SYSTEM SAFETY AND RISK OF UPSET MITIGATION MEASURES
Mitigation Measure SS-1: The Applicant shall provide structural support for underground utilities in and near the construction area during work in the trench and backfilling operations to prevent damage to such facilities during construction activities.
Impact: Construction could impact existing utilities and affect a large number of people (Class III).
Performance Criteria, Violation Level, and Timing:
PC1 Structural support shall be provided if any damage is expected. For example, if a sag deflection of 2 inches is expected or observed, support shall be provided. (Level 3) - During construction.
PC2 A list of utilities for which support is expected to be provided shall be submitted to CPUC/ANF monitors 7 days before that particular activity is conducted (Level 2) - During construction.
PC3 PPSI shall inspect the construction activities to identify any unacceptable sag deflection (Level 1) - During construction.
Effectiveness Criteria: No damage during construction to utilities in and near the construction area
Effectiveness Timing: During project construction
Mitigation Measure SS-2: The Applicant shall use hand tools (i.e., non-motor operated equipment) in utility intensive areas and within 24 inches of underground structures. Any soil remediation or excavation work in the vicinity of the pipeline shall also require the use of hand tools within 24 inches of the pipeline.
Impact: Construction could impact existing utilities, which in turn could affect a large number of people or damage the environment (Class III).
Performance Criteria, Violation Level, and Timing:
PC1 PPSI submits a list of locations with intensive utility lines (more than 2) and expected to be worked on in a close proximity (equal or less than 24 inches) to CPUC/ANF monitors 7 days before starting of construction activities in a particular location. (Level 2) - During construction.
PC2 Contractor shall sign a memo that they are aware of this requirement and use of hand tools in identified locations (to be kept at site by PPSI) (Level 3) - During construction.
Effectiveness Criteria: No damage during construction to utilities in and near the construction areas
Effectiveness Timing: During project construction
Mitigation Measure SS-3: The Applicant shall halt work in the immediate vicinity in the event of inadvertent damage to an underground utility, until the owner of the utility has been contacted and repairs have been effected.
Impact: Construction could impact existing utilities (Class III)
Performance Criteria, Violation Level, and Timing:
PC1 PPSI identifies in the Utility Plan existing pipelines including their owner named, a focal point of contact and 24-hour telephone number. (Level 3) - Submitted to CPUC/ANF 60 days prior to start of construction.
PC2 The owner of the damaged utility shall be notified within 10 minutes of damage. (Level 2) - During construction.
PC3 Work shall be halted immediately in the vicinity of any damaged pipeline, until the owner has been contacted and repairs are successfully completed. (Level 3) - During construction.
PC4 If the pipeline was not identified before by PPSI and USA, the work in the area immediately adjacent to the damaged line shall halt until identification of the owner and successful completion of the repairs. (Level 3) - During construction.
Effectiveness Criteria: Timely repairs of accidental damages and cooperative relationship with utility owners
Effectiveness Timing: During Project Construction
Mitigation Measure SS-4: The Applicant shall notify owners through the office of Underground Service Alert (USA) of any underground facilities (including electrical, water, gas, petroleum pipelines, fiber-optics, and agricultural water delivery and drainage pipelines) 48 hours in advance of excavation in the vicinity of these facilities. The Applicant shall have an electrical contractor on-call at all times during construction near the potentially affected facility to repair any circuits if required by the owner in the event they are damaged during construction. The appropriate response to hazards associated with damage to natural gas pipelines will be determined in consultation with natural gas utility operators and local fire departments. Local fire departments shall be notified of the schedule for construction activities in the vicinity of natural gas and other oil pipelines. (See Section C.11, Public Utilities and Energy, for a description of other underground utilities along the proposed pipeline ROW)
Impact: Construction could impact existing utilities (Class III).
Performance Criteria, Violation Level, and Timing:
PC1 PPSI provides to CPUC/ANF designee a copy of the request made to USA. (Level 2) - During construction
PC2 PPSI shall provide a copy of an agreement/contract with a registered electrical contractor who will be available on an on-call basis in the Utility Plan . (Level 2) - Prior to construction (in Utility Plan).
PC3 PPSI shall notify all appropriate Fire Departments of the construction schedule in the vicinity of oil and gas pipelines 14 days before the construction day. Copy of the notification shall be send to CPUC/ANF. In the event of an accident associated with these oil and gas lines the owners and fire department shall be notified within 10 minutes of the occurrence of the accident (Level 3) - During construction.
Effectiveness Criteria: Damage to utilities prevented. Rapid respond to accidents. Cooperative relationship with the utilities and the fire Department before and after any accident involving oil and gas pipelines
Effectiveness Timing: During Project Construction particularly after an accident which involves any oil and gas pipelines.
Mitigation Measure SS-5: The Applicant shall prepare a Fire Protection Plan (FPP) and a Hazardous Materials Management Plan (HMMP) for all areas along the pipeline ROW for the construction phase of the project. Contingency analysis and planning shall be conducted to identify fire situations, how to minimize their occurrence, and how to respond should they actually occur. Local Fire Departments shall review the plans based on their specific needs and resources. The plans shall assure that locations and conditions for storage of fuels comply with rules set forth in the Uniform Fire Code and National Fire Codes. The FPP shall include specific measures to avoid impacts on cultural resources, sensitive habitats, and sensitive biological resources identified in other sections of this EIS/SEIR. These plans shall be approved by the CPUC, ANF, and local fire jurisdictions and the environmental monitoring authority for the appropriate discipline.
Impact: Construction could cause fire in high hazard areas or could expose public or construction workers to hazardous substances (Class III)
Performance Criteria, Violation Level, and Timing:
PC1 The construction phase FPP and HMMP shall be submitted to CPUC and ANF for their approval and the local fire department for review and comments 60 days before the construction date. (Level 3) - 60 days before the construction
PC2 The FPP shall assure that locations and conditions for storage of fuels comply with rules set forth in the Uniform Fire Code and National Fire Codes. The plan shall identify and analyze potential fire scenarios and discuss the prevention and effective response procedures. The plan shall include specific measures to avoid impacts on cultural resources, sensitive habitats, and sensitive biological resources identified in other sections of this EIS/SEIR. (Level 2 ) - 60 days before the construction.
Effectiveness Criteria: The plan can be relied on to prevent a lot of potential hazardous scenarios, and will be effectively used in minimizing the fire or hazard exposure to the maximum extent. The plan also result in minimum impacts to other environmental resources (e.g., biological and cultural resources) during response to an accident.
Effectiveness Timing: Prior to Project Construction and during responses to accidents.
Mitigation Measure SS-6: The Applicant shall implement recommendations for geotechnical studies, Mitigation Measures G-3 and G-4, and 40 CFR 195 110 for proper pipeline and above-ground facilities design features in fault zones to accommodate potential ground movement. Section 419 of ANSI Standard B31-4 [sic, should be B31.4] must be followed in providing for expansion and flexibility. Develop and implement a program for routine inspections of mainline valves twice annually. The valves shall be checked for mechanical integrity. Remotely activated block valves shall be checked to ensure they operate automatically within 60 seconds. Check valves should be checked annually to assure proper functioning. Maintenance records shall be retained for inspection by the State Fire Marshal.
Impact: Fault rupture could damage pipeline and cause oil spill (Class I).
Performance Criteria, Violation Level, and Timing:
PC1 PPSI shall comply with recommendations developed as a result of geologic studies conducted under mitigation measures required for the project (Geology measures) (Level 3) - 60 days before construction.
PC2 Provide CPUC/ANF with proof of compliance with 40 CFR 195 110, and Section 419 of ANSI Standard B31.4 in their Geotechnical Report to be submitted 60 days before the Construction. (Level 3) - Prior to pipeline operation.
PC3 PPSI develops, implements, and maintains records of routine inspection program for mainline and check valves. (Level 2) - Prior to pipeline operation.
Effectiveness Criteria: Final design which incorporates geotechnical recommendations and is in compliance with all regulations and applicable standards.
