An Integrated Approach To Environmental Compliance Pays Off.
Although the logistics of managing environmental compliance on projects of such magnitude are daunting, the success of both Alliance and Maritimes was due in part to the integrated environmental management, training, and inspection approach applied to both jobs throughout construction. According to Jayne Battey, president of Essex Environmental, "Both projects demonstrated a strong commitment to their environmental programs and understood the importance of having a comprehensive environmental management program integrated with the construction effort."
The 2,322-mile Alliance project stretches across three Canadian provinces and four U.S. states. "The sheer magnitude of the project made it seem unlikely, and it was difficult initially to get people to believe that it was a real project," said Steve Dracos, Alliance project director.
While the pipeline covers many territories and states, it primarily traverses previously disturbed ground. Almost 90 percent of the U.S. segment crosses actively farmed parcels, many with adjacent pipelines.
While working in previously disturbed fields may seem to preclude the usual environmental concerns, Jay Godfrey, manager of communications for Alliance, emphasized the importance of the environmental issues for the landowners and Alliance.
"Of over 5,800 landowners whose land we crossed, their soil, water, and ability to drain the water constitutes their environment. These (issues) certainly are important to the landowners, and they certainly are important to us," Godfrey said. Protection of this land along with the water resources, native prairie wetlands and erosion control was the focus of Alliance's environmental program.
At the outset, Alliance developed innovative environmental planning techniques. The pipeline company invited over 80 environmental groups to "help us design appropriate mitigation measures to enhance the environment or mitigate against loss," Godfrey explained. "We recognized that in the course of crossing this vast distance there would be certain environmental groups who would have interest in what we were doing and have a good knowledge and understanding of those particular issues. This unusual step promoted cooperation instead of the typical adversarial relationship. We wanted to change the paradigm and make it a cooperative approach."
Another major component to the Alliance environmental program was the training and inspection provided by Essex Environmental. Alliance staffed each spread (in the U.S.) with three to four environmental inspectors, which included at least one agricultural specialist with experience in soil and farming issues. At the peak of construction, there were about 25 environmental inspectors on the pipeline who helped contractors avoid potential impact to properties and ensured that necessary mitigation measures were completed.
Third Party Inspection Program
Emphasizing cooperation, Alliance and the Federal Energy Regulatory Commission (FERC) launched an experimental government monitoring program known as the FERC Third Party Inspection Program. Because of the size of the project, Alliance anticipated numerous field changes that would need approval from the commission. Although not the only agency with jurisdiction over the pipeline, the FERC is the chief agency that regulates the construction and operation of the nation's interstate gas pipelines. When the FERC authorizes a project, it oversees compliance on all federal laws related to pipeline construction including environmental laws. "Our role during construction is in one word: compliance," said Michael Boyle, a FERC environmental project manager.
Alliance and the FERC introduced the program to ensure compliance and streamline the variance process by keeping agency monitors in the field. The FERC requires companies to submit every construction variance in writing to their Washington, D.C. office. The process burdens the companies, the FERC, and invariably costs both parties time and money. The program created a means for companies to provide immediate notification to the FERC via monitors in the field who could often respond with immediate approval for minor variances and expedite changes that are more complex. According to Tom Neenan, Essex's lead environmental inspector on Spread 3 of the Alliance Pipeline, "The program made my life a whole lot easier. The Third Party monitors also provided significant advice and input for the project."
New Landowner Agreements
Alliance also sought new agreements with landowners. In the states of Illinois, Minnesota, Iowa, and North Dakota, Alliance negotiated with farming interests to develop comprehensive agricultural mitigation agreements. The agreements, which exceeded federal and state requirements, addressed many issues important to farmers, including depth of cover, topsoil conservation, and drainage tile repair.
Protecting drain tiles was a major issue in the agricultural agreement. Years ago, farmers installed underground networks of drain tiles in their land to allow water to percolate through the ground, into the tiles, and away from their fields. "In the old days, wetlands were bad and the government helped the farmers drain the wetlands and provided funding to put in drain tiles," said Dracos. "We had around 10,000 drain tile crossings. The repairs cost roughly $20 million. That was in our original estimate, and we fixed them in accordance with the agricultural agreements."
