2-1 Description of the Proposed Action 

2.0 DESCRIPTION OF THE PROPOSED ACTION 

2.1 PROPOSED FACILITIES 

KMLP proposes to construct and operate a natural gas pipeline system (the “Project”) to 

interconnect the Sabine Pass LNG Terminal (Docket No. CP04-47-000) currently under construction with 

intrastate and interstate pipeline infrastructure in southwest Louisiana. The Project would consist of three 

segments of pipelines (totaling 135.7 miles), associated pipeline-support facilities (such as pig1

 launchers, 

pig receivers, and MLVs), and 14 interconnects (including regulation and metering equipment) with 

existing intrastate and interstate pipelines. Figure 2.1-1 shows the Project vicinity and appendix B 

provides detailed maps. 

This section describes the three pipeline segments (known as Leg 1, Leg 2, and the FGT Lateral), 

their support facilities, workspaces extra to the pipelines’ rights-of-way, interconnect sites, access roads, 

and yards for pipe storage and contractor use during the construction phase. Table 2.1-1 summarizes the 

pipelines proposed. 

TABLE 2.1-1 

Proposed KMLP Pipelines 

MP 

Parish Begin End 

Length 

(miles) 

Leg 1, 42-inch-diameter 

Cameron 

Calcasieu 

Jefferson Davis 

Acadia 

Evangeline 

Leg 2, 36-inch-diameter 

Cameron 

FGT Lateral, 24-inch-diameter 

Acadia 

Project Total 

0.0 

24.6 

74.9 

99.4 

112.5 

0.0 

110.6a

24.6 

74.9 

99.4 

112.5 

132.2 

1.2 

2.3 

24.6 

50.3 

24.5 

13.1 

19.7 

1.2 

2.3 

135.7 

_______________ 

a

 The FGT Lateral would start at MP 110.6 on Leg 1 and go for 2.3 miles. 

KMLP proposes to commence construction on Leg 1 and Leg 2 in November 2007 and on the 

FGT Lateral in October 2008. Leg 2 and interconnects would be completed by April 2008 and brought 

into service by October 1, 2008. Leg 1, the FGT Lateral, and their respective interconnects would be 

completed by November 2008 and brought into service by April 1, 2009. 

 

1

 A pig is a mechanical device that passes through the interior of a pipeline to clean or to inspect it. 
2-2 

PUBLIC 

FIGURE 2.1-1 

General Location of KMLP Project 
 2-3 Description of the Proposed Action 

2.1.1 Pipelines 

The KMLP Project would include the construction and operation of Leg 1, Leg 2, and the FGT 

Lateral. These three pipelines would be built from carbon-steel pipe manufactured in accordance with 

API 5L – the American Petroleum Institute’s specifications for seamless and welded steel line pipe for 

conveying gas in the natural gas industries. 

Leg 1 

Leg 1 would consist of 132.2 miles of 42-inch-diameter pipeline. It would receive gas from the 

Sabine Pass LNG Terminal at up to 1,440 pounds per square inch pressure gauge (psig) and would have a 

firm, peak day capacity of at least 2,130,000 decatherms (Dth) per day. 

The route followed by Leg 1 would originate at the Sabine Pass LNG Terminal (currently under 

construction) located on the east bank of the Sabine Pass waterway and the south side of SH 82 in 

Cameron Parish. From the Terminal it would proceed northwards, crossing SH 82, and enter Sabine 

Lake, which it would traverse in a north-northeasterly direction without entering the Texas portion of 

Sabine Lake at any point. Leg 1 would exit Sabine Lake at Shell Island near the mouth of the Sabine 

River and then proceed eastwards along the southern banks of the Sabine River and then, entering 

Calcasieu Parish, along the southern banks of the Gulf Intracoastal Waterway (GIWW). After crossing 

the GIWW in a northeasterly direction, Leg 1 would proceed eastwards again, cross Bayou Choupique, 

cross the Calcasieu River and Devil’s Elbow just north of Choupique Island – thus avoiding Lake Charles 

to the north – and then turn northwards to a point south of Iowa, Louisiana before turning in an eastnortheasterly direction and leaving Calcasieu Parish. 

Leg 1 would continue in an east-northeasterly direction, crossing Interstate Highway 10, to a 

point adjacent to Gum Gully, then turn eastwards, crossing Bayou Nezpique and entering Acadia Parish. 

After crossing Bayou Nezpique, Leg 1 would proceed in a north-northeasterly direction and cross SH 190 

into Evangeline Parish. Once in Evangeline Parish, the route would proceed in a generally northeasterly 

direction and terminate at an interconnect site with the CGT pipeline system. 

Leg 2 

Leg 2 would consist of 1.2 miles of 36-inch-diameter pipeline. It would receive gas from the 

Sabine Pass LNG Terminal at up to 1,100 psig, and would have a firm, peak day capacity of at least 

1,265,000 Dth per day. Leg 2 would commence at a receipt point within the Sabine Pass LNG Terminal 

and continue to a point of interconnection with the existing NGPL pipeline just south of SH 82 in 

Cameron Parish, Louisiana. Leg 2 would include 200,000 Dth per day of leased transportation capacity 

on the existing portion of the NGPL pipeline and the UTOS lateral extending to the Johnsons Bayou 

Southwest Loop area, also in Cameron Parish. 

Leg 1 and Leg 2 would be interconnected within the Sabine Pass LNG Terminal to allow bidirectional metering and provide flow capacity of not less than 1,065,000 Dth per day. 

FGT Lateral 

The FGT Lateral would consist of 2.3 miles of 24-inch-diameter pipeline. It would receive gas at 

up to 1,440 psig from Leg 1 and would have a potential capacity of up to 319,500 Dth per day. The 

lateral would originate on Leg 1 at MP 110.6, in Acadia Parish, run eastwards across Bayou des Cannes, 

and terminate at FGT compressor station #7, also in Acadia Parish. 
 2-4 Description of the Proposed Action 

Pig Launchers/Receivers and Mainline Block Valves 

Pig launchers/receivers and MLVs are necessary for proper maintenance and operation of a 

pipeline. The proposed milepost locations of these facilities are provided in table 2.1.1-1. 

TABLE 2.1.1-1 

Pig Launchers/Receivers and Mainline Block Valves 

Facility MP Parish 

Leg 1

MLV #1 0.0 Cameron 

Pig Launcher 0.0 Cameron 

MLV #2 20.1 Cameron 

MLV #3 39.1 Calcasieu 

MLV #4 47.7 Calcasieu 

MLV #5 54.5 Calcasieu 

MLV #6 73.8 Calcasieu 

MLV #7 93.1 Jefferson Davis 

MLV #8 110.0 Acadia 

MLV #9 116.8 Evangeline 

Pig Receiver 132.2 Evangeline 

MLV #10 132.2 Evangeline 

Leg 2

MLV #1 0.0 Cameron 

Pig Launcher 0.0 Cameron 

Pig Receiver 1.2 Cameron 

MLV #2 1.2 Cameron 

FGT Lateral

MLV #1 0.0 Acadia 

Pig Launcher 0.0 Acadia 

Pig Receiver 2.3 Acadia 

MLV #2 2.3 Acadia 

In order to undertake periodic cleaning and inspections by means of intelligent pigging, an 

appropriately sized pig launcher would be temporarily installed at the origin of each of the three pipelines 

along with a pig receiver of the same size at the endpoint. Although the installation of these launchers 

and receivers would be temporary and periodic, the piping and valves for each of the three pipelines 

would have to be configured to accommodate them. 

MLVs would be installed to enable the isolation of individual pipeline segments in order to 

contain unplanned pipeline-system upsets and permit controlled venting as part of a planned blowdown of 

the Project. Each pipeline would have a MLV at its origin and endpoint. Leg 1 would have eight 

additional MLVs installed at locations specified by U.S. Department of Transportation (DOT) safety 

regulations, i.e., in areas of relatively sparse population in order to minimize the social impacts of 

blowdown noise and the likelihood of vandalism. All MLVs would be installed within the permanent 
 2-5 Description of the Proposed Action 

right-of-way and, to the extent practicable, located near existing roads so as to minimize the construction 

of access roads. Each MLV would be fenced, gated, and locked; the valve itself would be buried but 

valve operators and controls would be located above ground. Each MLV would be capable of being 

remotely operated and controlled by a Supervisory Control and Data Acquisition (SCADA) system that 

would monitor operating parameters (e.g., valve position, gas pressure, and flow rate) and detect any 

leaks. The SCADA control room would be located in Houston, Texas. 

Jurisdictional Interconnects 

Interconnecting pipelines from the Project to interstate (but not intrastate) pipelines are subject to 

FERC jurisdiction, as is the Sabine Pass LNG Terminal. These 15 interconnecting pipelines are described 

in section 2.1.2 below along with the 14 interconnect sites at which they would connect with the Project. 

2.1.2 Aboveground Facilities 

The Project would deliver gas to 15 existing interstate pipelines and one existing intrastate 

pipeline via 14 interconnect installations. These installations would regulate and meter the flow of gas 

from the pipelines of the Project to the recipient pipeline system. Each interconnect site would comprise 

one or more meter runs consisting of: 

• Custody-transfer flow meter; 

• Pressure regulator; 

• Isolation block valves; 

• Flow control and high-pressure override valves; and 

• Associated instrumentation and controls. 

The sites would be fenced and gated and include a communications building that would contain a 

satellite link to the SCADA system and a telephone service for SCADA back-up as well as vocal 

communications. Electrical power would be provided for cooling, lighting, and ventilation as well as for 

the monitoring and control equipment. 

Interconnects would be located as close as practicable to the intersections of the Project and each 

individual customer pipeline system in order for the connecting pipelines to be as short as possible. 

Approximate locations and lengths of the interconnects are listed in table 2.1.2-1. 

