Loop 224
would be entirely co-located with its existing 200 Line right-of-way.
Throughout section B of this EA, we determined that the projects would have minimal
impacts on geology, soils, water resources, vegetation, wildlife, land use, cultural resources,
and safety. The potential effects most likely to have a cumulative impact pertain to air quality
and noise; therefore, the discussion below primarily focuses on the potential for cumulative
impacts as a result of construction and operation of the projects on these resources. The other
projects were not considered in this cumulative impact analysis due to distance or because
construction timing would not overlap with the proposed projects.
Table 20: Existing and Future FERC Jurisdictional Projects Evaluated for Cumulative Impacts
Project Name Location Nearest Facility
Location
Project
Description Status
Date of
Construction
Activities
Various TGP
Projects pursuant to section 2.55(a)
Various counties in
New York and Pennsylvania
Loop 224, Stations
219 and 224
Station piping and auxiliary
equipment, anomaly
digs
Allowed under
TGP’s existing blanket certificate
Ongoing
TGP’s MPP Project
Potter, Mercer,
Venago, and McKean Counties,
PA
Station 219
7.9 miles of looping
pipeline and
modifications at
four compressor stations
Approved Completed October
2013
National Fuel’s Mercer
Compression
Project
Mercer County,
Pennsylvania Station 219
Replacement of
2.05 miles of pipeline, new
compressor station,
and a new meter station
Approved
Under Construction,
began February 2014
National Fuel’s Northern Access
and TGP’s Station
230C Project
Erie County, New
York
Concord Compressor Station,
East Eden Meter
Station
New compressor
station, modifications at
four compressor
stations and one meter station
Approved
Completed
December 2012
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Table 20: Existing and Future FERC Jurisdictional Projects Evaluated for Cumulative Impacts
Project Name Location Nearest Facility
Location
Project
Description Status
Date of
Construction
Activities
TGP 300 Line Project
Various counties in Pennsylvania
Station 219
127 miles of
looping pipeline, two new
compressor stations,
and modifications at seven compressor
stations on 300 Line
Approved
Completed October
2012
TGP Northeast
Supply
Diversification Project
Livingston, Niagara, and Erie
Counties, New
York; Tioga and Bradford Counties,
Pennsylvania
Concord
Compressor Station, East Eden and
Hamburg Meter
Stations
6.8 miles of looping pipeline,
compressor station
and meter station modifications on
300 Line
Approved
Completed October 2012
TGP Northeast
Upgrade Project
Bradford, Wayne, Susquehanna, and
Pike Counties,
Pennsylvania; Sussex, Passaic, and
Bergen Counties,
New Jersey
Station 219
40 miles of looping
pipeline, modifications at
four compressor
stations, new meter station
Approved Completed October
2013
TGP Uniondale
Expansion Project
Susquehanna
County, Pennsylvania
Station 219
Modifications at one compressor
station and one
meter station
Approved Under Construction
began May 2014
TGP Rose Lake
Expansion Project
Bradford and Tioga Counties,
Pennsylvania
Station 219
Modifications at
three compressor
stations and TGP’s 300 Line
Approved Under Construction
began April 2014
National Fuel’s Line TNY
Replacement
Erie County, New
York
Concord
Compressor Station,
East Eden Meter Station,
6 miles of pipeline and appurtenant
facilities
Approved Under Construction
began May 2014
National Fuel’s Summit Storage
Lines Abandonment
Erie County,
Pennsylvania
Station 224, Loop
224
Construct 350 feet,
abandon 3,430 feet, and remove 420 feet
pipeline in storage
field
Pending Under FERC
review. Estimated
August 2014
National Fuel
Tuscarora Lateral
Steuben County, New York; Tioga
County,
Pennsylvania
Hinsdale
Compressor Station
17 miles of
pipeline,
modifications of two compressor
stations
Pending
Under FERC
Review. Estimated November 2014
51
Table 20: Existing and Future FERC Jurisdictional Projects Evaluated for Cumulative Impacts
Project Name Location Nearest Facility
Location
Project
Description Status
Date of
Construction
Activities
National Fuel’s
West Side Expansion and
Modernization
Project
Washington,
Allegheny, and
Beaver Counties, Pennsylvania;
Mercer and
Venango Counties, Pennsylvania
Station 219
24 miles of
pipeline, additional compression at the
Mercer Compressor
Station, modifications at the
Henderson
Compressor Station
Pending Under FERC
review. Estimated
November 2014
TGP Northeast Expansion Project
Various counties in
New York and
Massachusetts
Hinsdale Compressor Station
179 miles of
pipeline (50 miles
looping on TGP’s 200 Line),