Effectiveness Timing: Project Design
Mitigation Measure SS-7: The Applicant shall implement internal corrosion prevention techniques in accordance with the requirements of the California State Fire Marshal (49CFR195.418) as part of the pipeline maintenance procedures. Such activities shall include routinely scheduled pigging of the pipeline to remove pockets of accumulated fluids that contribute to internal corrosion (such as hydrogen sulfide, carbon dioxide, and water), the use of corrosion inhibitors and corrosion coupons, and periodic testing by a state-of-the-art "smart pig" to identify areas where corrosion, pipewall thinning, dents, cracks, and other defects have occurred. Specific measures are discussed below:
$ Whenever any section of the pipe is removed for any reason, it shall be inspected for possible internal corrosion and records retained for inspection by the State Fire Marshal.
$ The pipeline shall be tested with a state-of-the-art "smart pig" to identify areas where corrosion, pipewall thinning, dents cracks and other defects have occurred. State-of-the-art pigging will be capable of defining wall-thickness contours around any area of reduced wall thickness. The smart pigging will be done every year. A program of maintenance shall be developed to ensure that permits to perform the work are obtained as soon as possible and that pipeline defects are rectified within one month of securing the necessary permits for severe defects, and within six months for moderate defects.
Impact: Pipeline corrosion could cause pipeline leaking or rupture and result in oil spill (Class I).
Performance Criteria, Violation Level, and Timing:
PC1 To be developed for the Operation Phase MMCRP
Effectiveness Criteria: Maximum corrosion protection.
Effectiveness Timing: During project operation.
Mitigation Measure SS-8: The Applicant shall coat the pipeline with extruded polyethylene with side extruded butyl rubber to reduce the potential for external corrosion or use the proposed fusion epoxy coating if it could be proven (to the satisfaction of the California State Fire Marshal) that the coating could provide the same level of protection as the recommended mitigation measure for all operating conditions.
Impact: Pipeline corrosion could result in oil spill (Class I).
Performance Criteria, Violation Level, and Timing:
PC1 PPSI to submit a report identifying their selected coating. If the coating selected is not extruded polyethylene, provide CSFM approval of the selected coating. (Level 1) - Prior to construction.
Effectiveness Criteria: CSFM satisfaction that the best available anti-corrosion coating has been used for this project
Effectiveness Timing: Prior to project construction.
Mitigation Measure SS-9: The Applicant shall make a good faith effort to establish a cooperative organization whose members will include the pipeline operators in the study area (which would include PPSI, ARCO Pipe Line, Mobil, All American, Texaco, Chevron, and possibly The Gas Company). The purpose of this organization shall be to exchange information, initiate self-regulation, use joint resources for spill prevention, emergency response, and cleanup. Since the failure of each pipeline will have a drastic effect on regulation and operation of others, the members of this organization have internal incentives to cooperate despite their competition in the market. For example, the Institute of Nuclear Power Operations (INPO) formed after the Three-Mile Island accident, has been greatly effective in self-regulation and increasing the overall safety in the nuclear industry (J.V. Rees, 1994).
Impact: Multiple pipelines result in increased risk of oil spill (Class I).
Performance Criteria, Violation Level, and Timing:
PC1 Provide CPUC/ANF with copies of letters sent to, letters received from, and non-confidential minutes of meetings arranged with high level managers of the pipeline operators in the study area, urging them to consider forming a cooperative organization and discussing the benefits of this arrangement for all parties involved (citing similar cooperative arrangements between utility operators that face relatively high risk accidents and are subject to intense public scrutiny.). (Level 1) - Prior to operation.
Effectiveness Criteria: Effective exchange of information; sharing of resources has started.
Effectiveness Timing: Initiate during construction and the pre-operation period.
Mitigation Measure SS-10: After every 20 years of operation, the Applicant shall conduct a full analysis of the pipeline components for safety and reliability purposes. This analysis is in addition to the normal maintenance and inspection required, and should include the results of a comprehensive "smart pig" inspection, the integrity check on pump stations, heaters, storage tanks, valves, communication systems, and other components. A full report on the status of the entire system, any potential deficiencies, and the remedial actions should be prepared. This report should be submitted to CPUC, ANF, and the California State Fire Marshal or their successors. The continued operation of the pipeline after 20 years should be dependent on these agencies' approval of the safety status as presented by the Applicant.
Impact: Aging pipeline is more likely to rupture and cause oil spill (Class I).
Performance Criteria, Violation Level, and Timing:
PC1 To be developed during the preparation of the operation phase MMCRP
Effectiveness Criteria: Report confirms overall safety and system integrity.
Effectiveness Timing: Every 20 years of operation
Mitigation Measure SS-10a: The Applicant shall use wall thickness of 0.500-inch for the pipeline between EMP 25 and EMP 42 to minimize the likelihood of rupture and resultant oil spill impacts on the supplies of drinking water at Pyramid and Castaic Lakes. Also, the Applicant shall use 0.500-inch pipeline at all fault and stream crossings outside of this area.
Impact: Significant earthquakes could cause a pipeline rupture, which in turn would cause an oil spill (Class I).
Performance Criteria, Violation Level, and Timing:
PC1 30 days before construction) with copies of the pipeline purchase order that identifies the ordered pipeline specifications. (Level 3) - During construction.
PC2 The construction plans shall identify the usage of the 0.500 inch pipe at EMP 25 to EMP 42 and at fault and stream crossings. (Level 2 ) - Prior to construction.
PC3 EMs shall conduct spot checks and manually measure the pipeline thicknesses, specially at the above location. (Level 3) - During construction.
Effectiveness Criteria: The pipeline installed complies with the required wall thickness.
Effectiveness Timing: During Construction
Mitigation Measure SS-11: The Applicant shall install even speed and vibration sensors at all pump stations to shut down the pipeline automatically in the event that threshold acceleration should be exceeded. Such devices shall be required to detect earthquakes with intensity of 6.0 or more. The petroleum industry has some objections to automatic shutdown systems because erroneous shut down procedures have caused accidents. Should the Applicant disagree with this mitigation, they shall prepare a report and clearly demonstrate (to the satisfaction of CPUC, ANF, and CSFM) that these sensors would result in more oil spill accidents than they would prevent.
Impact: Earthquakes would result in pipeline ruptures and oil spills. Continued pumping after a rupture would significantly increase the spill volume (Class I).
Performance Criteria, Violation Level, and Timing:
PC1 The construction plan shall specify installation of the even speed and vibration sensors at all pump stations. (Level 3) - Prior to construction at pump stations
PC2 The sensors shall be designed for automatic shut down when an earthquake with an intensity of 6.0 or greater (on the Richter scale) is detected. (Level 3) - Prior to installation at pump stations.
or
PC3 If PPSI does not plan to install these sensors, they shall submit a report 60 days prior to pipeline construction demonstrating (to the satisfaction of CPUC, ANF, and CSFM) that these sensors would result in more oil spill accidents than they would prevent. The agencies will inform PPSI of their determination 30 days after receive of a satisfactory report. (Level 3) - 60 days prior to construction.
Effectiveness Criteria: Final design which incorporates vibration sensors. Pumps shut down in the event of earthquake.
Effectiveness Timing: Preconstruction, during project construction, and evaluate pump shut down after an earthquake.
Mitigation Measure SS-12: In Section C.6 (Geology), the potential for landslides and slope instability to affect the proposed pipeline is identified. In Section C.7 (Hydrology), the potential effect of an oil spill on California Aqueduct and other water resources is discussed. In order to reduce potential impacts in these situations, additional valves are recommended. To further reduce the potential oil spill impacts on major water supply reservoirs, additional block and check valves beyond those proposed by the Applicant shall be located between EMP 26 and 59 as described below. Further, in this Section (C.13), the largest potential oil spill is identified, based on a long segment of the proposed pipeline for which the Applicant proposed no valves. To reduce the volume of this spill an extra valve is recommended. Thus, the additional valves recommended are:
$ A block valve before and after the California Aqueduct crossing (this is required by DWR), at EMP 11.8 (the Applicant has already accepted this proposal and is redesigning the project accordingly)
$ A check valve at the Grapevine area, in the vicinity of the active landslides, at EMP 16.1 (the Applicant has already accepted this proposal and is redesigning the project accordingly)
$ One check valve between the Emidio Station and the first California Aqueduct crossing at EMP 11.8, where there are no valves for a stretch of over 11 miles (specific location to be determined by project engineers based on topography)
$ 2 block valves at approximately EMP 32 and EMP 59, check valves at approximately EMP 33.2, 34.5, and 59. The optimum locations to be determined by project engineers, depending on topography and stream crossing design
$ A block valve at the new Regional Intermodal Transportation Center (RITC) in the City of Burbank (the Applicant has already accepted this recommendation)
$ The block valve located at MP 136.5 (in the FEIR) will be relocated to MP 136, or just west of the Hollywood fault zone. A check valve will be placed near MP 137.2, or just east of the Hollywood fault zone.