The connecting pipelines would be built, owned, and operated by their respective customer 

pipeline companies2

. Because each of those companies (with the exception of Bridgeline Holdings, 

whose lateral would be intrastate) would be required to obtain authorization from the FERC to construct 

them, these connecting pipelines are not included in the environmental analysis presented in this draft 

EIS. 

 

2

 It is assumed that the connecting pipelines would be constructed and ready for service when the KMLP Project 

becomes operational. 
 2-6 Description of the Proposed Action 

TABLE 2.1.2-1 

Interconnect Locations and Connecting Pipelines 

Interconnect Name MP Parish Lateral Owner/Operator 

Lengtha

(feet) 

Leg 1

Transcontinental Gas Pipeline Corporation 0 

Texas Gas Transmission 0 

Southwest Loop Delivery 

Point 

28.2 Calcasieu 

Florida Gas Transmission 0 

Sabine Interconnect 61.4 Calcasieu Sabine Pipeline, LLC 0 

TGTPL Interconnect 87.5 Jefferson Davis Tennessee Gas Pipeline Company 0 

TLG Interconnect 91.5 Jefferson Davis Trunkline Gas Company, LLC 0 

TGT Interconnect 110.0 Acadia Texas Gas Transmission 300 

ANR #1 Interconnect 111.3 Acadia ANR Pipeline Company 0 

ANR #2 Interconnect 112.0 Acadia ANR Pipeline Company 0 

TET Interconnect 117.0 Evangeline Texas Eastern Transmission, LLC 0 

Transco Interconnect 122.1 Evangeline Transcontinental Gas Pipe Line 

Corporation 

200 

CGT Interconnect 132.2 Evangeline Columbia Gulf Transmission 100 

Leg 2 

NGPL Interconnect 1.2b Cameron Natural Gas Pipeline Company of America 0 

Bridgeline Interconnect N/Ac Cameron Bridgeline Holdings, L.P. 100 

Transcontinental Gas Pipeline Corporation 100 

Texas Gas Transmission 100 

Southwest Loop, Johnsons 

Bayou Delivery Point 

N/Ac Cameron 

Florida Gas Transmission 100 

FGT Lateral

FGT Interconnect 2.3 Acadia Florida Gas Transmission 0 

_______________ 

a

 A value of 0 feet indicates the lateral is expected to be located completely within the interconnect facility. b

 Located at the end of Leg 2 within Sabine Pass LNG Terminal property. 

c

 Located in Johnsons Bayou near the end of the existing UTOS system. 

2.1.3 Ancillary Areas 

Ancillary areas would include temporary workspaces outside of the construction right-of-way, 

access roads to the pipeline right-of-way, and pipe storage and contractor yards (see table 2.1.3-1). 

Extra Workspaces 

KMLP has requested permission for 864 extra workspaces totaling 303.5 acres. These 

workspaces would be needed in areas where special construction techniques are required, such as road, 

railroad, wetland, and waterbody crossings, as described fully in section 2.3. The size, shape, and 

configuration of each proposed extra workspace are unique due to the particular conditions at its proposed 

location, although they are typically 0.2 acres or less. These are shown in the facility maps in appendix B 

and are listed in appendix C. 
 2-7 Description of the Proposed Action 

TABLE 2.1.3-1 

Number of Ancillary Areas by Parish/County 

Parish/County Extra Workspaces Access Roads 

Pipe Storage and 

Contractor Yards 

Orange County, TX 3 0 0 

Cameron Parish, LA 86 5 0 

Calcasieu Parish, LA 354 43 5 

Jefferson Davis Parish, LA 213 13 4 

Acadia Parish, LA 81 9 0 

Evangeline Parish, LA 127 5 3 

Total 864 75 12 

Access Roads 

To the extent possible, KMLP would access the right-of-way and facilities (once built) from 

existing access roads and from roads crossed by the right-of-way. These include private roads, drives, 

lanes, and other roads that may require some modifications or improvements in order to support the 

expected loads and size of construction equipment and materials safely. 

Construction of and/or modifications to these access roads would include grading plus 

maintaining to prevent rutting, and, in some instances, placing of additional gravel onto the existing 

surface. Wherever possible, new access roads would be constructed of board matting, which would be 

removed after the construction phase. 

Appendix C, table C-2 lists access roads, including their locations and dimensions; the type of 

construction, including modifications or improvements proposed; and the amount of surface area affected 

by them. 

Pipe Storage and Contractor Yards 

KMLP proposes to use 12 temporary yards for pipe storage and contractor staging during 

construction of the Project facilities. See table C-3, appendix C for the location of the pipe storage and 

contractor yards. 

2.2 LAND REQUIREMENTS 

Construction of the Project would disturb 3,031 acres in total. Of this, 841 acres would be 

required for operation of the Project facilities. The remaining 2,190 acres would be restored to preconstruction land use. Table 2.2-1 summarizes the land requirements of all facilities of the Project. 

2.2.1 Pipeline Rights-of-Way and Extra Workspaces 

KMLP proposes to use a variety of construction right-of-way widths that would differ not only 

according to the diameter of the pipeline being installed, but also by land cover and whether topsoil would 

be segregated or not. Table 2.2-1 identifies land disturbed during construction and operation of the 
 2-8 Description of the Proposed Action 

Project. Approximately 2,565.5 acres would be disturbed in the rights-of-way and extra workspaces 

needed to construct Leg 1, Leg 2, and the FGT Lateral. KMLP’s proposed construction rights-of-way 

widths include the following configurations based on its proposed construction methods. The 

construction methods are described in more detail in section 2.3.1. 

Uplands: 

• A 125-foot-wide construction right-of-way for the 42-inch-diameter Leg 1 and the 36-inchdiameter Leg 2 with no soil segregation; 

• A 155-foot-wide construction right-of-way for the 42-inch-diameter Leg 1 and the 36-inchdiameter Leg 2 with ditch-plus-soil-side segregation; 

• A 165-foot-wide construction right-of-way for the 42-inch-diameter Leg 1 and the 36-inchdiameter Leg 2 with full-width segregation; 

• A 100-foot-wide construction right-of-way for the 24-inch-diameter FGT Lateral with no soil 

segregation; 

• A 120-foot-wide construction right-of-way for the 24-inch-diameter FGT Lateral with ditchplus-soil-side segregation; and 

• A 130-foot-wide construction right-of-way for the 24-inch-diameter FGT Lateral with fullwidth segregation. 

Unsaturated Wetlands: 

• A 100-foot-wide construction right-of-way for the 42-inch-diameter Leg 1 and the 24-inchdiameter FGT Lateral in wetland crossings of less than 100 feet (see section 4.4.2.3 for 

further discussion); 

TABLE 2.2-1 

Locations and Land Requirements for the Project 

Facility 

Land Affected 

During 

Construction 

(acres) 

Land Affected 

During 

Operation 

(acres) 

Leg 1 Pipeline 2,239.2 806.3 

Leg 2 Pipeline 7.0 1.5 

FGT Lateral 27.9 13.9 

Extra Workspaces 291.5 0.0 

Aboveground Facilities 12.3 12.3 

Pipe Storage and Contractor Yards 378.7 0.0 

Access Roads 74.2 6.9 

TOTAL 3,030.7 840.9 

_______________ 

Note: Due to rounding, totals may not add up. 
 2-9 Description of the Proposed Action 

• A 125-foot-wide construction right-of-way for the 42-inch-diameter Leg 1 and the 24-inchdiameter FGT Lateral in wetland crossings of greater than 100 feet (see section 4.4.2.3 for 

further discussion); and 

• A 155-foot-wide construction right-of-way where the 42-inch-diameter Leg 1 and 36-inchdiameter Leg 2 are parallel and 50 feet apart. 

Saturated Wetlands (Marsh): 

• A 100-foot-wide construction right-of-way for the 42-inch-diameter Leg 1 and the 24-inchdiameter FGT Lateral in wetland crossings of less than 100 feet (see section 4.4.2.3 for 

further discussion); and 

• A 125-foot-wide construction right-of-way for the 42-inch-diameter Leg 1 in wetland 

crossings of greater than 100 feet (see section 4.4.2.3 for further discussion). 

Open Water (Sabine Lake): 

• A 300-foot-wide construction right-of-way for Leg 1 in water less than 8 feet deep; and 

• A 200-foot-wide construction right-of-way for Leg 1 in water greater than 8 feet deep. 

KMLP requested construction rights-of-way widths greater than 125 feet in upland areas along 

Leg 1 with ditch-plus-spoil-side or full-width topsoil segregation; along the FGT Lateral with full-width 

topsoil segregation; and along the segment where Leg 1 and Leg 2 are parallel and 50 feet apart. We 

approve the request for a 155-foot-wide construction right-of-way where Leg 1 and Leg 2 are parallel and 

50 feet apart. We also approve the request for up to 125-foot-wide construction rights-of-way for Leg 1 

in uplands due to the large diameter of the pipe and local soil conditions and to accommodate topsoil 

segregation. However, we do not believe that the other requests for widths greater than 125 feet are 

justified by KMLP and we do not believe that KMLP has justified the request for a construction right-ofway width of more than 100 feet along the FGT Lateral (see table 2.3-1 in the following section). 

Therefore, we recommend that: 

• KMLP limit its nominal construction right-of-way width for Leg 1 and the FGT Lateral 

in upland areas to 125 feet and 100 feet, respectively. If additional right-of-way width is 

necessary, KMLP shall file with the Secretary a site-specific construction plan and 

written justification for any additional right-of-way width for review and written 

approval by the Director of OEP prior to construction.