additional
compression
Open season held, under development
Unknown
Table 21: Existing or Future Non-jurisdictional Projects Evaluated for Potential Cumulative Impacts
Project or Development Location Nearest Facility
Location
Planned
Structures
Permitting
Status
Date of Construction
Activities
Natural Gas Wells (Medina
sandstone)
Chautauqua County,
New York Loop 224 Four wells Permitted Ongoing
Natural Gas Wells Mercer County,
Pennsylvania Station 219 Fifteen wells Permitted Ongoing
Mining Cattaraugus County,
New York
Hinsdale Compressor
Station
Sand and gravel
mining Permitted Ongoing
Allegheny Wind Power Project
Cattaraugus County, New York
Hinsdale Compressor Station
29 wind turbines Under Review Not yet completed
National Fuel’s Mercer Compression Project involves one new compressor station,
one new meter station, and approximately 2 miles of pipeline replacement. Construction of
the Mercer Compression Project is estimated to be completed about 6 months before
construction of the TGP and National Fuel projects.
The PADEP online database indicated that there are fifteen permitted wells associated
with Marcellus Shale drilling activities in Mercer County, Pennsylvania; however, the
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database does not provide specific information relative to the exact location and timing of
these wells. In addition, it is unknown when, or even if, these wells would be drilled.
Therefore, we concluded that an in-depth analysis of Marcellus Shale wells is outside the
scope of the analysis in this EA because the exact location, scale, and timing of these facilities
are unknown. The impacts described in this EA for TGP’s and National Fuel’s Projects
would be temporary and with appropriate mitigation measures, would be minor. Therefore,
the Projects would result in limited additional resource impacts compared to the ongoing
Marcellus Shale production impacts.
There are no Marcellus Shale wells located in New York due to the moratorium on
hydraulic fracturing in New York; however, gas is extracted from the Medina sandstone in
Chautauqua County. Four conventional gas wells associated with the Medina sandstone were
identified within 1,000 feet of Loop 224 in Chautauqua County, New York.
Impacts of drilling activities involve well pad development, improvement of existing
dirt and paved roads, construction of new access roads, and construction of gathering pipeline
systems. All of these activities are outside of the Commission’s jurisdiction and are under the
jurisdiction of the PADEP and the NYSDEC. The first natural gas production from the
Marcellus Shale in Pennsylvania began in 2005. Between 2005 and 2010, an estimated 2,755
natural gas wells were drilled in Pennsylvania, about half of which are Marcellus Shale wells.
We have not included potential future upstream facilities (not yet proposed) in our
analysis, given that production of the Marcellus Shale reserves is anticipated to take between
20 and 40 years, and the location, scale, and timing of future upstream facilities that could
potentially contribute to cumulative impacts in the project areas are unknown.
8.2 Potential Cumulative Impacts
Soils
Cumulative impacts on soils and geology would occur when the construction period of
the Projects and other projects in the region occur at the same time. Depending on soil
conditions, these impacts may include loss of excavated soil from water and wind erosion,
soil compaction from construction equipment, and mixing of subsoil and topsoil. Cumulative
impacts could result from the proposed projects and TGP’s section 2.55(a) projects being
constructed in close proximity and at the same time. However, all of these projects would be
constructed according to the FERC Plan and Procedures which would minimize the likelihood
of erosion and sedimentation during and after construction through the implementation of
erosion and sediment control best management practices. Similarly, construction of natural
gas wells is regulated by the PADEP and NYSDEC which would require certain erosion and
sediment control measures for these types of construction projects. The projects’ impacts on
soils are expected to be minor to non-significant as most construction would take place within
previously disturbed rights-of-way and existing aboveground facility sites. Construction and
restoration activities as well as operation and maintenance activities would be monitored
throughout the process to ensure compliance. Consequently, any potential cumulative
impacts on geological resources and soils would be temporary and minor.