The pipeline company also agreed to numerous measures to prevent soil compaction damage. Local county inspectors were authorized to halt construction temporarily if they decided that, due to wet conditions, continued construction activity would damage the future production capacity of the land through soil compaction and mixing. Alliance agreed to test for compaction for any claim of damage and, if necessary, pay the costs of soil restoration. Farmers won't know if the soil was properly decompacted until this year's growing season, "but we ran (decompaction) tests and don't expect any problems," Dracos said.
The 200-mile-long U.S. portion of the Maritimes project crossed 425 streams, nearly 2,000 wetland areas, Atlantic salmon spawning habitat, and numerous protected species and cultural resources areas. Crossing such sensitive habitat drew the close attention of federal, state and local agencies as well as local residents.
To balance construction, environmental and community needs, the Maritimes team spent more than three years designing the project and refining the route. Planners chose access roads and routes through the sensitive habitats that satisfied the agencies and reduced problems for the contractors.
This level of planning required a strong environmental commitment. "A major component to the success of this project was that Maritimes had a tremendous commitment and lived by that commitment," said Steve Craycroft, Essex project manager and the Maritimes environmental compliance supervisor during construction. Maritimes worked closely with federal and state environmental agencies to ensure that the project complied with all regulations and permit conditions.
"Obviously, with a project of this magnitude--crossing multiple rivers and streams, and traversing several hundred miles of real estate--we had a lot of issues to address," said Gus McLachlan, environmental manager for Maritimes. "We worked hard at minimizing the project's impact on Maine's natural resources, archaeology, and wildlife."
To help minimize impacts, Maritimes employed 14 full-time Essex Environmental inspectors who coordinated with agency monitors from the FERC and the Maine Department of Environmental Protection (DEP).
"Our inspectors were highly visible throughout the project," Craycroft said. "We developed effective relationships with the agencies so that they developed a high level of confidence in the project. If there were problems, they could contact one of our environmental inspectors and that problem would be taken care of. We also implemented a comprehensive environmental training program, providing all project staff with a level of understanding that environmental compliance was everyone's responsibility."
On several occasions, the agencies expressed concern about stream crossings. Maritimes took steps to implement added protection measures, including multi-directional drilling and frequent dam and pump operations. Throughout the project, Maritimes continued to implement extraordinary best management practices and numerous innovative stream crossing methods.
Maritimes completed construction of the natural gas pipeline in 1999 and will finish restoration of the right-of-way this spring. Restoration crews also found that cleanup sometimes requires innovative methods. Recently, to prevent damage to the right-of-way caused by using heavy equipment, the Maritimes crew used a horse and slip scoop for repair work. The scoop, pulled like a plow behind a draft horse, was used to repair an area that was nearly inaccessible. "We had a lot of material to put back, and ideally a dozer would have done it, but there were a lot of steep slopes and stream crossings. The only way back in (with mechanized equipment) was to install bridges," explained Joe Schaeffer, Essex inspector on Maritimes. "Even though it was slow, in the long run it was a lot better than bringing equipment in there."
New Construction Approach
Many pipeline companies are transforming the industry by changing the way they do business. The proactive and integrated approach to environmental management on pipeline construction has caught up to and, in some cases, exceeded federal and state environmental mandates. Evidence of this transformation is in the environmental commitments of companies like Alliance and Maritimes.
By comparison, in the early 1990s a major pipeline company in the East failed to comply with protective measures for streams and wetlands. The company reportedly left mounds of soil standing in wetlands, damaging aquatic habitats. The action triggered a criminal investigation that ended in 1996 when the company's president and three other top construction managers pleaded guilty to Clean Water Act violations. A settlement agreement required the company to pay tens of millions of dollars in criminal and civil penalties.
With the increasing construction of gas pipelines across the U.S., companies can expect continued attention on environmental issues from federal and state agencies, environmental groups, the media, and landowners. Companies that integrate management strategies from the early stages of planning through to final restoration will find a higher likelihood for projects built on time, on budget, and without regulatory penalties.
According to Battey, "The more complex the project, the more important it is to take a strategic, integrated approach. In today's regulatory climate, you have to be smart about environmental compliance and think it through from start to finish."
by Kevin Kilpatrick, Technical Writer, Eugene, Oregon
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|Publication:||Pipeline & Gas Journal|
|Date:||May 1, 2000|
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