In wetlands, KMLP requested a 125-foot-wide construction right-of-way for wetland crossings of 

greater than 100 feet. KMLP further requested that a 100-foot-wide construction right-of-way be used for 

wetland crossings of less than 100 feet. For comparison, our Procedures limit the construction right-ofway width in wetlands to 75 feet. KMLP justified the expanded rights-of-way in saturated wetlands 

based the feasibility to cross these wetlands using the push-pull method. The push-pull method would be 

used in wetland crossings less than 100 feet, but in crossings greater than 100 feet the push-pull method is 

not feasible due to the excessive distance between accessible fabrication staging areas. In unsaturated 

wetlands, KMLP justified the expanded rights-of-way based on the large diameter of the pipeline, heavy 

equipment, poor soil stability, and accessibility to upland areas to place spoil. The justifications provided 

by KMLP are acceptable for the installation of the 42-inch-diameter Leg 1, but not for the 24-inchdiameter FGT Lateral. Therefore, we are restricting the construction in wetlands along the FGT Lateral to 

a 75-foot-wide right-of-way as required by our Procedures. 
 2-10 Description of the Proposed Action 

Following construction, KMLP would maintain a 50-foot permanent right-of-way for operation of 

the pipeline(s). Approximately 806.3 acres would be retained for the permanent right-of-way for Leg 1, 

1.5 acres for Leg 2, and 13.9 acres for the FGT Lateral. 

2.2.2 Aboveground Facilities 

The 14 proposed interconnect sites would be located on a total of 12.3 acres. In general, sites 

would be 200 feet by 200 feet; and the largest would be 202 feet by 225 feet. Land within the fenced 

perimeter would be occupied by a communications building, piping, and other equipment. Portions of 

these sites may be paved, covered with gravel, or landscaped, depending on facility operations and 

maintenance requirements. 

2.2.3 Ancillary Areas 

A total of 74.2 acres would be required for access roads during the construction phase, about 7 

acres of which would be retained during the operations phase. All temporary access roads would be 

restored to the preconstruction condition and uses. The dimensions, location, and type of each access 

road are given in appendix C. 

The 12 temporary yards for pipe storage and contractor staging would range in size from 

approximately 20 acres to 60 acres and in total would require approximately 379 acres of land. The 

proposed locations of these yards are identified in appendix C. All yards would be returned to the 

preconstruction condition and former usage. 

2.3 CONSTRUCTION AND RESTORATION PROCEDURES 

This section describes the general construction procedures proposed by KMLP. Section 4.0 

contains more detailed descriptions of proposed construction, mitigation, and restoration procedures as 

well as additional measures to mitigate environmental impacts. 

The Project would be designed, constructed, operated, and maintained in accordance with the 

DOT regulations 49 CFR Part 192, “Transportation of Natural and Other Gas by Pipeline: Minimum 

Federal Safety Standards”; 18 CFR 380.15, “Guidelines to be Followed by Natural Gas Pipeline 

Companies in the Planning, Clearing, and Maintenance of Rights of Way and the Construction of 

Aboveground Facilities”; and other applicable federal and state regulations. 

KMLP would construct the Project facilities in accordance with its specifications (including a 

Construction Drawing Package of approved pipeline, facility, and equipment drawings) as well as with 

the FERC’s Upland Erosion Control, Revegetation and Maintenance Plan (our Plan) and Wetland and 

Waterbody Construction and Mitigation Procedures (our Procedures). KMLP has requested certain 

alternative measures to our Plan and Procedures, which are addressed in table 2.3-1 and discussed further 

in section 4.0. 

KMLP would prepare a Stormwater Pollution Prevention Plan (SWPPP), which would include an 

Erosion & Sediment Control (ES&C) Plan and a Spill Prevention and Response Plan (SPRP), for the 

proposed pipeline system. These plans would address potential spills of fuels, lubricants, and other 

hazardous materials and describe spill-prevention practices, spill-handling and emergency procedures, 

and training requirements. The SWPPP would incorporate state, county, and parish requirements and 

provisions of our Plan and Procedures (in particular, section IV.A of the latter) with any FERC-accepted 
 2-11 Description of the Proposed Action 

TABLE 2.3-1 

Acceptance or Denial of Requested Alternative Measures 

Applicable 

Item Requested Variance 

Justification for 

Variance Request 

Accepted/

Denied 

Basis for 

Acceptance/Denial 

Upland Erosion Control, Revegetation, and Maintenance Plan 

IV.A.2 A typical temporary 

construction right-of-way 

width of 125 feet in uplands 

(see specific MP locations 

in appendix D) 

To provide a safe work site 

and space for spoil storage 

Accepted 

only along 

Leg 1 

Accepted only for specific sites along 

Leg 1 listed in appendix D (not project 

wide) based on large pipe and local soil 

conditions and to accommodate topsoil 

segregation (see section 2.2.1) 

V.A.5 Land surfaces restored to 

pre-construction contours, 

unless such contours 

threaten the integrity of the 

pipeline 

To arrest erosion if the 

existing land surface within 

the right-of-way is rapidly 

eroding before construction 

and to prevent ponding of 

water 

Denied Denied project wide, but the FERC will 

consider based on site-specific 

information to be submitted by KMLP 

prior to construction (see section 4.1) 

VII.A.5 Annual vegetation 

maintenance (mowing) on a 

50-foot corridor 

Excessively long growing 

period in southwest 

Louisiana 

Denied Denied because annual mowing over 

entire 50-foot right-of-way would 

continually disrupt vegetation (see 

section 4.5.2.1) 

Wetland and Waterbody Construction and Mitigation Procedures 

IV.A.1.d 

& e 

Refueling activities in 

waterbodies 

Vessels and waterborne 

equipment have to be used 

in Sabine Lake and Sabine 

River 

Accepted Accepted only for Sabine Lake and 

Sabine River (see section 4.4.2.3) 

VI.A.3 A typical temporary 

construction right-of-way 

width of 125 feet in wetlands 

where the crossing length 

exceeds 100 feet and a 

right-of-way width of 100 

feet in wetlands where the 

crossing length is less than 

100 feet (see specific MP 

locations in appendix D) 

Larger equipment and soil 

limitations require a larger 

right-of-way to assure a 

safe work site and space for 

spoil storage 

Accepted 

only along 

Leg 1 

Accepted only for specific sites along 

Leg 1 listed in appendix D (not project 

wide) based on large pipe and local soil 

conditions (see section 4.4.2.3) 

VI.A.6 Two aboveground facilities 

located within jurisdictional 

wetlands (see specific MP 

locations in appendix D) 

Locations of interconnects 

dictated by intersection of 

the proposed pipeline and 

existing pipelines and by 

the location of the Sabine 

Pass LNG Terminal 

Accepted Accepted only for specific MP locations 

identified in appendix D (not project 

wide) based on the lack of practicable 

upland locations (see section 4.4.2.3) 

VI.B.1.e A portion of access roads 2 

and 3 constructed in 

wetlands 

Access is required from the 

GIWW to reach the HDD 

workspace needed to 

minimize impacts to 

wetlands 

Accepted Accepted only for specific portions of 

access roads 2 and 3 because these 

roads would permit the use of HDD, 

which avoids about 25 acres of wetland 

impacts (see section 4.4.2.3) 

VI.B.1.a Some extra workspaces 

located within 50 feet of 

wetland boundaries (see 

specific MP locations in 

appendix D) 

Justification is site specific 

(see appendix D) 

Accepted Accepted only for specific sites listed in 

appendix D (not project wide) based on 

lack of practicable locations with 50-foot 

setbacks; also some sites are to 

facilitate HDD or other methods 

designed to reduce impacts (see 

appendix D) 

V.B.2.a Some extra workspaces 

located within 50 feet of 

water's edge (see specific 

MP locations in appendix D) 

Justification is site specific 

(see appendix D) 

Accepted Accepted only for specific sites listed in 

appendix D (not project wide) based on 

lack of practicable locations with 50-foot 

setbacks; also some sites are to 

facilitate HDD or other methods 

designed to reduce impacts (see 

appendix D) 
 2-12 Description of the Proposed Action 

alternative measures. These plans would be in force during the construction and operation phase of the 

project. To ensure that these plans are developed, we recommend that: 

• KMLP file its project-specific SWPPP, including an ES&C Plan and SPRP, with the 

Secretary for review and written approval by the Director of OEP prior to construction.

2.3.1 Pipelines 

Construction of the Project would involve a range of construction methods that fall into a number 

of categories shown in table 2.3.1-1. Appendix E shows the pipeline construction methods proposed by 

milepost (other than for crossings of waterbodies, roads and railroads, and foreign pipelines). 

TABLE 2.3.1-1 

Construction Methods by Category

Category Construction Methods 

Upland Conventional 

(described in section 2.3.1.1 of this 

draft EIS) 

• Upland Construction without topsoil segregation 

• Upland Construction without topsoil segregation, KMLP 42” pipeline adjacent 

to foreign pipeline 

• Upland Construction without topsoil segregation, KMLP 24” pipeline adjacent 

to foreign pipeline 

• Upland Construction with full-width topsoil segregation, KMLP 42” pipeline 

• Upland Construction, KMLP 42” pipeline adjacent to foreign pipe with ditch 

plus spoil side 

• KMLP 36” and 42” pipelines within LNG Terminal, no topsoil segregation 

• KMLP 36” pipeline within LNG Terminal, no topsoil segregation 

Wetland 

(described in section 2.3.1.2 of this 

draft EIS) 

• Unsaturated Wetland with topsoil segregation 

• Saturated Wetland with topsoil segregation 

• Submerged Wetland without topsoil segregation (“Marsh Buggy 

Construction”) 

Sabine Lake 

(described in section 2.3.1.3 of 

this draft EIS) 

• Inland Open Water at water depth of less than 8 feet 

• Inland Open Water at water depth of 8 feet and more 

Special 

(described in section 2.3.1.3 of 

this draft EIS) 

• Horizontal Directional Drilling (HDD) 

• Water-body crossings (other than Sabine Lake) 

• Road and railroad crossings 

• Foreign pipeline crossings 

• Techniques for construction in rice fields and crawfish ponds 

• Techniques for construction in cropland and pasture 

• Techniques for residential areas 

• Techniques for commercial and industrial areas 

2.3.1.1 Conventional Upland Construction Methods 

In upland terrain of the Project, KMLP would use conventional overland construction techniques 

for large-diameter pipelines. Construction would follow a set of sequential operations as shown in figure 

2.3.1.1-1 and as further described below. In the typical pipeline construction scenario, the construction 

spread (crew) would proceed along the pipeline right-of-way in one continuous operation. As the spread 

moves along, construction at any single point along the pipeline, from initial surveying and clearing to 

backfilling and finish grading, would last approximately six to ten weeks. The number of construction 
2-13 

FIGURE 2.3.1.1-1 

Upland Pipeline Construction Sequence 

PUBLIC 
 2-14 Description of the Proposed Action 

spreads will be determined upon selection of a construction contractor. The entire process would be 

coordinated in such a manner as to minimize the total time an individual tract of land is disturbed and, 

therefore, exposed to erosion and temporarily precluded from its normal use. 