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Water Resources
The cumulative impacts on groundwater resources are expected to be temporary and
limited to periods during the construction phase of the projects. They would be limited to
areas that are affected by the projects that are in close proximity to each other. The
completion of natural gas wells, especially for development of the Marcellus Shale in
Pennsylvania, has the potential to impact groundwater quality due to the use of chemical
additives in the drilling process. In response to water quality concerns in Pennsylvania, the
PADEP has updated its regulations governing the development of oil and gas wells relative to
the protection of water supplies. Drilling companies in Pennsylvania must now disclose the
chemical additives used to stimulate gas wells and appropriately manage drilling return water
to prevent impacts on water resources. TGP would implement its Plan as well as its SPRP for
the Niagara Expansion Project and all of its 2.55(a) activities would be constructed in
accordance with the FERC Plan and Procedures, which would minimize any potential impacts
on groundwater during construction. The cumulative effect of the Projects and the other
identified or proposed projects in the area on groundwater resources is not expected to be
significant.
TGP and National Fuel’s projects would primarily have minor, temporary impacts on
wetlands; however, some impacts on wetlands would be long-term, such as permanent
impacts on 0.18 acre of forested wetlands along TGP’s Loop 224. In addition, TGP’s impacts
on waterbodies are expected to be minor due to TGP’s commitment to follow its Procedures
during construction and restoration of the pipeline right-of-way across waterbodies. Potential
indirect impacts of the projects on wetlands and waterbodies include runoff of stormwater into
nearby resources. However, TGP would implement its Plan and National Fuel would
implement its ESCAMP to ensure that the impacts on waterbodies are minimized. For many
of the existing aboveground facilities, there are sufficient vegetated buffers between the
proposed facilities and nearby wetlands and waterbodies. Therefore, we conclude that TGP
and National Fuel’s projects would not contribute to the cumulative impacts on wetlands or
waterbodies.
Vegetation and Wildlife
Projects that are constructed in the same general location and timeframe could have a
cumulative impact on local vegetation and wildlife communities. Construction activities
associated with the projects, combined with the clearing associated with wells constructed in
the vicinity, could result in cumulative impacts on vegetation and wildlife including the
removal of vegetation; alteration of wildlife habitat; displacement of wildlife; and other
potential secondary effects such as increased population stress, predation, and the
establishment of invasive plant species. These effects would be greatest during any overlap in
the construction timing of these projects. This may result in additional habitat fragmentation
where vegetation is modified from forest to either scrub-shrub or herbaceous classes.
However, this would be minimized due to the majority of TGP’s and National Fuel’s
proposed facilities being within existing facility sites or co-located with existing
infrastructure.
54
Impact on vegetation and wildlife from Marcellus Shale development would depend
on the duration of disturbance, with some disturbances potentially lasting for several years
(e.g., operation of well pads). Cumulative impacts from the Niagara Expansion Project and
the Northern Access 2015 Project would be minimal because of the relatively short duration
of construction and because disturbed areas would be restored soon after construction is
complete. Therefore, the Projects’ cumulative impacts on vegetation and wildlife are
anticipated to be minor.
Construction and operation of the projects are not likely to adversely affect any
federally listed or state-listed species, and this would not contribute to cumulative impacts on
sensitive species.
Land Use
The impacts of construction and operation of the projects would be minimized due to
the co-location of the facilities adjacent to existing compressor stations, meter stations, and
pipeline facilities. Construction of the facilities would add an additional 36 acres of
permanent impact. The primary impact on land use would be the conversion of 2.9 acres of
forested land to maintained right-of-way for TGP’s Project. All temporary construction areas
would be restored to their pre-construction conditions. Construction of the projects would
increase the size of the compressor station and meter station facilities and TGP’s right-of-way
along the 200 Line; however, this impact would not be significant due to the presence of the
existing facilities. The Hinsdale Compressor Station is a new aboveground facility and would
result in a change in land use from open land to industrial use. If construction of the Projects
overlaps with the gas development activities or any of TGP’s 2.55(a) activities, the primary
impact would be increased construction related traffic on area roads. These impacts,
however, would be temporary and limited to the construction period.