$ Add block and check valves to comply with California State Fire Marshal=s requirements of Avalves at each side of a major thoroughfare, railroad track or waterway.@ See Comment PA.8 in Part H.
Impact: The impact is potential of significant oil spill. Valves are extremely important in reducing the volume of spills, when they occur. Larger oil spills could result in areas where valves are widely spaced.
Performance Criteria, Violation Level, and Timing:
PC1 PPSI construction plans shall identify the following (the milepost would be different to reflect the correct mileposts implemented for the final plans. The locations shall remain the same unless a variance is requested by PPSI and approved in writing by CPUC/ANF.) (Level 3) - Prior to construction:
- A block valve before and after the California Aqueduct crossing at EMP 11.8
- A check valve at the Grapevine area, in the vicinity of the active landslides, at EMP 16.1
- A check valve between the Emidio Station and the first California Aqueduct crossing at EMP 11.8
- 2 block valves at approximately EMP 32 and EMP 59, check valves at approximately EMP 33.2, 34.5, and 59.
- A block valve at the new Regional Intermodal Transportation Center (RITC) in the City of Burbank
- The block valve located at MP 136.5 (in the FEIR) will be relocated to MP 136, or just west of the Hollywood fault zone. A check valve will be placed near MP 137.2, or just east of the Hollywood fault zone
- Block and check valves to comply with California State Fire Marshal=s requirements of Avalves at each side of a major thoroughfare, railroad track or waterway.@ See Comment PA.8 in Part H.
PC2 The valves are installed at the approved locations. (Level 3) - During construction.
Effectiveness Criteria: Valves in operation at the approved locations protecting the resources that they were designed for.
Effectiveness Timing: Resources protected during an oil spill.
Mitigation Measure: SS-12a: Section C.17 analyzes the impacts associated with West Liebre Gulch Ridge Alternative Alignment. As a result of this analysis (see Section C.17) the Applicant shall install additional valves along that alternative alignment as follows:
$ One new block valve in the first 0.4 miles after the departure from the proposed route
$ One new block valve just west of the West Liebre Gulch crossing
$ One new check valve just east of the West Liebre Gulch crossing (replacing the block valve currently shown at EMP 37).
Impact: Larger oil spills could result in areas where valves are widely spaced. A significant uncontrolled oil spill at this location could result in a significant impact on drinking water resources of a large population (Class I).
Performance Criteria, Violation Level, and Timing:
PC1 The recommended valves shall be shown on the submitted construction plans (Level 2) - Prior to construction.
PC2 Specified valves to be installed in the specified location (Level 3) - During construction.
Effectiveness Criteria: Valves installed and in operation.
Effectiveness Timing: Drinking water resources protected during an oil spill.
Mitigation Measure SS-13: The Applicant shall maintain an up-to-date Oil Spill Contingency Plan (OSCP) in compliance with 49 CFR 195.402, the standards of all applicable jurisdictions along the route, as well as additional items discussed below. The OSCP shall include procedures indicating the pipeline inspection procedures following an earthquake of 6.0 or greater. The areas of the ROW around the earthquake epicenter must be inspected first. Pipeline bridge crossings and potential liquefaction areas are then to be inspected in a predetermined order. Include wildlife contingency measures including specifics of how to deal with oiled wildlife, both terrestrial and aquatic; a list of names and telephone numbers of persons who are expert in the rehabilitation of oiled wildlife; locations and response times of facilities and persons for responding to oiled wildlife, creating facilities if necessary; and providing for the ability to rehabilitate oiled wildlife over the long term, if necessary (see also Mitigation Measures B-W-4, B-W-5, and B-W-6 in Section C.3.2.2.5).
Review of OSCP: The OSCP will be subject to review by the California State Fire Marshal, California Department of Fish and Game, U.S. Fish and Wildlife Service, the Los Angeles County Metropolitan Transportation Authority, and other applicable local, State and Federal agencies who will review it for compliance with all requirements of 49 CFR 195.402, and California SB 2040, and the standards of all applicable jurisdictions along the route. In addition, the plan will be specifically reviewed for methods and instructions for containing oil across land, down stream channels, storm drains, and in water. The removal of contaminated vegetation and implementation of methods to protect and care for birds and wildlife in the event they become soiled with oil will also be reviewed.
Spill Response Training/Equipment: All appropriate emergency personnel must be trained for spill response. Oil spill containment and recovery equipment shall be inspected and maintained annually. Regular drills shall be scheduled and the results evaluated so that oil spill response personnel are familiar with the equipment and with the project area.
PPSI will investigate the possibility of using a Task Force or Special Committee consisting of the fire agencies along the pipeline route to serve as, or augment the spill response contractors that are required under this and other mitigation measures. The Task Force or Special Committee would be funded adequately to meet PPSI=s obligations for oil spill response and fire fighting equipment.
Contact Lists: The OSCP shall include a list of the names and telephone numbers of the pre-approved response contractors and the following:
$ Information on the type and amount of equipment each can provide
$ Number of laborers available and estimated time to mobilize the response team.
The plan shall include a listing of names, telephone numbers, and addresses for emergency access to private lands along the pipeline route.
Biology Considerations:
(1) Station oil spill response and containment equipment at the following locations:
$ Emidio and Grapevine Pump Stations
$ Pyramid Lake
$ Vicinity of the Castaic Creek crossing
$ Vicinity of the Santa Clara River crossing
$ Vicinity of the Dominguez Channel crossings.
(2) Outline provisions for qualified biological monitors on site during all cleanup activities in the vicinity of known rare plant population locations.
(3) Outline provisions for restoration of affected plant populations and habitat in the event of an impact and these shall be reviewed and approved by CPUC, USFS, and CDFG, as appropriate, prior to their implementation.
(4) Include maps that show population locations of rare, threatened, or endangered plant species. Maps must show population locations and suitable habitat and must define ingress and egress points and areas where cleanup activities can occur without impact on rare plants. Provide directions for emergency containment procedures if a spill should occur in or upstream of habitat of sensitive plant species. This information shall be reviewed every five years by the Applicant, ANF, CPUC, and responsible agencies, and updated as appropriate.
(5) Prepare evaluation of the non-cleanup option for ecologically vulnerable habitats such as riparian habitats (see also Mitigation Measure B-W-5).
(6) Areas of particular biological sensitivity shall be noted (similar to the Base Maps in Appendix B of FEIR) and special cleanup techniques outlined, should these areas be contaminated.
(7) Provisions to rehabilitate a habitat affected by a spill and/or by cleanup activities shall include the following:
$ Measures to protect sensitive habitats from damage
$ Measures to minimize potential damage from response and repair operations
$ Measures to restore native plant and animal communities to pre-spill conditions
$ Site-specific restoration plans for riparian and coastal habitats
$ Containment and cleanup measures addressing storm drain and flood control channels.
A monitoring program shall be established to assess the rate and overall success of the cleanup and reclamation efforts.
(8) Develop site-specific contingency plans for sensitive habitats (see Mitigation Measure B-V-6 for details of plan).
Cultural/Archaeology/Paleontological Considerations: Areas of archaeological or paleontological significance within the potentially-affected spill area that are discovered during the lifetime of the project shall be noted in the OSCP. Special cleanup techniques, emphasizing water-surface cleaning and absorbent cleaning and prohibiting use of heavy construction equipment in these areas shall be required.
A qualified local archaeologist and a trained Native American observer shall be included in designing the Oil Spill Response Plan to ensure that site impacts can be avoided or minimized during containment and cleanup. To the maximum extent feasible, site areas shall not be affected unnecessarily by ground disturbance associated with construction of dams, berms, trenches, or the establishment of staging areas. The Oil Spill Response Plan shall include provisions for contacting a qualified local archaeologist and Native American observer when an oil spill response is required. The archaeologist and Native American observer shall visit the spill site to assist in avoiding sites and to monitor the containment. After containment is accomplished, cleanup activities shall be preceded by a brief archaeological reconnaissance of the affected area. If any sites are located in the area, the archaeologist and spill cleanup team leaders shall evaluate further actions, including emergency site excavation.