The basic steps of upland construction are described below. This description focuses on upland 

construction without topsoil segregation, but variations involving topsoil segregation and routing 

alongside foreign pipelines are also noted. KMLP would use Special Construction Techniques such as 

HDD in sensitive locations. These techniques are described in section 2.3.1.3 and listed in table 2.3.1-1. 

Surveying and Staking 

After notification of and coordination with affected landowners, a KMLP crew would conduct a 

civil survey and stake the outside limits of the right-of-way, the centerline of the pipeline, drainage 

centerlines and elevations, highway and railroad crossings, and any temporary extra workspace, such as 

lay down areas or staging areas for stream crossings. The Louisiana One Call system would be contacted 

and underground utilities (e.g., cables, conduits, and pipelines) would be located and flagged. 

Clearing and Grading 

Following surveying, KMLP would clear the right-of-way of obstacles. Large obstacles such as 

trees, rocks, brush, and logs would be removed. Timber would only be removed when absolutely 

necessary for construction purposes. Timber and other vegetation debris might be chipped for use as 

erosion-control mulch, burned, or otherwise disposed in accordance with applicable state and local 

regulations and landowner crossing agreements. Burning would be conducted in such a manner as to 

minimize the fire hazard and prevent heat damage to surrounding vegetation. Where necessary, fences 

would be cut and braced along the right-of-way, and temporary gates would be installed to control 

livestock and limit public access. The right-of-way would then be graded where necessary to create a 

reasonably level working surface to allow safe passage of construction equipment and materials. Where 

applicable – such as in residential and certain agricultural areas, as outlined in section 2.3.1.3 – conserved 

topsoil would be stockpiled separately from excavated subsoil. Temporary erosion control measures, 

such as silt fencing and interceptor dikes, would be installed immediately after initial disturbance of the 

soil. 

Trenching 

A rotary trenching machine, a track-mounted backhoe, or similar equipment would be used to 

excavate to a sufficient depth to allow a minimum of three feet of soil cover between the top of the pipe 

and the final land surface after backfilling. Due to the absence of consolidated bedrock near the surface, 

no blasting is anticipated. 

The trench would be excavated at least 12 inches wider than the diameter of the pipe, or a 

minimum of 54 inches for the 42-inch-diameter Leg 1, 48 inches for the 36-inch-diameter Leg 2, and 36 

inches for the 24-inch-diameter FGT Lateral. The sides of the trench would be sloped (for safety) with 

the top of the trench up to 30 feet across, or more, depending upon the stability of the native soils. 

Excavated soils would typically be stockpiled along the right-of-way on the side of the trench (the 

spoil side) away from the construction traffic and pipe assembly area (the working side). On actively 

cultivated agricultural tracts (except in most rice fields) and in residential areas, subsoil would be 

stockpiled separately from topsoil (see section 2.3.1.3). Where the route is collocated adjacent to an 

existing pipeline, the spoil would be placed on the same side of the trench as, but not directly over, the 

existing pipeline to keep working equipment off the operating pipeline. 
 2-15 Description of the Proposed Action 

Stringing 

Steel pipe for the pipeline would be procured in nominal 40-foot lengths called “joints” that 

would be protected with an epoxy coating that would have been applied at an external coating yard and 

shipped to strategically located materials storage areas known as pipe yards. (The beveled ends would 

have been left uncoated for the welding step.) 

The individual joints would be transported to the right-of-way by truck and placed by small crane 

in a single continuous line (i.e., strung) along the excavated trench. This would leave the strung pipe 

easily accessible to the construction personnel on the working side of the trench and allow the subsequent 

lineup and welding operations to proceed efficiently. See section 2.3.1.3 for a variation at waterbody 

crossings. 

Pipe Bending 

Since the joints of pipe delivered to the job site would be straight, bending of the joints would be 

required to allow the pipeline to follow natural grade changes and turns in the right-of-way. Prior to 

welding, selected joints would be bent to the desired angle in the field by track-mounted hydraulic 

bending machines. 

Pipe Assembly and Welding 

After stringing and bending are complete, the joints of pipe would be placed on temporary 

supports adjacent to the trench. The ends would be carefully aligned and welded together. Multiple 

passes would be made to achieve a full penetration weld. Only qualified welders would be allowed to 

perform the welding. Welders and welding procedures would be qualified according to applicable 

American Petroleum Institute (API) standards. 

Non-Destructive Examination and Weld Repair 

To ensure that the assembled pipe meets or exceeds the design strength requirements, the welds 

would be inspected visually and tested for integrity by means of non-destructive examination methods 

such as radiography (X-ray), or ultrasound, in accordance with American Society of Mechanical 

Engineers (ASME) standards. Welds displaying unacceptable slag inclusions, void spaces, or other 

defects would be repaired or cut out and re-welded. 

Coating Field Welds, Inspection, and Repair 

Following welding, the previously uncoated ends of the pipe at the joints would be epoxy coated. 

The coating on the completed pipe section would be inspected and any damaged areas would be repaired. 

Pipe Lowering 

The completed portion of pipe would be lifted off the temporary supports and lowered into the 

trench by side-boom tractors or equivalent equipment. Prior to lowering the pipe, the trench would be 

inspected to ensure that it is free of rocks and other debris that could damage the pipe or the coating. 

De-watering would also be undertaken if there were any stormwater in the trench. Before the pipe is 

lowered into the trench, the pipe and trench would be inspected to ensure that the pipe and trench 

configurations are compatible. 
 2-16 Description of the Proposed Action 

Figures 2.3.1.1-2 through 2.3.1.1-8 show typical cross-sections (at the stage of pipe lowering) for 

construction spreads respectively for different variations of upland construction methods. 

Padding and Backfilling

After the pipe is lowered into the trench, the trench would be backfilled. Previously excavated 

materials would be pushed back into the trench using bladed equipment or backhoes. Wherever the 

previously excavated material is found to contain large rocks or other materials that could damage the 

pipe or coating, clean fill or protective coating would be placed instead around the pipe prior to 

backfilling. Following backfilling, a small crown of material might be left to account for any future soil 

settling that might occur. Excess soil would be distributed evenly on the right-of-way, only in upland 

areas, while maintaining existing contours. Wherever topsoil segregation is performed, segregated topsoil 

would be placed in the trench after backfilling with subsoil is complete. 

Hydrostatic Test and Final Tie-In 

Following backfilling of the trench, the pipeline would be hydrostatically tested in accordance with DOT 

regulations to ensure that it is capable of safely operating at the design pressure. The testing process 

involves filling a segment of the pipeline with water and maintaining a prescribed pressure for a 

prescribed duration. The exact steps of that process would be as follows: 

1. Surface water used for testing is drawn through a screened intake; 

2. Test segments of the pipeline are capped and filled with water; and 

3. The water in the pipe is pressurized and held for a minimum of 8 hours. 

Any loss of pressure that cannot be attributed to other factors, such as temperature changes, 

would be investigated. If a leak or break in the line were to occur during testing, it would be repaired and 

the segment of pipe retested until DOT specifications were met. 

Upon completion of the test, the water would either be pumped to the next segment for testing or 

discharged. The test water would be discharged through an energy-dissipating device (two rows of hay 

bales staked to the ground with a silt fence in between in a 30-35-foot circle) in compliance with NPDES 

permit conditions. Although topography and the availability of test water would determine the length of 

each test segment, anticipated hydrostatic test water withdrawal and discharge locations are discussed 

further in section 4.3.2.2. Test water would contact only new pipe, and no chemicals would be added. 

Upon the successful testing and drying of a segment of pipe, the test cap and manifold would be 

removed, and the pipe would be connected to the remainder of the pipeline. No desiccant or chemical 

additives would be used to dry the pipe. See section 2.3.1.3 for a variation for pipeline segments installed 

through HDD. 

Cleanup and Restoration

Post-construction restoration activities would be in accordance with our Plan and Procedures as 

applicable, and FERC’s acceptance of the alternative measures requested by KMLP. After the segment of 

pipe has been installed, backfilled, and successfully tested, the right-of-way, temporary extra workspaces, 

and other disturbed areas would be finish-graded, and the construction debris would be disposed of 

properly. After construction, all disturbed areas would be restored to original contours, except at those 

locations where permanent changes in drainage would be required to prevent erosion, scour, and possible 

exposure of the pipeline (subject to the FERC’s acceptance of a site-specific request by KMLP prior to 

construction, as noted in table 2.3-1 and discussed further in section 4.1). See section 2.3.1.3 for the use 
2-17 

FIGURE 2.3.1.1-2 

Typical Cross-Section for Upland Construction of 42” Pipe Without Topsoil Segregat

PUBLIC 
2-18 

FIGURE 2.3.1.1-3 

Typical Cross-Section for Upland Construction of 42” Pipe Adjacent to Foreign Pipe without Tops

PUBLIC 
2-19 

FIGURE 2.3.1.1-4 

Typical Cross-Section of 42” Pipe with Full-Width Topsoil Segregation 

PUBLIC 
2-20 

FIGURE 2.3.1.1-5 

Typical Cross-Section for Upland Construction of 42” Pipe Adjacent to Foreign Pipe 

with Ditch-plus-Spoil-Side Topsoil Segregation 

PUBLIC 
2-21 

FIGURE 2.3.1.1-6 

Typical Cross-Section for Upland Construction of 42” and 36” Parallel Pipes within t

Sabine Pass LNG Terminal without Topsoil Segregation 

PUBLIC 
2-22 

FIGURE 2.3.1.1-7 

Typical Cross-Section for Upland Construction of 36” Pipe within the 

Sabine Pass LNG Terminal without Topsoil Segregation 

PUBLIC 
2-23 

FIGURE 2.3.1.1-8 

Typical Cross-Section for Upland Construction of 24” Pipe Adjacent to 

Foreign Pipe without Topsoil Segregation 

PUBLIC 
 2-24 Description of the Proposed Action 

of measures to return segregated topsoil in areas of cropland and pasture and in rice fields and crawfish 

ponds. 