Because the proposed projects and the Mercer Compression Project involve
construction of facilities adjacent to existing infrastructure, we do not anticipate any
significant cumulative impacts on visual resources. Visual impacts from natural gas
development would include maintained rights-of-way for gathering and other pipelines; well
pads; compressor station; meter stations; and gas processing facilities. Where aboveground
facilities are located in close proximity to TGP and National Fuel’s projects, permanent visual
impacts would be expected. These impacts would be caused by the gas development itself
since aboveground work associated with the proposed projects would take place adjacent to
existing facilities. Temporary rights-of-way (for TGP’s Project and natural gas gathering
lines) would also be allowed to revert to pre-construction conditions. Therefore, only minor
and short-term cumulative impacts on visual resources are anticipated in the project area.
Air Quality and Noise
The Niagara Extension Project’s impacts on air quality would be related to
construction emissions of particulates that would occur on a temporary basis and would
subside once construction is complete. There are no permanent aboveground air emissions
sources associated with this project. The recent increase in natural gas transmission projects
in the northeast have been, in part, the result of the increased availability of natural gas
55
supplies from shale development and the need to transport those supplies to market.
Therefore, these interstate transmission pipelines are the effect, not the cause, of natural gas
production in the northeast. While there are Marcellus Shale development activities occurring
throughout the state, the Niagara Expansion Project would not contribute to air quality
impacts during operation, so there would be no cumulative impact from the project.
The Northern Access 2015 Project consists of modifications to the Concord
Compressor Station and construction of a new one, the Hinsdale Compressor Station.
Operation of these compressor stations would have long-term impacts on air quality. Section
B.6.1 provides an air quality analysis that demonstrates that the new and modified compressor
stations, when added to background concentrations of criteria pollutants, would not exceed
the NAAQS (tables 13 and 14). As previously discussed, the primary NAAQS were
established to protect human health, including those in sensitive populations such as the
elderly, children, and asthmatics. National Fuel’s modeling analysis was conducted in
accordance with NYSDEC Division of Air Resources-10: Guidelines for Dispersion Modeling
Procedures for Air Quality Impact Analysis and the EPA’s Guideline on Air Quality Models.
The ambient air quality data include air emissions from existing sources and, as such, is a
cumulative assessment of existing air quality. The Northern Access 2015 Project would have
incremental, minor air quality impacts. National Fuel’s air emissions when combined with
existing air emissions, based on monitoring data, would not be an exceedance of the
NAAQS.
Recent and planned projects would have an impact on air quality, but it is difficult to
quantify those impacts; however, we will qualitatively discuss these projects. Each state
maintains an EPA-approved SIP, as described in section B.6.1, that accounts for and manages
emissions within the state. Emissions sources must comply with SIP requirements, which
ensure that the NAAQS are not exceeded. As new sources of air emissions are planned,
appropriate permitting reviews must take place to ensure that, on their own merit and
cumulatively, these sources would not result in an exceedance of the NAAQS. Federal
regulatory programs, such as New Source Review, require companies to analyze the
implementation of technologies that would achieve lower emissions as part of the permit
application. We believe that federally enforceable SIPs adequately protect air quality. In
addition, any FERC-regulated project would incur an additional level of federal review.
Therefore, we conclude that, while there would be cumulative impacts associated with the
Projects during the life of the projects, these impacts would not be significant.
The Concord and Hinsdale Compressor Stations would add to cumulative noise
impacts. As demonstrated in section B.6.2, the noise from each compressor station would not
be perceptible by humans at the nearest NSAs. These noise levels take into account the
ambient noise, which would include any existing natural or man-made sources of noise. As
such, the noise analysis presented in section B.6.2 is a cumulative analysis. The Concord
Compressor Station and East Eden Meter Station are existing noise sources and the
modifications would represent a minor change in noise levels. The nearest NSAs to the
Hinsdale Compressor Station are at least a half-mile away from the proposed site.