Hydrological and Water Quality Considerations: As discussed in Mitigation H-11, the OSCP shall include a stream by stream analysis of maximum potential oil spill that can be released, the exact potential pathway of the oil, the time to reach potable water resources, and specific measures to prevent contamination of water resources. A computer based (preferable GIS) system that could simulate the progression of the oil spill and identify response resources would be very useful. Mitigation Measure H-11 also requires the development of other measures to protect Pyramid and Castaic Lakes from an oil spill.
Land Use Considerations: Develop procedures for sensitive land uses to further reduce potential land use impacts. These sensitive land uses include schools, hospitals, residences, religious facilities, recreational lands, prisons, and oil fields along the pipeline ROW and environmentally-sensitive areas. Designated representatives of these nearby land uses shall be consulted. The OSCP will include lists of sensitive receptors within 1,000 feet (305 meters) of the pipeline ROW (as defined in Section C.8.1.2) and procedures to ensure they are notified in the event of a spill.
Socioeconomic Considerations: Develop specific measures relative to business disruptions and direct cost recovery in the event of an oil spill. Please see Mitigation Measures L-7 in Section C.8 (Land Use), and SP-5 in Section C.12 (Socioeconomics).
Transportation Considerations: Develop specific measures that address and mitigate potential disruption to transportation systems and provide for planning and coordination with the appropriate agencies. Please see Mitigation Measure T-13 in Section C.15 (Transportation and Traffic).
Impact: Oil spill could cause environmental damage (Class I).
Performance Criteria, Violation Level, and Timing:
PC1 This is an Operation-Phase Mitigation Measure. Performance Criteria will be developed for this mitigation measure in a separate document. Include the APM SS-57 commitment of annual update (Level 1) - Prior to operation and operation.
Effectiveness Criteria: OSCP approved by CPUC/ANF, State Fire Marshall, and reviewed and commented on by local fire departments.
Effectiveness Timing: Prior to project operation, and during actual oil spills.
Mitigation Measure SS-14: The Applicant shall distribute copies of the approved Oil Spill Contingency Plan to each agency whose operations could potentially be affected by a spill along the pipeline route, and to local fire departments who may be called on for emergency response. Copies of the contingency plan shall also be made available to any public agency along the pipeline route that requests copies. All contingency plan recipients are to be notified of contingency plan changes via formal contingency plan updates.
Impact: Oil spill could cause environmental damage (Class I).
Performance Criteria, Violation Level, and Timing:
PC1 To be developed for the Operation Phase MMCRP. (Level 1) - Prior to operation.
Effectiveness Criteria: Copies an updates received by all appropriate agencies and Local Fire Departments on a timely manner.
Effectiveness Timing: Prior to and during project operation.
Mitigation Measure SS-15: The Applicant shall supply and maintain oil spill containment and response equipment at locations accessible to first response personnel along the route to facilitate rapid response to an oil spill. Selected locations and equipment must be approved by appropriate jurisdictions along the pipeline ROW.
Impact: Oil spill could cause environmental damage (Class I).
Performance Criteria, Violation Level, and Timing:
PC1 To be developed for the Operation Phase MMCRP. (Level 1) - Prior to operation.
Effectiveness Criteria: Fire Departments aware of response equipment available.
Effectiveness Timing: After project construction, prior to project operation.
Mitigation Measure SS-16: The Applicant shall conduct a public education program consistent with 49 CFR 195.440 to help the public and agencies understand pipeline safety hazards. The program will be supervised by the State Fire Marshal and approved by emergency services agencies in each county. This program shall include distribution of a brochure explaining how to recognize a leak, what to do in the event of a spill, what potential safety impacts could occur, and who to call. The brochure will be distributed to homes, sensitive receptors, and businesses within 1,000 feet of the pipeline, and shall be actively distributed by Pacific Pipeline System Inc., along with construction notifications during the installation of the proposed pipeline. Translated versions of the educational material should be distributed in high-minority communities. Please see Mitigation Measure ML-5 in Section C.16 (Impacts on Minority Populations).
Impact: Oil spill could cause environmental damage (Class I).
Performance Criteria, Violation Level, and Timing:
PC1 PPSI to submit to CPUC/ANF a draft copy of the safety brochure and its translated version together with the anticipated distribution list 60 days before the construction startup date. (Level 2) - Prior to start of construction.
PC2 PPSI to distribute the approved brochure to the approved list in combination with the construction notice. (Level 3) - Prior to and during construction, when construction notifications are distributed.
Effectiveness Criteria: The affected Public receive educational material on potential safety hazards of pipeline and guidance on what to do if it happens prior to operation.
Effectiveness Timing: Prior to project construction.
Mitigation Measure SS-17: The Applicant shall exercise the OSCP with a full-scale response drill prior to operation of the pipeline. Any deficiencies identified as a result of this exercise shall be corrected by the Applicant prior to startup. Emergency response drills shall be conducted according to the National Preparedness for Response Exercise Program (PREP) Guidelines and, at a minimum, shall include a pipeline equipment deployment exercise annually, an internal tabletop exercise annually and an internal notification exercise quarterly. Drills shall be used to clarify the role of the oil spill responder. Again, the communication problem and need for interpretation in the high-minority communities should be addressed in any response drill.
Impact: Oil spill could cause environmental damage (Class I).
Performance Criteria, Violation Level, and Timing:
PC1 To be developed for the Pre-operation and Operation Phase MMCRP (Level 1) - Prior to operation.
Effectiveness Criteria: Drill successfully executed and lessons learned to be communicated to all participants.
Effectiveness Timing: Prior to project operation.
Mitigation Measure SS-18: The Applicant shall conduct a comprehensive safety and reliability analysis of the SCADA system and pipeline control room prior to commencement of operations. The analysis should meet or exceed the guidelines developed by the Institute of Electronic and Electrical Engineers. Include the improvements recommended by this study to the hardware and software. Provide the regulatory agencies with the study results.
Impact: Oil spill could cause environmental damage. The SCADA system has a critical role in reducing the oil spill volume and the resulting impacts on several resources (Class I).
Performance Criteria, Violation Level, and Timing:
PC1 The performance criteria for the study and the adequacy of the SCADA and control room design (including the provision of a secondary control room) to be developed for the Pre-operation and Operation Phase MMCRP. (Level 1) - Prior to operation and operation.
PC2 The construction plan shall include provisions for establishment of the primary and secondary control rooms (Please see the Applicant Proposed Measure SS-28**). (Level 1) - Prior to start of construction.
Effectiveness Criteria: Study is professionally conducted. The result is implemented and the SCADA system installed provide the highest level of reliability and fastest response time that is currently and commercially available for crude oil pipelines.
Effectiveness Timing: Prior to project operation.
Mitigation Measure SS-19: This mitigation measure described in the Draft EIS/SEIR is deleted. The Oil Pipeline Environmental Responsibility Act (AB 1868) signed into law in October 1995 covers the requirements of this measure; see discussion in Section C.13.1.3.2.
Mitigation Measure SS-20: In consultation with spill response contractors and the public response agencies, the Applicant shall conduct an evaluation of the response capabilities along the ROW to meet the needs of additional oil and gas projects in the area. This evaluation should address the potential for multiple release scenarios, response capabilities required to meet the needs of credible maximum spill scenarios in the region, and the feasibility and the barriers to effective sharing of response resources. (Other shippers should be contacted for cooperation, as recommended under Mitigation Measure SS-9.) The current system for coordinating the response resources and the efforts of many public agencies should also be reviewed in the evaluation of response capabilities. There is a potential that oil spills near the refinery connections, or at the Santa Clara river crossing could eventually reach the ocean. Therefore, the Applicant shall execute a contract with a marine cooperative spill cleanup co-op to ensure these resources are available.
Impact: Oil spill could cause environmental damage. An efficient, well-coordinated and cooperative plan can significantly increase the resources and responsiveness of emergency agencies (Class I).
Performance Criteria, Violation Level, and Timing:
PC1 To be developed for the Pre-operation and Operation Phase MMCRP (Level 1) - Prior to operation.