Temporary and permanent erosion and sediment control measures, including silt fencing, 

diversion terraces, and vegetation, would also be installed per our Plan and Procedures. In most upland 

locations, an herbaceous vegetative cover would be re-established by spreading a grass seed and hydromulch mixture over the disturbed surface. See section 2.3.1.3 for a variation involving re-vegetation in 

areas of cropland and pasture. 

The type of seed would be selected to match adjacent cover, or as otherwise requested by the 

landowner or land management agency, or as recommended by the county extension agent. Depending 

upon the time of year, a seasonal variety, such as ryegrass, might be spread until a more permanent cover 

could be established. Steep slopes (e.g., stream banks) might require erosion control mats, revetments, or 

sod. Reseeding, fertilizing, and other measures would be employed until a cover equivalent to 

approximately 80 percent of similar, adjacent areas were achieved. Forested areas would be allowed to 

recover, except that no trees would be allowed to grow within the pipeline operational right-of-way so as 

to facilitate pipeline inspections. See section 2.3.1.3 for re-seeding of cropland, pasture areas, residential 

areas, and commercial areas. 

The success of re-vegetation would be monitored by KMLP (see section 2.5). Temporary and 

interim erosion control measures would be removed from areas where permanent measures are 

successfully in place. Private and public property, such as fences, gates, driveways, and roads that are 

disturbed by the pipeline construction would be restored to original or better condition. 

2.3.1.2 Wetland Construction Techniques 

Construction across delineated wetlands would occur in accordance of our Procedures, except 

where requested alternative measures are accepted. The construction technique used would be 

determined by the wetland conditions. In an unsaturated wetland, soil conditions would allow for topsoil 

segregation. In saturated wetlands, it would not be practicable to segregate topsoil. If there is enough 

standing water, floating construction techniques would be used such as push-pull method from a marsh 

buggy. In sensitive wetland areas or adjacent to large waterbodies, KMLP would use HDD to avoid 

impacts, as is described in section 2.3.1.3. 

Prior to commencement of construction in wetlands, KMLP would work with the COE, FWS, 

NOAA Fisheries, LDWF, other state and local agencies, and landowners to develop an acceptable sitespecific re-vegetation plan. 

Construction in Unsaturated Wetland 

The construction method employed in these areas would be similar to conventional upland 

techniques described in section 2.3.1.1, with some exceptions. Figures 2.3.1.2-1 and 2.3.1.2-2 show a 

typical cross-section for a construction spread in unsaturated wetlands. 

If normal construction equipment were to cause rutting or mixing of topsoil and subsoil, either 

low-ground-pressure equipment would be substituted for it, or a temporary board road would be installed. 

The choice of which of these two alternatives to use would be up to the construction contractor; both 

would allow passage of equipment with minimal disturbance to the surface and vegetation. 
 2-25 Description of the Proposed Action 

FIGURE 2.3.1.2-1 

Unsaturated Wetland Crossing with Topsoil Segregation 

PUBLIC 
 2-26 Description of the Proposed Action 

FIGURE 2.3.1.2-2 

Unsaturated Wetland Crossing with Topsoil Segregation 

PUBLIC 
 2-27 Description of the Proposed Action 

Trees would be cut to grade but only the stumps within 15 feet of the edge of the pipe trench 

would be removed unless safety concerns were to dictate otherwise. Topsoil over the pipe trench would 

be segregated from subsoils. A vegetated buffer zone would be left between the wetland and the upland 

construction areas, except in the pipe trench and travel lane. Erosion-control measures such as silt fences, 

interceptor dikes, and hay-bale structures would be installed and maintained to minimize sedimentation 

within the wetland. Trench plugs would be installed where necessary to prevent the unintentional 

draining of water from the wetland. 

Upon completion of construction, the right-of-way would be restored. Original surface hydrology 

would be re-established by backfilling the pipe trench and grading the surface either with backhoes or 

draglines operating from the board road or with low-ground-pressure tracked vehicles working in the 

spoil pile, depending upon the ambient water level, degree of soil saturation, and the bearing capacity of 

the soils. Segregated topsoil would be replaced in unsaturated wetlands. 

Marsh and wetlands along the Project range from saline to fresh, with varying degrees of 

saturation and water elevation, requiring a variety of plant species to be re-established. Unsaturated 

wetlands would be seeded. Areas where roots and stumps were removed in the pipe trench would allow 

existing vegetation to recover more rapidly in the remainder of the right-of-way once the board roads and 

spoil piles have been removed. In forested wetlands, trees greater than 15 feet in height would not be 

allowed to grow within 15 feet of the pipeline. Otherwise, unsaturated wetlands would be restored to 

their original state. 

Construction in Saturated Wetland 

The construction method employed in these areas would be similar to that described above for 

construction in unsaturated wetlands (see figure 2.3.1.2-3 and 2.3.1.2-4). Topsoil would be segregated 

except in areas where standing water is present or soils are saturated or frozen. In saturated soils, a 

concrete-coated pipe may be required to maintain negative buoyancy. 

Board mats and timbers would be used to facilitate the movement of equipment through and work 

within the wetlands. Equipment not associated with construction of the Project would be allowed to pass 

through the wetland in accordance with the our Procedures. 

Upon completion of construction, the right-of-way would be restored. Original surface hydrology 

would be re-established by backfilling the pipe trench and grading the surface either with backhoes or 

draglines operating from the board road or with low-ground-pressure tracked vehicles working in the 

spoil pile, depending upon the ambient water level, degree of soil saturation, and the bearing capacity of 

the soils. If topsoil is segregated, it would be replaced. Vegetation would be restored in accordance with 

our Procedures. 

Construction in Coastal (and other Submerged) Wetland 

Tidal marsh located between SH 82 and the southern shore of Sabine Lake between MP 1.5 to 

MP 3.92 and submerged freshwater marsh between MP 32.3 and MP 35.2 would be crossed using the 

push-pull method where conditions are compatible (i.e., wetland crossings less than 100 feet). 

A crane mounted on specially designed pontoons equipped with tracks, known as a marsh buggy, 

would be used to excavate a pipe trench (see figure 2.3.1.2-5). By backing the marsh buggy along the 

pipe trench centerline, and backfilling by tracking along the remains of the spoil pile after pipe 

installation, the construction right-of-way would be kept to the minimum width necessary for the pipe 

trench and the spoil pile, with no separate equipment space or passing lane. However, because of the 
 2-28 Description of the Proposed Action 

FIGURE 2.3.1.2-3 

Saturated Wetland Crossing without Topsoil Segregation 

PUBLIC 
 2-29 Description of the Proposed Action 

FIGURE 2.3.1.2-4 

Saturated Wetland Crossing without Topsoil Segregation 

PUBLIC 
 2-30 Description of the Proposed Action 

FIGURE 2.3.1.2-5 

Typical Submerged Marsh Crossing (Push-Pull) 

PUBLIC
 2-31 Description of the Proposed Action 

saturated condition of the soils, the slopes of both the pipe trench and the spoil pile would be very 

shallow, requiring a proportionately wider construction space for the trench and spoil pile (estimated to be 

90 feet). By keeping the stringing and welding of the pipe out of the submerged wetlands between 

staging areas, the area affected by construction would be kept to a minimum. Topsoil segregation would 

not be practical because the soil horizon would not be visible under water and the water would cause 

mixing of the topsoil and the subsoil. The pipe trench would remain flooded with water at all times, 

allowing flotation of the pipe. 

Temporary staging areas would be established at locations along the right-of-way that are 

accessible for construction equipment, personnel, and the delivery of materials via existing roads or 

waterways. Some staging areas might be set up on spud barges temporarily anchored in navigable 

waterways. Push-pull sections would be fabricated within these staging areas using a process similar to 

that described below for construction on barges in open inland waters. However, rather than moving the 

barge forward upon completion of each joint, the pipe would be pushed into the pipe trench. Floats would 

be strapped onto the pipe to keep it afloat to minimize drag on the bottom of the trench. A cable would be 

strung from the leading end of the push-pull section to the next staging area and placed in tension to guide 

the pipe along the trench. Because of the large bending radius of the 42-inch-diameter concrete-coated 

pipe, the trenches between staging areas would have to be nearly straight. The distances between staging 

areas would be limited by the weight of the pipe section and the pushing/pulling capacity of the 

construction equipment. 

Once the section of pipe has been floated into place, the floats would be cut and the pipe would 

be allowed to sink to the bottom of the trench. The marsh buggy would then backfill the trench and the 

disturbed area would be restored. Original surface hydrology would be re-established by backfilling the 

pipe trench (and flotation channel, where applicable) and grading the surface either with backhoes or 

draglines operating from low-ground-pressure tracked vehicles working in the spoil pile, depending upon 

the ambient water level, degree of soil saturation, and the bearing capacity of the soils. 