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Conclusion
We identified recently completed, ongoing, and planned projects in the project areas
that met the criteria for inclusion in the cumulative impacts study. Cumulative impacts on air
quality and noise are possible, but the impacts are expected to be minimal and localized. In
addition, implementation of best-management practices, engineering controls, resource
protection, and the mitigation proposed would minimize environmental impacts for the
projects. This would mean that when the impacts of the projects are added to the impacts
from other identified projects, the cumulative impacts would be minimal.
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C. ALTERNATIVES
In accordance with NEPA, and FERC policies, we identified and evaluated
alternatives to the projects to determine whether they would be reasonable and
environmentally preferable to the proposed action. These alternatives included the no-action
alternative, system alternatives, route alternatives, and aboveground facility site alternatives.
Our evaluation criteria for selecting potentially environmentally-preferable alternatives are:
technical and economic feasibility and practicability;
substantial environmental benefits over the projects; and
ability to meet the project purpose of meeting the increased demand for
interstate gas transmission in the Northeastern U.S. and Eastern Canada.
1.0 No-Action Alternative
Under the No-Action Alternative, TGP and National Fuel would not implement the
proposed actions and the potential environmental impacts associated with the projects would
be avoided; however, the projects’ objective would not be met, of TGP to meet increased
demand for interstate natural gas transmission in the Northeastern U.S and Eastern Canada.
Other natural gas companies could construct projects to provide the natural gas service
offered by the projects. Such alternative projects could require the construction of additional
and/or new pipeline facilities in the same or other locations to transport the gas volumes
proposed by the Project. These projects would result in their own set of specific
environmental impacts that could be less than, equal to, or greater than those described for the
current proposal.
2.0 System Alternatives
TGP identified system alternatives using different pipeline system configurations to
provide 140,000 dekatherms per day. A potential TGP system alternative would involve
installation of a new greenfield pipeline instead of leasing transportation capacity from
National Fuel. This alternative would involve construction of approximately 76 miles of 16-
inch-diameter pipeline from TGP’s existing Station 313 to its Station 229 and the addition of
3,000 hp of compression at Station 313. Assuming a 95-foot-wide right-of-way, this
alternative would affect approximately 875 acres of land; therefore, this alternative would
result in greater environmental impacts, including more ground disturbance, and impacting
more landowners, forested land, waterbodies and wetlands than the proposed projects.
Another potential TGP system alternative would involve only looping its existing
pipeline system. A total of approximately 90 miles of pipeline loop would be needed to meet
the projects’ objective. Assuming a 95-foot-wide construction right-of-way, this alternative
would affect approximately 1,000 acres of land; therefore, this alternative would result in
58
more ground disturbance including impacts on more properties and landowners as well as
greater impacts on environmental resources such as forested land, waterbodies, and wetlands.
Although these system alternatives could meet the projects’ objective, they would
result in greater environmental impacts environmental resources and landowners. In addition,
there were no resource impacts from the proposed projects that drove the need to identifying
any additional system alternatives. Therefore, we determined that neither of these system
alternatives have a distinct environmental advantage over the proposed actions.
3.0 Alternative Pipeline Routes
Alternative pipeline routes are alternatives that vary from the proposed pipeline route
and may be major (deviate from the proposed route for an extended distance) or minor
(deviate from the proposed route for a short distance). TGP’s Loop 224 is adjacent to the
existing 200 Line right-of-way for its entire length; therefore, any newly identified alternative
routes would involve development of new right-of-way, resulting in greater environmental
impacts than the proposed pipeline route. Because TGP’s Project is co-located with existing
right-of-way, and was found to result in limited environmental impacts, we did not identify
any routing alternatives.
4.0 Aboveground Facility Site Alternatives
TGP’s proposed activities at Station 219 and 224 and the Hamburg Meter Station are
located within the existing aboveground facilities on land owned by TGP. Similarly, National
Fuel’s proposed facilities at the Concord Compressor Station and East Eden Station are
located within the company’s existing facilities. In addition, no sensitive resources would be
affected by TGP’s or National Fuel’s activities at these locations. Any site alternatives for
these facilities would result in greater environmental impacts and impacts on additional
landowners. Therefore, we did not examine any alternative sites for these facilities.