Effectiveness Criteria: The response capabilities in the study area is thoroughly assessed and a good faith effort to coordinate these resources and facilitate sharing of the capabilities has been demonstrated. A marine cooperative spill cleanup co-op has been identified and copies of the contract has been received.
Effectiveness Timing: Prior to operation.
Mitigation Measure SS-20b*: Contract with a marine spill clean-up cooperative to ensure that adequate response capabilities are available for potential spills to the ocean. The Project Proponent shall specifically ensure that adequate response capabilities exist for shallow water spill recovery. An evaluation is also to be made of the response capabilities along the ROW, both with the spill response cooperatives and the public response agencies, to meet the needs of additional oil and gas projects in the area. This evaluation should address the potential for multiple release scenarios, response capabilities required to meet the needs of credible worst case spill scenarios in the region, and the feasibility and the barriers to effective sharing of response resources. The current system for coordinating the response resources and the efforts of many public agencies should also be reviewed in the evaluation of response capabilities.
Impact: Oil spill could cause environmental damage (Class I).
Performance Criteria, Violation Level, and Timing:
PC1 To be developed for the Pre-operation and Operation Phase MMCRP (Level 1) - Prior to operation.
Effectiveness Criteria: The response capabilities in the study area is thoroughly assessed and a good faith effort to coordinate these resources and facilitate sharing of the capabilities has been demonstrated. A marine cooperative spill cleanup co-op has been identified and copies of the contract has been received.
Effectiveness Timing: Prior to operation.
Mitigation Measure SS-21: The Applicant shall provide each pump station with appropriate fire-fighting equipment. Aqueous film-forming foam (AFFF) equipment shall be installed where water supplies are available. At locations without water supply, a non-aqueous fire suppression system shall be installed with equivalent or superior performance to AFFF. All systems must meet or exceed local fire codes and other legal requirements.
Impact: Fire could damage pump/pressure relief stations and affect the surrounding area.
Performance Criteria, Violation Level, and Timing:
PC1 To be developed for the Pre-operation and Operation Phase MMCRP (Level 1) - Prior to operation.
Effectiveness Criteria: Equipment installed and maintained.
Effectiveness Timing: Prior to operation.
Mitigation Measure SS-22: The Applicant shall prepare a Fire Protection Plan for the operational phase of the Proposed Project. The Plan shall include details of fire protection and loss prevention measures that will be implemented during the operation of the pipeline. The Plan shall be approved by all affected fire protection jurisdictions.
Impact: Fire could damage pump stations and pipeline facilities and could adversely affect public safety (Class I).
Performance Criteria, Violation Level, and Timing:
PC1 To be developed for the Pre-operation and Operation Phase MMCRP (Level 1)
Effectiveness Criteria: An approved plan in place that identifies the hazard scenarios and a detailed plan for loss prevention and response coordination.
Effectiveness Timing: Prior to operation.
Mitigation Measure SS-22a: The proposed pipeline shall be used only as stated in the Applicant=s Project Description: for transportation of crude oil only and at an average flow rate of 130,000 BPD. No exceedance of this level is allowed without appropriate environmental review and analysis, and no other material including petroleum compounds or products (whether in gas or liquid form) may be transported through this pipeline. The H2S content of the crude oil transported by the pipeline shall not exceed 10 ppm.
Impact: Fire could damage pump stations and pipeline facilities. The analysis conducted for this project and its eventual approval are based on the use of the pipeline for specific material. The usage of other compounds could increase the impacts and was not assessed (Class I).
Performance Criteria, Violation Level, and Timing:
PC1 To be developed for the Pre-operation and Operation Phase MMCRP (Level 1)
Effectiveness Criteria: Throughput does not exceed 130,000 MBD; crude oil only.
Effectiveness Timing: During Operation.
Mitigation Measure SS-23: This mitigation measure described in the Draft EIS/SEIR is deleted based on factors including: (1) recognition that speculative economic factors dictate shipment of crude oil via alternate modes of transportation; (2) consideration of potential beneficial impacts for all new pipeline alternatives; and (3) difficulties in implementation, enforcement, and monitoring of the previously-proposed measure.
Mitigation Measure SS-24: To reduce likelihood of damage to the pipeline from third-party construction, place markers at major highway and road crossings, keyed to Thomas Guide page numbers. Placement and markers are to meet the approval of each applicable County jurisdiction. Additionally, to avoid potential construction impacts, two pipeline markers shall be visible from any point along the pipeline, with a maximum spacing of 500 feet between any two markers.
Impact: Damage to pipeline from construction of cumulative projects (Class I).
Performance Criteria, Violation Level, and Timing:
PC1 Show the location of the markers on the construction plan. (Level 2) - Prior to construction.
PC2 Install the marker according the above specifications, except in cases where the local authorities do not permit such markers. (Level 3) - During construction.
Effectiveness Criteria: Markers are installed according to the specification.
Effectiveness Timing: Construction
Mitigation Measure SS-25: This mitigation measure was recommended for the Mojave Alternative and is not applicable for the approved Project.
Mitigation Measure SS-26: This mitigation measure was recommended for the Mojave Alternative and is not applicable for the approved Project.
SYSTEM SAFETY APPLICANT PROPOSED MEASURES
The Applicant has incorporated a number of measures into the Proposed Project to help reduce the hazards associated with construction and operation of the pipeline. The Applicant's proposed measures are summarized below. Some of these measures (such as cathodic protection) are required by Federal or State laws.
Oil Spill Prevention Measures. The following design and construction measures have been incorporated into the design for the new 20" pipeline.
Applicant Proposed Measure SS-27**: State-of-the-art Supervisory Control and Data Acquisition (SCADA) system, including pressure/temperature measurements at the block valves and fiber optic communications. The SCADA system would send instructions to and receive information from Remote Terminal Units (RTUs) located at pump stations and block valves located along the pipeline. The master station would originate remote control commands and receive status and alarm data from the RTUs. The RTUs would receive and execute valid commands from the master station and transmit alarm and status information back to the master station. The SCADA computer system would be programmed to continuously scan for alarms.
Impact: Impacts associated with accidental release of crude oil (Class I). An efficient, error free, and fast SCADA system will reduce the magnitude of the impacts associated with the oil spills.
Performance Criteria, Violation Level, and Timing:
PC1 The performance criteria for the study and the adequacy of the SCADA and control room design (including the provision of a secondary control room) to be developed for the Pre-operation and Operation Phase MMCRP. (Level 1) - Prior to operation.
PC2 The construction plan shall include provisions for establishment of the primary and secondary control rooms (Please see the Applicant Proposed Measure SS-28**). (Level 1) - Prior to station construction.
Effectiveness Criteria: A Study is professionally conducted (as stated under SS-18). The result is implemented and the SCADA system installed provide the highest level of reliability and fastest response time that is currently and commercially available for crude oil pipelines.
Effectiveness Timing: Pre-operation
Applicant Proposed Measure SS-28**: A secondary control station would be established at one of the pump stations (most likely at Emidio) in case the master station becomes disabled for a prolonged period. In case of a short-term power outage, an uninterrupted power supply (UPS) would supply power to the central control facility for approximately four hours. After two hours of power failure, operation personnel would be sent to the secondary center to continue operations. Otherwise the pipeline would be systematically shut down.
Impact: Impacts associated with accidental release of crude oil (Class I). A continuous and uninterrupted control of operation, especially at the control center would and during an accident, can prevent accidents or reduce the potential impacts.
Performance Criteria, Violation Level, and Timing:
PC1 The Construction Plans should provide for a secondary control room at one of the pump stations (most likely at Emidio). (Level 2) - Prior to station construction.
PC2 The design for the control facility and the SCADA study to be conducted (see Mitigation Measure SS-18) should provide for a UPS capable of supplying a minimum of four hours of power at the control centers. The study should evaluate the assumption of transfer of the control operation to the secondary facility after two hours of power interruption at the central control room (Level 2) - Prior to operation.
Effectiveness Criteria: A SCADA system has been installed based on the recommendations of the study detailed under SS-18, which provides the highest reliability, adequate redundancy, and provisions for power interruptions in a reasonably worst case accident scenario.
Effectiveness Timing: Pre-operation and operation
Applicant Proposed Measure SS-29**: Valves will be located at environmentally sensitive areas, areas of liquefaction/faulting/scour, and at pump stations. A total of 30 block and 14 check valves would be located along the pipeline. (Additional valves will be included as required by mitigation measures.)