Submerged wetlands would typically be re-vegetated by transplanting mature herbaceous 

specimens at pre-established spacing. Some of these plants might be ones that were on the right-of-way 

before construction and were stored in temporary nurseries until restoration. Other plants would be 

obtained preferably from adjacent wetlands (collected over an area sufficiently large to minimize negative 

impact in the donor wetland) or else from local commercial nurseries. 

2.3.1.3 Special Pipeline Construction Techniques 

HDD Crossing Technique 

Major and other select waterbodies (not including open water construction across Sabine Lake), 

select highways, particularly congested pipeline corridors, and some wetland areas would be crossed by 

means of HDD. HDD would also be used to enter and exit Sabine Lake. KMLP is proposing a total of 

18 HDDs for the Project. A typical HDD installation for waterbody crossing is shown in figure 2.3.1.3-1 

and proposed HDD locations are listed by milepost in table 4.3.2.1-3 and appendix E. A complete 

description of the HDD process, including contingency plan, is provided in appendix I. 

HDD involves drilling a pilot hole under the waterbody, foreign pipeline, road, railroad, or 

wetland. The hole would be enlarged through successive reamings until the hole is large enough to 

accommodate the pipe. Throughout the process of drilling and enlarging the hole, a slurry called drilling 

mud of naturally occurring non-toxic materials such as bentonite clay and water, would be circulated 

through the drilling tools to lubricate the drill bit, remove drill cuttings, and hold the hole open. To 

capture drilling fluids in water-to-water HDDs and to minimize the release of drilling fluids to the surface 
2-32 

FIGURE 2.3.1.3-1 

Typical HDD Waterbody Crossing

PUBLIC 
 2-33 Description of the Proposed Action 

waterbody, a casing would be placed between the entry pit and the drill barge. Solids from any drilling 

fluids released to a surface waterbody would either settle out in the containment pits, or be rapidly 

dissipated by natural currents. Pipe sections long enough to span the entire crossing would be staged and 

welded along the construction work area on the opposite side of the waterbody (or other area being 

crossed) and then pulled through the drilled hole. 

The length of pipeline that can be installed by HDD depends upon soil conditions and pipe 

diameters, and is limited by available technology and equipment sizes (however, the maximum limit of 

HDD is about 5,000 feet). The main advantage of HDD is that the planned disturbance of the surface 

between the entry and exit points of the HDD is minimal, i.e., limited to the temporary deployment of 

telemetry cable, provided there is reasonable access to the entry and exit points for the drilling rig and 

fluids handling equipment. Also, it requires prefabrication of a section of pipe aboveground that is equal 

to the length of the HDD portion, and then pull that string back into the hole, the process disturbs the land 

cover and can create a depression (called a false trench) in areas outside of the construction right-of-way. 

Waterbodies crossed by HDD are discussed in section 4.3.2.1. Table 4.3.2.1-3 lists the 

approximate entry and exit locations, drill length, and features crossed by each proposed HDD.

Open-Cut Waterbody Crossing Technique 

The open cut crossing method is proposed for most minor waterbody crossings where dry 

(unsaturated) coil conditions are anticipated on the banks. This technique is similar to an upland open-cut 

technique. It would involve excavation of the pipeline trench across the waterbody, installation of a 

prefabricated segment of pipeline, and backfilling of the trench with native material. No effort would be 

made to isolate the stream flow from the construction activities. Backhoes and other excavation 

equipment would typically operate from one or both banks of the waterbody but could operate within the 

waterbody to achieve the necessary reach. Equipment in the waterbody would be limited to that needed 

to complete the crossing. All other construction equipment would cross the waterbody over equipment 

bridges, unless otherwise allowed by our Procedures for minor waterbodies. 

KMLP would minimize impacts to aquatic environments by implementing our Procedures. 

Construction activities would be scheduled so that the trench would be excavated immediately prior to 

pipe-laying activities. The duration of construction within each waterbody would be limited to 24 hours 

for minor waterbodies (10-feet wide or less) and 48 hours for intermediate waterbodies (greater than 10-

feet wide but less than or equal to 100 feet in width). In accordance with the FERC’s Procedures, 

excavated spoil would be stockpiled in the construction right-of-way at least 10 feet from the stream bank 

or in approved additional work areas, and would be surrounded by sediment-control devices. The 

waterbody banks would be restored to as near to pre-construction conditions as possible within 24 hours 

of completion of each open-cut crossing. 

Dry Waterbody Crossing Techniques 

Crossings of small perennial and intermediate streams would be accomplished in accordance with 

our Procedures. The pipeline would be installed by means of a dry-ditch method for crossings of 

waterbodies up to 30-feet wide (at the water’s edge at the time of construction) that are state-designated 

significant warmwater fisheries. KMLP proposes to cross all waterbodies up to 30-feet wide by dry ditch 

method, e.g., flume and horizontal bore. Appendix F lists all water bodies crossed and the crossing 

method. 

The dry flume crossing method would be used for some minor and intermediate waterbodies and 

would involve installation of a temporary dam and a flume pipe to divert the entire stream flow over the 
 2-34 Description of the Proposed Action 

construction area and allow for trenching of the crossing in dry or nearly dry conditions (see figure 

2.3.1.3-2). A 10-foot vegetated buffer zone would be left between the edge of the waterbody (or any 

associated wetlands) and the upland construction area. Dams would be constructed of sand bags, sand 

bags and plastic sheeting, or inflatable bladders to direct the flow into the flume pipe. Spoil removed 

during the trenching would be stored at least 10 feet away from the water’s edge (topographic conditions 

permitting). A section of pipe long enough to span the entire crossing would be fabricated on one bank 

and slipped under the flume pipe to the opposite bank. The trench would be backfilled and the bottom of 

the watercourse and banks restored and stabilized before the flume pipe and dams are removed. Sediment 

barriers, such as silt fencing, staked straw bales and trench plugs, would be installed to prevent spoil and 

sediment-laden water from entering the waterbody. 

Horizontal boring is a method that would involve pushing the pipe through a hole below minor 

waterbodies. Often, these waterbodies are drainaige ditches along the side of a road in which case both 

the waterbody and road would be bored. First, a bore pit would be dug on one side of the crossing and a 

receiving pit on the other. Both would be excavated to at least 5 feet below the surface. The bore pit 

would be graded such that the bore would be at the proper elevation for installation of the pipe. A boring 

machine would then be lowered to the bottom of the bore pit and placed on supports. The boring machine 

would cut a shaft under the waterbody by means of a cutting head mounted on an auger. The pipe would 

then be pushed through behind the auger. This method is also used for most major road or railroad 

crossings, as described below. 

Sabine Lake Crossing 

Leg 1 of the pipeline would enter and exit Sabine Lake by HDD. The construction methods in 

these areas would be as described below for HDDs, except that the pre-fabricated HDD pull sections at 

both the southern and northern end of the lake would be dewatered, floats would be strapped to the 

pipeline to provide positive buoyancy, and the pipeline would be floated across the water using tugboats 

(rather than allowed to drag across the lake bottom). KMLP anticipates that the installation of the pull 

section into the borehole can be completed in less than 24 hours. 

For construction in the open waters of Sabine Lake (from approximately MP 4.8 to MP 18.0), 

Leg 1 of the Project would be installed using shallow draft spud barges. The use of spud barges in areas 

of the lake that are less than 8 feet deep would require the excavation of a flotation channel within a 

construction right-of-way up to 300 feet wide. Using barges with anchor spuds would eliminate the 

need for an anchor spread and anchor-handling boats, minimizing the area affected by construction 

operations. Based on pre-construction surveys, KMLP proposes the following construction steps in the 

open water areas of Sabine Lake. 

The pipeline route would not cross over the Sabine River, but rather turn east at the mouth of the 

river around MP 18.6 and proceed along its southern banks through a series of HDDs and open cuts. 

However, the proposed HDD at the mouth of the Sabine River would have a temporary extra workspace 

that would protrude into the river and a pull section that would be floated across the river using tugboats. 

Other HDDs along the southern banks of the Sabine River would also have floating pull sections 

extending into the river, which would be held in place by timber piles. KMLP anticipates that the pull 

sections would lie across the water for less than 24 hours. 
 2-35 Description of the Proposed Action 

FIGURE 2.3.1.3-2 

Flume Crossing Method 

PUBLIC 
 2-36 Description of the Proposed Action 

Pre-Construction Survey 

KMLP has conducted a shallow-hazards survey within a 3,000-foot-wide corridor in Sabine Lake 

to identify existing foreign (i.e., third-party) pipelines, obstructions that may adversely affect 

construction, and potentially significant submerged cultural resources. Where water depths are 

sufficiently shallow, the pre-construction survey was accomplished by means of small, shallow draft 

boats equipped with remote-sensing instrumentation, including a magnetometer/gradiometer, side-scan 

sonar, sub-bottom profiler, bathometer, and Global Positioning System (GPS) navigation. Adjustments to 

the proposed centerline were made, where feasible, to avoid magnetic anomalies that might indicate 

obstructions or significant cultural resources. Where avoidance was not feasible, anomalies were further 

investigated by probing, sampling, or diving, and either removed or recovered, as appropriate and as 

approved by local agencies. KMLP plans to conduct a second shallow-hazards survey within the 

construction right-of-way immediately prior to construction to verify that conditions have not changed 

since the original survey and to locate foreign pipelines. The right-of-way centerline and boundaries 

would then be staked with bamboo poles or floating buoys for excavation. 

Excavation 

The trench for the Project would be excavated by means of a barge-mounted clam-bucket (or 

equivalent) dredge. With a draft of up to seven feet, it would be necessary for the dredge barge to 

excavate a flotation channel to provide access for itself from existing navigation channels to the right-ofway (see figure 2.3.1.3-3), and along the right-of-way, in water depths of less than 8 feet (see figure 

2.3.1.3-4). In water depths greater than 8 feet, a flotation channel would not be required (see figure 

2.3.1.3-5). The dredge barge would cast pipe-trench and flotation-channel spoil to either side of the rightof-way centerline, keeping the spoil below the water surface, where feasible, to minimize wave-generated 

turbidity. 