The proposed Hinsdale Compressor Station is located on three parcels that are
intersected by National Fuel’s Line X. The site is bordered by Phillips Road to the west and a
railroad to the east. Also to the east is Interstate 86 which impacts the ambient noise of the
area. No comments were received expressing opposition to the proposed location and the
proposed site does not affect any sensitive resources. In addition, the landowners are
agreeable to selling the land for the compressor station. Therefore, as noted in section B,
impacts of constructing and operating the compressor station would be minimized with
appropriate measures. No alternative site was identified that would provide a significant
environmental advantage.
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D. CONCLUSIONS AND RECOMMENDATIONS
Based on the analysis presented in this EA, we determined that if TGP and National
Fuel construct and operate the proposed facilities in accordance with their applications and
supplements, and our recommended mitigation measures, approval of these proposals would
not constitute a major federal action significantly affecting the quality of the human
environment. We recommend that the Commission Order contain a finding of no significant
impact and include the mitigation measures listed below as conditions to any Certificate the
Commission may issue.
1. TGP and National Fuel shall follow the construction procedures and mitigation
measures described in their applications and supplements (including responses to staff
data requests) and as identified in the EA, unless modified by the Order. TGP and
National Fuel must:
a. request any modification to these procedures, measures, or conditions in a
filing with the Secretary;
b. justify each modification relative to site-specific conditions;
c. explain how that modification provides an equal or greater level of
environmental protection than the original measure; and
d. receive approval in writing from the Director of OEP before using that
modification.
2. The Director of OEP has delegated authority to take whatever steps are necessary to
ensure the protection of all environmental resources during construction and operation
of the project. This authority shall allow:
a. the modification of conditions of the Order; and
b. the design and implementation of any additional measures deemed necessary
(including stop-work authority) to assure continued compliance with the intent
of the environmental conditions as well as the avoidance or mitigation of
adverse environmental impact resulting from project construction and
operation.
3. Prior to any construction, TGP and National Fuel shalleach file an affirmative
statement with the Secretary, certified by a senior company official, that all company
personnel, environmental inspectors (EIs), and contractor personnel will be informed
of the EI’s authority and have been or will be trained on the implementation of the
environmental mitigation measures appropriate to their jobs before becoming
involved with construction and restoration activities.
4. The authorized facility locations shall be as shown in the EA, as supplemented by filed
alignment sheets. As soon as they are available, and before the start of
construction, TGP and National Fuel shall each file with the Secretary any revised
detailed survey alignment maps/sheets at a scale not smaller than 1:6,000 with station
positions for all facilities approved by the Order. All requests for modifications of
environmental conditions of the Order or site-specific clearances must be written and
60
must reference locations designated on these alignment maps/sheets.
TGP’s and National Fuel’s exercise of eminent domain authority granted under NGA
section 7(h) in any condemnation proceedings related to the Order must be consistent
with these authorized facilities and locations. TGP’s and National Fuel’s right of
eminent domain granted under NGA section 7(h) does not authorize it to increase the
size of its natural gas pipeline to accommodate future needs or to acquire a right-of-
way for a pipeline to transport a commodity other than natural gas.
5. TGP and National Fuel shall each file with the Secretary detailed alignment
maps/sheets and aerial photographs at a scale not smaller than 1:6,000 identifying all
route realignments or facility relocations, and staging areas, pipe storage yards, new
access roads, and other areas that would be used or disturbed and have not been
previously identified in filings with the Secretary. Approval for each of these areas
must be explicitly requested in writing. For each area, the request must include a
description of the existing land use/cover type, documentation of landowner approval,
whether any cultural resources or federally listed threatened or endangered species
would be affected, and whether any other environmentally sensitive areas are within or
abutting the area. All areas shall be clearly identified on the maps/sheets/aerial
photographs. Each area must be approved in writing by the Director of OEP before
construction in or near that area.
This requirement does not apply to extra workspace allowed by TGP’s Plan and
National Fuel’s ESCAMP and/or minor field realignments per landowner needs and
requirements which do not affect other landowners or sensitive environmental areas
such as wetlands.