Impact: Impacts on public safety and environmental/cultural resources as a result of an oil spill (Class I).
Performance Criteria, Violation Level, and Timing:
See Mitigation Measures SS-12 and SS-12a
Effectiveness Criteria: Proper valves (conforming to the specifications detailed in the FEIR and FEIS/SEIR) are successfully installed at the approved locations
Effectiveness Timing: Construction
Applicant Proposed Measure SS-30**: Mainline block valves for the project would be activated by a nitrogen gas system that could be automatically shut down without the need for an outside power source.
Impact: Impacts associated with an accidental release of crude oil (Class I)
Performance Criteria, Violation Level, and Timing:
PC1 Provide CPUC/ANF with a copy of purchase order for the valves that shows both the quantity ordered and the specification (Level 2) - Prior to valve installation
PC2 All block valves installed are nitrogen activated (Level 3) - During construction.
Effectiveness Criteria: All block valves installed are nitrogen activated and proper maintenance (Frequent check of the nitrogen system, not less than every six months [see APM SS-31]) is conducted
Effectiveness Timing: Construction and Operation
Applicant Proposed Measure SS-31**: Block valves would be inspected every six months to ensure proper operation and to prevent encroachment by woody vegetation (per regulation 49 CFR 195.420). During valve inspection, the nitrogen supply for the pneumatic activation of the valve actuators would be checked and recharged if needed.
Impact: Impacts associated with an accidental release of crude oil (Class I)
Performance Criteria, Violation Level, and Timing:
PC1 To be developed for the Pre-operation and Operation Phase MMCRP (Level 1)
Effectiveness Criteria: The valves are maintained at the required frequency
Effectiveness Timing: Operation
Applicant Proposed Measure SS-32**: The pipeline would be overflown by a patrol every two weeks for the purpose of spotting any leaks not detected by centralized leak systems, and to monitor any potential hazardous conditions that would threaten the pipeline, such as landslides, flood hazards, or third-party construction.
Impact: Impacts associated with accidental releases of crude oil (Class I). SS-32** is also associated with the impacts associated with geologic and hydrologic hazards such as landslide and flood hazards.
Performance Criteria, Violation Level, and Timing:
PC1 Provide CPUC/ANF or CSFM a copy of the contract with the airplane company (Level 1) - Prior to operation.
PC2 Conduct and log the fly-over inspections. Where there are no-fly zones, conduct ground inspections. Maintain a file for all inspection report (Level 3) - During operation.
Effectiveness Criteria: The inspection has done on regular basis at the required frequency, and the inspection results has been recorded and maintained at PPSI control building and available for inspection, when required by the agencies
Effectiveness Timing: Operation
Applicant Proposed Measure SS-33**: Pump stations would be visually inspected every two to three days for appropriate equipment lubrication, signs of potential malfunction, and any abnormal appearance or sound. Similar inspections would occur at the pressure relief/reduction station and receiving stations.
Impact: Impacts associated with accidental releases of crude oil (Class I)
Performance Criteria, Violation Level, and Timing:
PC1 A visual inspection of the pump stations, pressure relief stations, and receiving stations at a frequency of at least every three days shall be required in the inspection/ maintenance plan to be submitted to agencies. (Level 1) - Submit plan prior to operation; inspections during operation.
PC2 The above stated inspections are conduced as specified and a report is logged and maintained at the central control office (Level 2) - During operation.
Effectiveness Criteria: The inspections are conducted as specified and the records are properly maintained
Effectiveness Timing: Operation
Applicant Proposed Measure SS-34**: Pump stations would be bermed to contain spills.
Impact: Oil spill impacts
Performance Criteria, Violation Level, and Timing:
PC1 Construction Plans reflect the berms as specified in the FEIS/SEIR (Level 1) - Prior to station construction.
PC2 The berms are constructed according to the plan specifications (Level 3) - During construction.
Effectiveness Criteria: The berms are constructed according to the plan specifications
Effectiveness Timing: Construction
Applicant Proposed Measure SS-35**: All field welding would be performed by qualified welders to the specifications of, and in accordance with, all applicable State and municipal ordinances, rules, and regulations, including API 1104 and the rules and regulations of the U.S. Department of Transportation.
Impact: Accidental release of crude oil as a result of welding failures
Performance Criteria, Violation Level, and Timing:
PC1 The qualifications of the welders to be maintained in files and available for inspection by agencies. All required rules, regulations, standards, ordinances shall be specified in the contract (Level 1) - During construction
PC2 The welding to be completed based on the stated requirements in PC1 (see welding inspection requirements in APM SS-36) (Level 3) - During construction.
Effectiveness Criteria: Welding are completed in compliance with all required rules, regulations, standards, ordinances as specified in PC1
Effectiveness Timing: Preconstruction and construction
Applicant Proposed Measure SS-36**: Every single pipeline weld would be radiographically (i.e., X-ray) inspected by a third-party licensed technician and reviewed by a certified company inspector. Radiographs would be recorded and interpreted for acceptability according to requirements of API 1104. All rejected welds would be repaired or replaced, as necessary, and re-radiographed until compliance is achieved. The X-ray reports, as well as a record indicating the location of welds, would be kept for the life of the project.
Impact: Accidental release of crude oil as a result of welding failures
Performance Criteria, Violation Level, and Timing:
PC1 Provide the agencies with a copy of the contract/agreement reached with the third party welding inspection company and their qualifications/certification (Level 1) - Prior to construction.
PC2 Conduct radiographic inspection of every single weld according to API 1104 and other applicable rules and standards. Reject all unacceptable welds and replace them with acceptable welds and reinspect. Prepare a report indicating the locations with rejected and replaced welds and other pertinent inspection information. Keep the record at the central control office for the life of the project. (Level 3) - During construction.
Effectiveness Criteria: Every single weld is properly examined, the non-complied welds are repaired or replaced and reinspected, and the records are kept and available for external audits by agencies.
Effectiveness Timing: Pre-construction, construction, operation
Applicant Proposed Measure SS-37**: Burial of pipe at stream crossings would be at a depth to maintain adequate protection from a 100-year, 24-hour flood event.
Impact: See Mitigation Measure H-6
Performance Criteria, Violation Level, and Timing: See Mitigation Measure H-6
Effectiveness Criteria: See Mitigation Measure H-6
Effectiveness Timing: See Mitigation Measure H-6
Applicant Proposed Measure SS-38**: State-of-the-art metallurgical specifications for pipe (X-grade pipe, 0.5 to 0.312 pipeline wall thickness) would be used.
Impact: Accidental release of crude oil as a result of pipeline failures.
Performance Criteria, Violation Level, and Timing: See Mitigation Measures G-2, SS-10a
Effectiveness Criteria: See Mitigation Measures G-2, SS-10a
Effectiveness Timing: See Mitigation Measures G-2, SS-10a
For more specific requirements please refer to Table B.2-2 Of the FEIS/SEIR.
Applicant Proposed Measure SS-39**: Specialized design would be applied for fault crossings, landslide areas, and other geohazards. Design features could include the use of thicker-walled steel pipe, the use of engineered backfills (including unconsolidated backfill), as well as paired valves to bracket the fault/geohazard.
Impact: Potential pipeline failure and oil spill associated with geohazards
Performance Criteria, Violation Level, and Timing: See Mitigation Measures G-2, G-3, and G-4
Effectiveness Criteria: See Mitigation Measures G-2, G-3, and G-4
Effectiveness Timing: See Mitigation Measures G-2, G-3, and G-4
Applicant Proposed Measure SS-40**: Conduct and implement the recommendations of a Hazard and Operability Study of the pipeline system.
Impact: Accidental release of crude oil and resulting offsite consequences
Performance Criteria, Violation Level, and Timing:
PC1 PPSI shall conduct a HAZOP that identifies failure modes and worst case scenarios, evaluates onsite and offsite consequences, and recommend measures that would minimize the failure probabilities and assist the response procedures. This study shall be coordinated or combined with the SCADA system study required by Mitigation Measure SS-18. (Level 1) - 60 days prior to start of operation
PC2 PPSI shall implement the approved recommendations in the above study. (Level 3) - 30 days prior to start of operation.