In waters that support powered marine vessel traffic, the spoil would be placed parallel to the 

trench in 500-foot-long piles, with 50-foot-wide openings to allow the passage of local watercraft. To 

ensure the safety of the boating public, the spoil piles and openings would be marked with timber piles, 

warning signs, and navigation lights. Surveyors would ensure the dredge remains on the approved 

centerline, verify that the spoil remains within the 300-foot construction right-of-way, and confirm that 

the bottom of the pipe trench was at the designed depth. 

Pipe Fabrication and Lowering 

The pipeline would be fabricated aboard a string of shallow-draft spud barges, lashed together in 

a line to form the lay barge. The concrete-coated pipe would first be offloaded from tugboat-towed 

supply barges by means of a crane mounted on the lead barge. Each pipe joint would then be aligned 

end-to-end with the previous joint on a set of rollers that would extend the length of the lay barge. The 

pipe joints would be assembled into one continuous pipeline by passing them through multiple welding, 

inspection, repair, and coating stations. Only qualified welders would be allowed to perform the welding. 

Welders and the welding procedure would be qualified according to applicable API standards. To ensure 

that the assembled pipe met or exceeded the design strength requirements, the welds would be visually 

inspected and examined by means of X-ray, ultrasound, or other approved methods, in accordance with 

American Society of Mechanical Engineers standards. Welds displaying unacceptable slag inclusions, 

void spaces, or other defects would be repaired or cut out and re-welded. Once each weld had passed 

inspection and received its final coating, the pipe would be lowered off the back end of the lay barge into 

the pipe trench by lifting the anchor spuds of the lay barge and moving the lay barge forward the length of 

one pipe joint. The next pipe joint would be rolled into position for welding and the process would be 

repeated. 
 2-37 Description of the Proposed Action 

FIGURE 2.3.1.3-3 

Typical Access Canal in Open Water 

PUBLIC 
 2-38 Description of the Proposed Action 

FIGURE 2.3.1.3-4 

Typical Inland Open Water Construction, <8 feet depth of water 

PUBLIC 
 2-39 Description of the Proposed Action 

FIGURE 2.3.1.3-5 

Typical Inland Open Water Construction, >8 feet depth of water 

PUBLIC 
 2-40 Description of the Proposed Action 

To ensure boating safety, barges and tugboat traffic associated with construction of the pipeline 

would comply with all U.S. Coast Guard requirements. KMLP would also provide information to allow 

the Coast Guard to issue a Notice to Mariners. 

Jetting 

Following lowering in, surveyors would confirm that the pipe is at sufficient depth to provide a 

minimum of four feet of soil cover, as required by the COE. Should the minimum cover not have been 

achieved, the pipe would be lowered farther using a barge-mounted hydraulic jetting system. 

Foreign Pipeline Crossings in Open Water 

The crossing of foreign pipelines in open water would require a specialty crew and equipment to 

pass the proposed pipeline under the existing pipeline, raise the proposed pipeline to the surface to make 

the tie-in, and to place concrete mats between the pipelines to ensure minimum separation distance is 

maintained. 

Backfilling and Final Grading 

Once sufficient depth of the pipe has been achieved to provide the minimum soil cover, the 

dredge barge would return to backfill the pipe trench and flotation channel, using the available spoil 

adjacent to the excavation. The bottom would be restored to within 1 foot of the original contour using 

the clam bucket. Surveyors would confirm that final grade and tolerance have been achieved. Where the 

1 foot-grade tolerance was not achieved, a joint of pipe or similar device would be mounted on the dredge 

line and dragged across the bottom to remove high spots, until the contours had been restored to within 

the allowable tolerance. Where insufficient spoil remained to completely backfill the trench and channel 

to within 1 foot of original contours due to erosion of the spoil piles and suspension of solids in the water 

column during handling, the trench and channel would be allowed to naturally fill with sediments over 

time. 

Calcasieu River Crossing 

The Calcasieu River and the major tributary that serves as a ship channel to the Trunkline LNG 

Terminal (from MP 49.6 to MP 51.1) would be crossed just north of Choupique Island by means of two 

back-to-back HDD crossings separated by an approximately half-mile stretch of conventional upland 

construction across the intervening peninsula. The entry hole for the first HDD and the exit hole for the 

second would have to be located in a COE dredge-spoil disposal area in that peninsula. KMLP would 

design the pipeline through this area with consideration for the potential placement of additional 

overburden and the consolidation and settlement of dredge spoil materials. 

Foreign Pipeline Crossings 

The Project would cross numerous foreign pipelines. KMLP pipelines would be installed by 

horizontal bore under most single pipelines, as shown in figure 2.3.1.3-6. In areas where pipelines are 

highly congested or are near major waterbodies or wetlands, HDD would be used (see table 4.3.2.1-3). 

KMLP proposed to use two consecutive HDDs to cross a high concentration of pipelines from MP 25.3 to 

MP 26.8. Because the HDD plans in KMLP’s application were incomplete, we recommend: 

• KMLP file with the Secretary a site-specific construction plan for the crossing of foreign 

pipeline corridors between MP 25.3 and MP 26.8. These site-specific plans should 

include scaled drawings identifying all areas that would be disturbed by construction. 
 2-41 Description of the Proposed Action 

FIGURE 2.3.1.3-6 

Typical Foreign Pipeline Crossing 

PUBLIC 
 2-42 Description of the Proposed Action 

KMLP should file these plans for review and written approval by the Director of the 

OEP prior to construction. 

Road and Railroad Crossings 

A total of 104 major paved highways and railroads, along which traffic could not be interrupted, 

would be crossed by horizontal boring or by HDD under the roadbed. Most of the smaller unpaved roads 

would be crossed by open trenching, and then restored to pre-construction conditions or better. If an 

open-cut road were to require extensive construction time, provisions would be made for temporary 

detours or other measures to allow safe traffic flow during construction. 

The pipeline would be buried to a depth of at least 5 feet below the road surface, and 10 feet 

below the rail of the railroad, and would be designed to withstand anticipated external loadings. At points 

of access to the right-of-way from hard-surfaced roads, a stone pad would be installed as a construction 

entrance to control mud and dirt from tracking onto the highway. Casings will be installed only where 

specifically required by railroad or road authorities. 

Extra workspaces for the Project as a whole, including those associated with road and railroad 

crossings, are shown in appendix C. 

Crop and Pasture Crossings 

KMLP would segregate topsoil in actively cultivated and rotated cropland and improved 

pastureland. A maximum of 12 inches of topsoil would be segregated in accordance with our Plan and 

Procedures in these areas, and in other areas at the specific request of the landowner or land management 

agency, if applicable (e.g., Louisiana State Lands, FWS). The topsoil and subsoil would be temporarily 

stockpiled in separate windrows on the construction right-of-way and would not be allowed to mix. 

Where topsoil is less than 12 inches deep, the actual depth of the topsoil would be removed and 

segregated. The depth of the ditch would be sufficient to allow for at least three feet of cover on top of 

the pipe. 

After construction, compacted subsoil would be disked, and the segregated topsoil would be 

returned to its original horizon, unless otherwise requested by the landowner. Actively cultivated 

cropland would be left unseeded at the request of the landowner if preparation of the ground for planting 

is due to occur right after the completion of construction. Pasture would be reseeded with species similar 

to pre-construction and nearby vegetation. 

Rice Field and Crawfish Pond Crossings 

Rice fields and crawfish ponds (or isolatable sections thereof) would be drained before 

commencement of construction of the Project. KMLP would attempt to schedule construction during 

times when the fields and ponds are not normally flooded. If necessary, KMLP would also negotiate with 

the landowners a deferral of flooding or planting for the season or year in which construction were due to 

take place. This would improve the chances of the soil being dry and thus reduce the chance of soft spots 

in the soil remaining over the pipeline after construction. Typically, the conventional upland construction 

methods (described in section 2.3.1.1) would be appropriate. Should soil saturation be too great at the 

commencement of construction, temporary timber mats would be used resulting in a construction method 

more similar to unsaturated-wetland construction methods. If soil saturation were even greater, a 

saturated-wetland construction method would be used. 
 2-43 Description of the Proposed Action 

Topsoil would be segregated unless the water level and degree of soil saturation were too high at 

the time of construction or if there were no obvious horizon between the topsoil and subsoils. Compacted 

subsoil would be disked, and the segregated topsoil would be returned to its original horizon, unless 

otherwise requested by the landowner. 

Residential Area Crossings 

There are no residences (i.e., homes) within 50 feet of the edge of the proposed construction 

right-of-way. However, the pipeline would cross several residential areas between MP 38 and 124 which 

would involve barns and sheds within 50 feet of the edge of the construction right-of-way.. 

In these areas, KMLP would reduce construction workspace areas as practicable to minimize 

inconvenience to property owners; at some locations, HDD might be used to minimize surface 

disturbance to residences and other buildings near the right-of-way. If construction were to require the 

removal of private property features, such as gates or fences, the landowner or tenant would be notified 

and consulted prior to the action. Following completion of major construction, the property would be 

restored as requested by the landowner, insofar as the landowner's requirements are compatible with 

KMLP’s standards regarding restoration and maintenance of the right-of-way, and applicable regulations, 

except that permanent structures would not be allowed within the 50-foot operating right-of-way. 

Property restoration would be in accordance with any agreements between KMLP and the landowner. 

The FERC's residential construction procedures would be followed. 

Residential lawns would be re-seeded or sodded according to the variety of the original grass. 

Wherever practical, shrubs and small trees would be temporarily transplanted and replaced unless they 

were too close to the right-of-way to begin with. 