Examples of alterations requiring approval include all route realignments and facility
location changes resulting from:
a. implementation of cultural resources mitigation measures;
b. implementation of endangered, threatened, or special concern species
mitigation measures;
c. recommendations by state regulatory authorities; and
d. agreements with individual landowners that affect other landowners or could
affect sensitive environmental areas.
6. Within 60 days of the acceptance of the Certificate and before construction begins, TGP and National Fuel shall each file an Implementation Plan with the
Secretary for review and written approval by the Director of OEP. TGP and National
Fuel must file revisions to the plans as schedules change. The plan shall identify:
a. how TGP and National Fuel will implement the construction procedures and
mitigation measures described in their applications and supplements (including
responses to staff data requests), identified in the EA, and required by the
Order;
61
b. how TGP and National Fuel will incorporate these requirements into the
contract bid documents, construction contracts (especially penalty clauses and
specifications), and construction drawings so that the mitigation required at
each site is clear to onsite construction and inspection personnel;
c. the number of EIs assigned, and how the company will ensure that sufficient
personnel are available to implement the environmental mitigation;
d. company personnel, including EIs and contractors, who will receive copies of
the appropriate material;
e. the location and dates of the environmental compliance training and
instructions TGP and National Fuel will give to all personnel involved with
construction and restoration (initial and refresher training as the project
progresses and personnel change);
f. the company personnel (if known) and specific portion of TGP’s and National
Fuel's organizations having responsibility for compliance;
g. the procedures (including use of contract penalties) TGP and National Fuel
will follow if noncompliance occurs; and
h. for each discrete facility, a Gantt or PERT chart (or similar project scheduling
diagram), and dates for:
i. the completion of all required surveys and reports;
ii. the environmental compliance training of onsite personnel;
iii. the start of construction; and
iv. the start and completion of restoration.
7. TGP and National Fuel shall each employ at least one EI per construction spread. The
EI shall be:
a. responsible for monitoring and ensuring compliance with all mitigation
measures required by the Order and other grants, permits, certificates, or other
authorizing documents;
b. responsible for evaluating the construction contractor's implementation of the
environmental mitigation measures required in the contract (see condition 6
above) and any other authorizing document;
c. empowered to order correction of acts that violate the environmental
conditions of the Order, and any other authorizing document;
d. a full-time position, separate from all other activity inspectors;
e. responsible for documenting compliance with the environmental conditions of
the Order, as well as any environmental conditions/permit requirements
imposed by other federal, state, or local agencies; and
f. responsible for maintaining status reports.
8. Beginning with the filing of their Implementation Plans, TGP and National Fuel
each shall file updated status reports with the Secretary on a biweekly basis until all
construction and restoration activities are complete. On request, these status
reports will also be provided to other federal and state agencies with permitting
responsibilities. Status reports shall include:
62
a. an update on TGP’s and National Fuel’s efforts to obtain the necessary federal
authorizations;
b. the construction status of the project, work planned for the following reporting
period, and any schedule changes for stream crossings or work in other
environmentally-sensitive areas;
c. a listing of all problems encountered and each instance of noncompliance
observed by the EI during the reporting period (both for the conditions
imposed by the Commission and any environmental conditions/permit
requirements imposed by other federal, state, or local agencies);
d. a description of the corrective actions implemented in response to all instances
of noncompliance, and their cost;
e. the effectiveness of all corrective actions implemented;
f. a description of any landowner/resident complaints which may relate to
compliance with the requirements of the Order, and the measures taken to
satisfy their concerns; and
g. copies of any correspondence received by TGP or National Fuel from other
federal, state, or local permitting agencies concerning instances of
noncompliance, and TGP’s or National Fuel’s response.
9. Prior to receiving written authorization from the Director of OEP to
commence construction of any project facilities, TGP and National Fuel
shall each file with the Secretary documentation that it has received all
applicable authorizations required under federal law (or evidence of waiver
thereof).
10. TGP and National Fuel must receive written authorization from the Director of OEP
before placing the project into service. Such authorization will only be granted
following a determination that rehabilitation and restoration of the right-of-way and
other areas affected by the project are proceeding satisfactorily.