Effectiveness Criteria: The potential accidents associated with the pipeline are systematically evaluated and the pipeline and its control and safety system are designed to minimize any potential failure.
Effectiveness Timing: Construction and operation
Applicant Proposed Measure SS-41**: A fusion-bond epoxy (FBE) coating would be applied to the pipeline at the mill before delivery to the construction site. However, field coating would be necessary on all field weld joints made at the site in order to provide a continuous coating along the pipeline. After the pipe has been welded and radiographically inspected (X-rayed), a minimum of 14 mils of FBE coating would be applied to all field joints and fittings. Alternatively, shrink sleeves could also be used. The coating would be covered with polyurethane insulation. A polyurethane sleeve would be placed over the joints and injected with 12 to 2 inches of polyurethane insulation. Alternatively, half polyurethane shell insulation could also be used.
Impact: Impacts associated with accidental releases of crude oil
Performance Criteria, Violation Level, and Timing:
PC1 PPSI shall submit their field joint weld coating procedures and specifications for agency review and approval. (Level 1) - 60 days before construction.
PC2 Field joint coating shall be conducted according to the approved procedure as determined by PC1 above. (Level 3) - During construction.
Effectiveness Criteria: Every joint weld is effectively covered with the approved coating at the field
Effectiveness Timing: Construction
Applicant Proposed Measure SS-42**: Implementation of an active and strict construction monitoring program that would monitor the insulating qualities of the pipe coating to assure that they are integral and undamaged at the time of backfilling.
Impact: Impacts associated with accidental releases of crude oil
Performance Criteria, Violation Level, and Timing:
PC1 Submit the monitoring procedures and performance criteria to CPUC/ANF (Level 1) - 60 days before start of the construction
PC2 Implement the monitoring program at the field. (Level 2) - During construction.
Effectiveness Criteria: The insulating qualities of the pipe coating are integral and undamaged at the time of backfilling.
Effectiveness Timing: Construction
Applicant Proposed Measure SS-43**: Implementation of a construction specification that would require the use of a selected backfill envelope completely surrounding the pipe, before introducing rocks and other abrasive materials that might damage the coating.
Impact: Impacts associated with accidental releases of crude oil
Performance Criteria, Violation Level, and Timing:
PC1 Implement the specifications during the construction. (Level 2) - During construction
Effectiveness Criteria: A procedure is in place and is effectively implemented that has resulted in no damage to pipe coating by rocks or other abrasive material
Effectiveness Timing: Construction
Applicant Proposed Measure SS-44**: Installation of a prominently-colored plastic strip in the backfill, warning excavators that a pipeline lies below.
Impact: Impacts associated with accidental release of oil as a result of pipeline damages
Performance Criteria, Violation Level, and Timing:
PC1 Install the plastic strip in the backfill at approximately 18 inches below the surface level in all areas where there is open trench (impossible for bored or directionally drilled areas). (see also the project parameters SS-PP10) (Level 2) - During construction.
Effectiveness Criteria: The strip is installed at all backfilled locations
Effectiveness Timing: Construction
Applicant Proposed Measure SS-45**: Implementation of a cathodic protection program that would provide for closely-spaced test stations, for frequently monitored parameters, and for periodic re-analysis and observation of trends of changes in potentials and current flow, so as to predict possible areas of corrosion and to take remedial action before leaks can develop.
Impact: Impacts associated with accidental releases of crude oil
Performance Criteria, Violation Level, and Timing:
PC1 Submit a cathodic protection program that would provide the distance between the test stations, identifies the monitoring parameters, and the procedure for periodic re-analysis and observation of trends of changes in potentials and current flow, so as to predict possible areas of corrosion. (Level 1) - 60 days prior to operation.
PC2 Implement the program after the approval by agencies and take the required remedial actions (Level 2) - Implementation of the design parameters during construction and the maintenance, analysis, and remedial actions during the first year of operation.
Effectiveness Criteria: A cathodic program is in place and was implemented that allows for closely-spaced test stations, for frequently monitored parameters, and for periodic re-analysis and observation of trends of changes in potentials and current flow. The program is used to predict possible areas of corrosion and is used to take remedial actions before leaks can develop. The program will be finalized after operation and allowing for establishments of pipe to soil potential.
Effectiveness Timing: Pre-construction, construction, and operation
Applicant Proposed Measure SS-46**: Implementation of a strictly-enforced construction spacing standard, regulating the distance that the pipeline would be installed in parallel or crossing configurations in relation to other underground pipes and utilities.
Impact: The potential impacts on other utilities and cumulative impacts of multiple pipeline failure. (See also Mitigation Measure U-1)
Performance Criteria, Violation Level, and Timing:
PC1 Submit the construction spacing standard for distances to the parallel or crossing configurations in relation to other underground pipelines and utilities. (Level 1) - 60 days before construction.
PC2 Implement the program both in design and in the field. (Level 2) - During construction.
Effectiveness Criteria: A strictly-enforced construction spacing standard, regulating the distance that the pipeline would be installed in parallel or crossing configurations in relation to other underground pipes and utilities is in place and implemented, resulting in no impact on other utilities during the construction.
Effectiveness Timing: Pre-construction and construction
Applicant Proposed Measure SS-47**: Use of a design factor of 0.60 on the pipeline in the railroad ROW which is a 20 percent improvement over DOT standards.
Impact: Impacts associated with accidental releases of crude oil
Performance Criteria, Violation Level, and Timing:
PC1 The factor to be used in the design of the pipeline (Level 3) - Prior to construction.
Effectiveness Criteria: The factor is used in design
Effectiveness Timing: During operation
Applicant Proposed Measure SS-48**: Hydrostatic testing would be performed after construction and prior to startup. Periodic hydrostatic testing would also be conducted as required by the California Pipeline Safety Act and the California Fire Marshal.
Impact Impacts associated with accidental releases of crude oil
Performance Criteria, Violation Level, and Timing:
PC1 Hydrostatic test of pipeline is conducted according to the CSFM requirements (Level 3) - Prior to operation.
Effectiveness Criteria: Hydrostatic testing is conducted properly and any defection is documented and repaired to CSFM satisfaction
Effectiveness Timing: Pre-operation
Applicant Proposed Measure SS-49**: Commitment to conduct a baseline instrumented inspection of the complete pipeline using a smart pig prior to operation. Further inspections would be performed periodically.
Impact: See Mitigation Measure SS-7
Performance Criteria, Violation Level, and Timing: See Mitigation Measure SS-7
Effectiveness Criteria: See Mitigation Measure SS-7
Effectiveness Timing: See Mitigation Measure SS-7
Applicant Proposed Measure SS-50**: A preliminary Oil Spill Contingency Plan (OSCP) has been prepared by PPSI that would be finalized based on the information presented above. The OSCP would need to be reviewed and approved by appropriate Federal, State and local agencies prior to operation. The final OSCP would provide a finalized list of emergency service providers. PPSI has also prepared an Emergency Response Plan to specify measures to be taken in emergency scenarios. These documents will identify the responsible parties for the incident commander and the supporting organizations and agencies.
Impact: Impacts associated with accidental releases of crude oil
Performance Criteria, Violation Level, and Timing: See Mitigation Measures SS-13 and SS-14 and Federal and CSFM requirements
Effectiveness Criteria: See Mitigation Measures SS-13 and SS-14 and Federal and CSFM requirements
Effectiveness Timing: See Mitigation Measures SS-13 and SS-14 and Federal and CSFM requirements
Oil Spill Contingency Plan and Emergency Response Plan shall be completed and approved based on the above requirements.
Oil Spill Response. The Applicant has begun development of an Oil Spill Contingency Plan which will be submitted to and approved by CPUC, ANF, and the responsible agencies along the pipeline prior to construction of the pipeline. The Applicant has committed to the following tasks in developing the plan:
Applicant Proposed Measure SS-51**: Execute a comprehensive Offsite Consequence Analysis and incorporate its findings into the programs described below.
Impact: Impacts associated with accidental releases of crude oil
Performance Criteria, Violation Level, and Timing:
PC1 Conduct (and submit to CPUC/ANF for review) an offsite consequence analysis. This study shall be fully coordinated or combined with the SCADA system study (required by Mitigation Measure SS-18) and the HAZOP study (required by Applicant Proposed Measure SS-40**) (Level 1) - Prior to operation.