Commercial and Industrial Area Crossings 

Impacts to commercial and industrial areas would be limited to the construction and postconstruction restoration periods when construction activities could inconvenience business owners, 

employees, and customers. KMLP would maintain close coordination with business owners to maintain 

access, decrease construction duration, and generally minimize impacts. Specifically, impacts to 

commercial facilities located on the east side of the Calcasieu River would be avoided by HDD. 

Commercial lawns would be re-seeded or sodded according to the variety of the original grass. 

Wherever practical, shrubs and small trees would be temporarily transplanted and replaced unless they 

were too close to the right-of-way to begin with. 

2.3.2 Aboveground Facilities 

Construction of the meter station and interconnection facilities would involve typical industrial 

facility construction procedures. Construction activities and storage of construction materials and 

equipment would be confined to the facility footprint. Following the initial earth work, excavation would 

be completed as needed for the concrete foundations for the metering equipment and any buildings. 

Subsurface friction piles may be required to support foundations, depending upon the bearing capacity of 

the existing soils and the equipment loads. Forms would be set, rebar installed, and the concrete poured 

and cured in accordance with applicable industry standards. Backfill would be compacted in place, and 

excess soil would be used elsewhere or distributed around the site to improve grade. Construction debris 

and wastes would be disposed of appropriately. 
 2-44 Description of the Proposed Action 

The metering equipment and other materials would be delivered to the site by truck, off-loaded 

using cranes or front-end loaders (or both), positioned on the foundations, leveled, grouted where 

necessary, and secured with anchor bolts. All components in high-pressure natural gas service would be 

hydrostatically tested, and all controls and safety equipment and systems, including emergency shutdown, 

relief valves, and gas and fire detection equipment would be checked and tested before being placed in 

service. Following completion of construction, each site would be fenced and most areas in and around 

the meters and associated piping and equipment would be covered with crushed rock (or equivalent). 

Roads and parking areas may be crushed rock, concrete, or asphalt. Other ground surfaces, including 

adjacent areas outside the fence, would be restored, seeded, and revegetated. 

Pig launchers and receivers would be installed completely within the boundaries of the associated 

meter station/interconnect sites. MLVs would be installed within the pipeline right-of-way. 

2.3.3 Ancillary Facilities 

Each extra workspace would be surveyed and staked, cleared, and graded in a manner that took 

account the use of the land on which it is to be located. In general, this would be the same manner as the 

nearest portion of right-of-way (because their land uses would in general be identical). Similarly, after 

construction, each extra workspace would be restored in a manner appropriate to the original land use. 

Previously existing access roads that were modified and used during construction would be 

returned to original or better condition upon completion of the pipeline facilities installation. New access 

roads constructed specifically for the Project would be removed, the surface graded to original contours, 

and the land restored to its original use, unless otherwise requested by the landowner, or unless the roads 

would be required for ongoing access to the right-of-way during pipeline operations, and in accordance 

with any permit requirements. Temporary erosion-control measures would be removed upon final 

stabilization and installation of permanent erosion control measures. 

As discussed in section 2.1.3, KMLP proposes to use 12 pipe storage and contractor staging areas 

during construction of the Project (see appendix C). The modifications that KMLP proposes to make to 

these areas during construction consist of: 

• Grading; 

• Adding road base, i.e., geotech lining and gravel; and 

• Constructing pipe supports, i.e., dirt berms. 

Upon completion of the construction phase, all temporary facilities (e.g., trailers, sheds, latrines, 

pipe supports, fencing, and gates) would be removed from the pipe storage and contractor yards. Unless 

otherwise requested by the landowner, each site would be graded to original contours and the land 

restored to its original use. The site would be re-vegetated, any permanent erosion-control measures 

would be installed, and temporary erosion-control measures would be removed. 

2.4 OPERATION AND MAINTENANCE PROCEDURES 

KMLP would operate and maintain the proposed pipeline and aboveground facilities in 

compliance with 49 CFR 192, the FERC’s regulations at 18 CFR 380.15, and our Plan and Procedures. 

KMLP would employ locally based, full-time staff to operate and maintain the proposed pipeline 

system. Maintenance activities would include monitoring, inspection, and repair of the right-of-way, and 
 2-45 Description of the Proposed Action 

cleaning of the pipeline. Periodic aerial and ground inspections would be performed to identify soil 

erosion that may expose the pipeline; dead vegetation, which may indicate a leak in the pipeline; 

unauthorized encroachment on the right-of-way, e.g., by buildings; and other conditions that could 

constitute a safety hazard or require preventative maintenance or repairs. The pipeline impressed-current 

cathodic protection system would also be monitored and inspected periodically to ensure proper and 

adequate corrosion protection. All MLV sites would be regularly inspected and maintained. Intelligent 

pigging would be undertaken periodically to inspect the interior of the pipeline. 

KMLP would maintain vegetation on the permanent right-of-way in upland areas by mowing, 

cutting, and trimming. Large brush and trees would be removed periodically from within the operational 

right-of-way. Trees greater than 15 feet in height, or deep-rooted shrubs that could damage the pipeline’s 

protective coating, obscure periodic surveillance, or interfere with potential repairs, would not be allowed 

to grow within 15 feet of the pipeline in wetlands or within 25 feet of the pipeline in uplands. The 

frequency of vegetation maintenance would depend upon the growth rates, but would not be more 

frequent than dictated by our Plan and Procedures. Vegetation maintenance would not normally be 

required in agricultural or grazing areas. Other than preventing tree growth as described above, vegetation 

maintenance would not normally be required in wetlands.

Pipeline facilities would be clearly marked at line-of-sight intervals and at crossings of roads, 

railroads, waterbodies, and at other key points in accordance with DOT regulations. Markers would 

clearly indicate the presence of the pipeline and provide a telephone number and address where a 

company representative could be reached in the event of an emergency or prior to any excavation in the 

area of the pipeline by a third party. 

2.5 ENVIRONMENTAL COMPLIANCE, INSPECTION, AND MITIGATION MONITORING 

KMLP would employ a tracking system to ensure that relevant pre-construction surveys, 

clearances, permits, and plans were completed prior to releasing the construction contractors to begin 

construction activities. 

For purposes of quality assurance and compliance with mitigation measures, other applicable 

regulatory requirements, and project specifications, KMLP would be represented on each pipeline spread 

by a Chief Inspector, one or more Craft Inspectors, and at least one Environmental Inspector (EI). The EI 

position would be a full-time position. EIs would have authority to stop work and require corrective 

actions to achieve environmental compliance. Their duties would be consistent with those contained 

within Paragraph II.B (Responsibilities of Environmental Inspectors) of the FERC’s Plan and would 

include ensuring compliance with any environmental conditions attached to the FERC Authorization, any 

other permits or authorizations, and environmental designs and specifications. Because KMLP has not 

yet defined these details for the Project, we recommend that: 

• KMLP file with the Secretary for review and written approval by the Director of OEP 

the proposed number of spreads, EIs per spread and for the entire Project, and the 

specific duties of those EIs prior to the issuance of the final EIS.

KMLP also would develop a project-specific environmental training program that would be 

designed to ensure that: 

• Qualified environmental training personnel provide thorough and well-focused training 

sessions regarding the environmental requirements applicable to the trainees’ activities; 

• All individuals receive environmental training before they begin work; 
 2-46 Description of the Proposed Action 

• Adequate training records are kept; and 

• Refresher training is provided as needed to maintain high awareness of environmental 

requirements. 

KMLP would file with the Commission any updates to its proposed environmental inspection 

program. KMLP is considering but has not committed to requesting the use of our Third-Party 

Compliance Monitoring and Variance Request Program for pipeline construction and restoration. In 

addition to KMLP’s program, we would conduct periodic inspections to monitor the project for 

compliance with the Commission’s environmental conditions. 

2.6 SAFETY CONTROLS 

DOT regulations in 49 CFR Part 192 require that KMLP prepare an Integrity Management Plan, 

to prevent system losses and failures, and an Emergency Response Plan, to protect the public, workers, 

and the environment in the event of loss or failure. 

Engineering features and maintenance aspects have been incorporated by KMLP in its Project 

design to prevent system losses and failures. Engineering features include: 

• Corrosion protection system; 

• Overpressure protection system; 

• SCADA and leak-detection system; 

• MLVs; and 

• Hydrostatic testing as part of commissioning. 

Maintenance aspects include: 

• Preventative maintenance program; 

• Aerial surveillance flights; 

• On-ground leak-detection surveys; and 

• Intelligent pigging. 

Protection against corrosion would be provided by an external fusion-bonded epoxy coating 

together with an impressed-current cathodic-protection system. Cathodic-protection protection units 

would be monitored regularly to maintain the requisite pipe-to-soil potential in accordance with the 

specifications of the relevant DOT regulations. 

In accordance with DOT regulations, KMLP would devise and implement an Emergency 

Response Plan to be followed in the event of an emergency such as a gas leak, fire, explosion, or other 

damage to the pipeline system. Procedures would include: 

• Training of employees on emergency procedures; 

• Establishing liaisons with appropriate fire, police, and other community officials; and 

• Informing the public on how to identify and report an emergency condition. 
 2-47 Description of the Proposed Action 

2.7 FUTURE PLANS AND ABANDONMENT 

At this time, KMLP has no plans for future expansion of any facilities associated with the Project. 

If ever an expansion is envisioned (for example, additional interconnects to deliver gas to other pipelines, 

compression facilities to increase system capacity, or new access roads to gain access to these or other 

new facilities), it would require FERC authorization, following appropriate analysis, and be subject to 

applicable federal, state, and local regulations in force at that time. 

KMLP envisions a 25-year life for the Project. However, the facilities themselves would, with 

proper maintenance, be capable of being operated for 50 years or more, according to KMLP. Regardless 

of the duration of utilization of the proposed pipeline system, abandonment of any facilities would require 

FERC authorization, following appropriate analysis, and be subject to applicable federal, state, and local 

regulations in force at that time. 
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