11. Within 30 days of placing the authorized facilities in service, TGP and National
Fuel shall file an affirmative statement with the Secretary, certified by a senior
company official:
a. that the facilities have been constructed in compliance with all applicable
conditions, and that continuing activities will be consistent with all applicable
conditions; or
b. identifying which of the Certificate conditions TGP and National Fuel have
complied with or will comply with. This statement shall also identify any
areas affected by the project where compliance measures were not properly
implemented, if not previously identified in filed status reports, and the reason
for noncompliance.
12. Prior to construction, TGP should complete its consultation with the NYSDAM
regarding impacts on agricultural lands, and file with the Secretary documentation of
this consultation and any additional mitigation measures TGP plans to incorporate in
its project design.
63
13. Prior to construction, TGP should provide documentation of FWS approval for the
withdrawal of hydrostatic test water from French Creek or provide an alternate source
of hydrostatic test water.
14. National Fuel shall not begin construction of facilities and/or use of any staging,
storage, or temporary work areas and improved access roads until:
a. National Fuel files with the Secretary:
i. remaining cultural resources survey reports and addendums;
ii. site evaluation reports and avoidance/treatment plans, as required; and
iii. comments on the cultural resources reports, addendums and plans from the
New York SHPO;
b. the ACHP is afforded an opportunity to comment if historic properties would
be adversely affected; and
c. the FERC staff reviews and the Director of OEP approves the cultural
resources reports and plans, and notifies National Fuel in writing that treatment
plans/mitigation measures (including archaeological data recovery) may be
implemented and/or construction may proceed.
All materials filed with the Commission containing location, character, and
ownership information about cultural resources must have the cover and any relevant
pages therein clearly labeled in bold lettering: “CONTAINS PRIVILEGED
INFORMATION - DO NOT RELEASE.”
13. National Fuel shall file noise surveys with the Secretary no later than 60 days after
placing the Hinsdale and Concord Compressor Stations in service. If full load
condition noise surveys are not possible, National Fuel shall provide interim surveys at
the maximum possible load and provide a full load survey within 6 months. If the
noise attributable to the operation of all of the equipment at the Hinsdale and Concord
Compressor Stations under interim or full load conditions exceeds a day-night level
(Ldn) of 55 decibels on the A-weighted scale (dBA) at any nearby noise-sensitive
areas, National Fuel shall file a report on what changes are needed and shall install the
additional noise controls to meet the level within 1 year of the in-service date.
National Fuel shall confirm compliance with the above requirement by filing a second
noise survey with the Secretary no later than 60 days after it installs the additional
noise controls.
14. National Fuel shall file a noise survey with the Secretary no later than 60 days after
placing the modified facilities at the East Eden Meter Station in service. If the noise
attributable to the operation of the modified equipment at the meter station at
maximum flow conditions exceeds predicted noise levels at any nearby noise-sensitive
areas, National Fuel shall file a report on what changes are needed and shall install the
additional noise controls to meet the level within 1 year of the in-service date.
National Fuel shall confirm compliance with the above requirement by filing a second
64
noise survey with the Secretary no later than 60 days after it installs the additional
noise controls.
Appendix A
Project Maps
A-1
A-2
A-3
A-4
A-5
A-6
A-7
B-1
Appendix B - List of Preparers
Allen, Christine E. – Project Manager, Project Description, Water Resources, Vegetation,
Wildlife, Threatened and Endangered Species, Geology and Soils, Land Use,
Cumulative Impacts, Alternatives B.S., Marine Biology, 2005, University of North Carolina, Wilmington
Harris, Jessica – Air and Noise, Reliability and Safety
B.S., Mechanical Engineering, 2006, Clark Atlanta University
Howard, Eric – Cultural Resources
M.A., Anthropology, 1997, University of Tennessee
B.A., Anthropology, 1992, University of Tennessee
![Beverage Holdings, L.L.C. v. 5701 Lombardo, L.L.C. (Slip ...Beverage Holdings, L.L.C. v. 5701 Lombardo, L.L.C., Slip Opinion No. 2019-Ohio-4716, 2019-Ohio-4716.] NOTICE This slip opinion](https://img.dokumen.tips/doc/110x75/5f812130bcd9fd43d43f5b4f/beverage-holdings-llc-v-5701-lombardo-llc-slip-beverage-holdings.jpg)