PC2 Incorporate the result of this study in design of control systems, the Oil Spill Contingency Plan, and the Emergency Response Plan (Level 2) - Prior to operation (any design changes that might result from these studies shall be implemented).
Effectiveness Criteria: The offsite consequences of reasonably worst case accidents are identified and all reasonable measures to either prevent these accidents and/or reduce their potential impacts are incorporated in the design and all emergency plans
Effectiveness Timing: Pre-operation and after an oil spill
Applicant Proposed Measure SS-52**: Develop, implement, and maintain a comprehensive Spill Response Program, including extensive route mapping and topographical data sufficient to predict "spill fate," i.e., paths of spill from possible rupture points along the line, and areas, as well as resources, that could be affected by such an incident. The program would also contain detailed preplanned containment and diversion booming strategies to protect sensitive human and wildlife resources, including residential areas, public assembly areas, potable water resources, etc. The program would meet or exceed the criteria of the latest local, State, and Federal regulations for oil spill contingency plans. Response literature, maps, and procedures will be fully computerized to assure easy access and higher accuracy in emergency situations.
Impact: Impacts associated with accidental releases of crude oil
Performance Criteria, Violation Level, and Timing:
PC1 Submit a comprehensive description of the Spill Response Program and its capabilities. This program is expected to include computerized access to information, extensive maps, and ability to simulate the spill fate based on the characteristics of the accident and the site specific information. The program would also contain detailed preplanned containment and diversion booming strategies to protect sensitive human and wildlife resources, including residential areas, public assembly areas, potable water resources. (Level 1) - 90 days before operation
PC2 Implement the use of the program during the operation (Level 2) - During operation.
Effectiveness Criteria: A computerized program is developed, implemented, and maintained that will be used as part of the Emergency Response Plan. This program shall include extensive route mapping and topographical data sufficient to predict "spill fate," i.e., paths of spill from possible rupture points along the line, and areas, as well as resources, that could be affected by such an incident. The program would also contain detailed preplanned containment and diversion booming strategies to protect sensitive human and wildlife resources, including residential areas, public assembly areas, potable water resources. Response literature, maps, and procedures is fully computerized to assure easy access and higher accuracy in emergency situations.
Effectiveness Timing: Pre-operation and operation
Applicant Proposed Measure SS-53**: Develop, train, drill, and maintain a well-equipped emergency response team capable of executing the Emergency Response program.
Impact: Impacts associated with accidental releases of crude oil
Performance Criteria, Violation Level, and Timing:
PC1 To be developed for the operation phase MMCRP (Level 1)
Effectiveness Criteria: An emergency response team is developed through proper training, adequate drills, and adequate resources that can execute the Emergency Response program
Effectiveness Timing: Pre-operation and operation
Applicant Proposed Measure SS-54**: Strategically locate repair, containment, and isolation equipment, so that leaks could be further isolated in populated urban areas.
Impact: Impacts associated with accidental releases of crude oil
Performance Criteria, Violation Level, and Timing:
PC1 The Emergency Response Plan and the Oil Spill Contingency Plan to be submitted to the agencies (as required by Mitigation Measures SS-13 and SS-14) shall provide for and identify information on strategically located repair, containment, and isolation equipment, so that leaks could be further isolated in populated urban areas. (Level 2) - Pre-operation (at least 90 days before operation startup date).
Effectiveness Criteria: The Emergency Response Plan and the Oil Spill Contingency Plan have provide for and identified information on strategically located repair, containment, and isolation equipment, so that leaks could be further isolated in populated urban areas.
Effectiveness Timing: Pre-operation and operation
Applicant Proposed Measure SS-55**: Retain a qualified oil spill response contractor.
Impact: Impacts associated with accidental releases of crude oil
Performance Criteria, Violation Level, and Timing:
PC1 The OSCP and EDP shall include the name of the name, qualifications, location, and resources of the response contractor with whom PPSI has signed an agreement. (Level 1) - Prior to operation.
Effectiveness Criteria: Qualified contractors selected and are ready to respond prior to the operation
Effectiveness Timing: Pre-operation and Operation
Applicant Proposed Measure SS-56**: Develop and maintain an Emergency Response Plan for all accident scenarios which could be associated with the pipeline with contents and format as specified by the State of California Oil Spill Prevention and Response (OSPR) Act of 1990.
Impact: See Mitigation Measures SS-13 and SS-14, and Applicant Proposed Measures SS-50** and SS-52**
Performance Criteria, Violation Level, and Timing: See Mitigation Measures SS-13 and SS-14, and Applicant Proposed Measures SS-50** and SS-52**
Effectiveness Criteria and Timing: See Mitigation Measures SS-13 and SS-14, and Applicant Proposed Measures SS-50** and SS-52**
Applicant Proposed Measure SS-57**: Annually update and implement the Oil Spill Contingency Plan (OSCP) to protect sensitive water resources, plant and animal species and communities, recreation facilities, and roads and highways.
Impact: See Mitigation Measure SS-13
Performance Criteria, Violation Level, and Timing: See Mitigation Measure SS-13
Effectiveness Criteria and Timing: See Mitigation Measure SS-13
SYSTEM SAFETY PROJECT PARAMETERS
SS-PP1 Spoils would be screened as the material is returned to the ditch using standard construction screening equipment. (FEIR, p B-55)
SS-PP2 Welding crews will apply the remaining weld passes to bring the thickness of the weld to more than the thickness of the pipe by approximately 1/16 inch. (FEIS/SEIR, p B-42)
SS-PP3 A detection test (holiday detector) will be conducted on all field joints, fittings, and bends to locate any coating discontinuities that could permit moisture to reach the pipe. (FEIS/SEIR, p B-43)
SS-PP4 Tie-in welds would be required whenever the continuous operation of the main-line pipe crews are interrupted. This would be the case at road crossings, water crossings, block valves, and other special locations. (FEIS/SEIR, p B-43)
SS-PP5 All field welding will be performed by qualified welders to the specifications of and in accordance with all applicable State and municipal ordinances, rules, and regulations, including API 1104 and the rules and regulations of the US DOT (Title 49, Part 195). (FEIS/SEIR, p B-44)
SS-PP6 As a safety precaution, a minimum of one 20-pound dry chemical unit fire extinguisher will be required for each welding truck. (EIS/SEIR, p B-44)
SS-PP7 In addition to standard mill testing of pipe and fittings, hydrostatic testing will be performed after construction and prior to start-up. (EIS/SEIR, p B-44)
SS-PP8 Each 10-mile segment of pipe would be tested separately as completed during construction. (FEIR, p B-56)
SS-PP9 Since approximately 1.6 acre-feet (861,630 gallons) of water would be used for each 10-mile segment, the proponent proposes to re-use the water four or five times before disposal. Hydrotest water would be stored in upstream portions of the pipeline while downstream portions were being readied for testing. Water would be moved from one test portion of the line to the next using a pig propelled by air. (FEIR, p B-57)
SS-PP10 Each valve assembly will be aligned with adjoining pipe sections and flanges using flanged fittings welded onto the pipe. (FEIS/SEIR, p B-46)
SS-PP11 The pipe would be buried a minimum of 18 inches below the surface of the rock in areas where the applicant has performed drilling and blasting operations. (FEIS/SEIR, p B-48)
SS-PP12 Directional low-grade charges will be used such that shock effects would not propagate any further than the immediate ROW. (FEIS/SEIR, p P-40)
SS-PP13 In areas of human use, shots must be blanketed(matted) or trench backfilled before detonation. (FEIS/SEIR, p P-40)
SS-PP14 Landowners or tenants in proximity to the shot would be notified in advance so that livestock and other property could adequately protected. (FEIS/SEIR, p P-40)
SS-PP15 Before detonation, a clearance will be made to ensure that construction personnel and equipment and local residents will be out of danger. (FEIS/SEIR, p P-41)
SS-PP16 Special Construction Techniques Between Grapevine Pump Station and Lebec: A Backhoe would dig a Abell hole@ (5' wide by 5' long by 7' long) at the start of the constricted area and continue digging the trench for the length of the pipe. The pipe would be inspected for coating damage. Pipe lowered into trench with tractor sideboom and canvas slings. The pipe would be welded, inspected and joint coated. Shoring of the bell hole would be removed and then backfilled. (FEIS/SEIR, p P-41)