The Mission: Select and Deliver a Clear Pipeline Right of Way
Delivering a clear right of way for pipeline projects presents an environmental and permitting challenge requiring a multi-faceted approach. Pipeline projects should include an environmental regulatory review during the alignment selection phase, assessment during the property acquisition phase, and testing and monitoring during the construction phase. Environmental specialists are an integral part of any pipeline project team from concept through construction. Their efforts support the decision process for alignments, costs, and schedule, ensuring there are no surprises and all permit requirements are met. A few of the areas of expertise required by the team are geology, historical architecture, threatened and endangered species, archaeology, and hazardous materials. Depending on site conditions and funding requirements, environmental due diligence will range from a regulatory review and Phase I site assessments to environmental impact statements conforming to the Texas Water Development Board or the National Environmental Policy Act. The proper implementation of the environmental process minimizes the risk of both the owner and the contractor, resulting in cost and schedule savings.
Environmental Due Diligence
During initial planning, a review of environmental regulatory records or a hazardous materials site review should be conducted to identify potential high-risk areas that can be avoided by using an alternate alignment. A visual reconnaissance of the proposed alignment to identify potential sites or areas of concern that may not be included in the regulatory records should be performed. Once the alignment is defined, Phase I Environmental Site Assessments (ESAs) should be conducted to identify current and/or historic on-site and nearby operations that may affect the proposed pipeline right of way. To be eligible for certain protections under the Comprehensive Environmental Response, Compensation and Liability Act, ESAs are performed in accordance with the Environmental Protection Agency All Appropriate Inquiries (AAI) rule.
If the Phase I assessment identifies potential environmental issues, a Phase II Subsurface Investigation is performed to determine if soil and/or groundwater contamination exists. Based on the extent of contamination identified, options can be evaluated to address the issue. These options may include soil/groundwater remediation as part of a regulatory cleanup and closure program or development of a site-speciﬁc soil and groundwater management plan to guide construction contractors.
Removal of Above and Underground Structures
A common issue encountered on pipeline projects is the presence of buildings, petroleum or propane storage tanks, water wells and septic systems. Each of these systems have different regulations for removal and closure. EPA National Emission Standards for Hazardous Air Pollutants require that prior to demolition of a structure, a thorough inspection for asbestos-containing building material must be conducted by a licensed asbestos inspector. If asbestos is present in a regulated quantity, then proper abatement and disposal of the asbestos-containing material is required before conducting demolition activities. Coordination of utility termination of existing water, gas, electric service and in some cases capping of sanitary sewer lines is an integral part of demolition. An historical review to determine if the structures fall under federal, state or local archaeological or historic preservation standards is generally required on public projects.
An often overlooked aspect of right of way clearance is security and maintenance of the property in the period of time between acquisition and construction. Securing the property until demolition can occur is often required for public safety and can be an unforeseen cost. Maintenance of the property to meet the municipality’s ordinances is often required. This can add an additional burden to the owner’s maintenance personnel if not properly planned for. Additional requirements as part of issuing the demolition permit for a structure may include conducting a tree survey of the site and pest/rodent abatement.
Proper implementation of environmental due diligence during a pipeline project reduces risk for both the owner and the contractor by eliminating unforeseen construction delays and ensuring timely permit applications and design and construction are in compliance with permit requirements. Maintaining the environmental personnel through design and construction is critical to success. Whether the issue is hydrocarbons, asbestos, historical preservation or demolition, Halff has the experts to assist you. If Halff can assist your team with a water utility issue, please call Executive Vice President Jessica Baker, PE, CFM, PMP, at (214) 217-6692.
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Texas Regional Stormwater Conference
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Jan. 14, 2021