ENVIRONMENTAL IMPACT ANALYSIS 

SECTION 4 
 4-1 4.0 –Environmental Impact Analysis 

4.0 ENVIRONMENTAL IMPACT ANALYSIS 

The environmental consequence of constructing and operating the Terminal Expansion and Elba 

Express Pipeline facilities would vary in duration and significance. Four levels of impact 

duration were considered: temporary, short term, long term, and permanent. Temporary impact 

generally occurs during construction with the resource returning to preconstruction condition 

almost immediately afterward. Short term impact could continue for up to 3 years following 

construction. Impact was considered long term if the resource would require more than 3 years 

to recover. A permanent impact could occur as a result of any activity that modifies a resource 

to the extent that it would not return to preconstruction conditions during the life of the Project, 

such as the construction of Terminal Expansion facilities. We considered an impact to be 

significant if it would result in a substantial beneficial or adverse change in the physical 

environment and the relationship of people with the environment. 

In this section, we discuss the affected environment, general construction and operational impact, 

and proposed mitigation for each resource. Southern LNG, EEC, and Southern, as part of their 

proposals, agreed to implement certain measures to reduce impact. We evaluated their proposed 

mitigation to determine whether additional measures are necessary to reduce impact. These 

additional measures appear as bulleted, boldfaced paragraphs in the text. We will recommend 

that these measures be included as specific conditions to authorizations that the Commission may 

issue to Southern LNG, EEC, and Southern. Conclusions in this EIS are based on our analysis of 

the environmental impact and the following assumptions: 

• Southern LNG, EEC, and Southern would comply with all applicable laws and 

regulations; 

• the proposed facilities would be constructed as described in section 2.0 of this document; 

and 

• Southern LNG, EEC, and Southern would implement the mitigation measures included in 

the application and supplemental filings to the FERC, including those submitted in its 

comments on the EIS. 

4.1 GEOLOGIC RESOURCES 

4.1.1 Geologic Setting 

Terminal Expansion

The Terminal is located in the Coastal Plain Province. This region contains a thick sequence of 

unconsolidated and semi-consolidated alluvium consisting of interlayered sands, sandy clay, 

gravelly sands, marine clays, and quartz sands. 

The topography of the Elba Island is a gentle 0 to 5 percent slope with elevations ranging from 0 

to 11.5 feet above sea-level. 

Dredge spoil was placed hydraulically on Elba Island more than 30 years ago during 

maintenance of the Savannah Harbor Channel and typically ranges from 0 to 4 feet in thickness. 
 4-2 4.0 –Environmental Impact Analysis 

As a result, the topography of the island has been altered. Identified surficial materials present 

during a geotechnical investigation completed to support the Terminal Expansion facilities are 

provided in table 4.1-1 below. 

TABLE 4.1-1

Surficial Material Present at Elba Island Terminal Expansion Site 

Surficial Material Elevation 

(ft MLW) Description 

Fill 0 to -7.5 Hydraulic fill composed of a clay, silt, and sand; hard crust at ground surface; 

thickness is variable. Recent dredge spoil. 

Soft Clay -7.5 to -26.5 Alluvial clay with discontinuous sand lens and an organic content of 10 to 35%; very 

soft to firm consistency with increasing depth. A Pleistocene (0.1 to 1.8 mya) 

deposit. 

Sand -26.5 to -47.5 Poorly graded, fine to medium sand, medium dense, to dense. Variable thickness of 

5 to 31 feet. Believed to be an early Pleistocene to late Miocene (5.3 to 11.2 mya) 

depositional feature. 

Very Stiff Sandy Clay -47.5 to -95 Olive green sand and clay deposits, with silts, clays, and fine sands. Known locally 

as the Marl Formation. Reported as a competent bearing stratum for pile 

foundations. Miocene (5.3 to 23.8 mya) deposit. 

Very Dense Clayey Sand -95 to -105 Very dense. Miocene deposit. 

Very Dense Silty Sand -105 to -140 Very dense. Miocene deposit. 

________________________________________________________________ 

(WPC, 2006a) 

The shoreline on the northeast side of Elba Island, along the Savannah River main stem, is 

almost completely armored with granite riprap to prevent erosion. The shoreline on the 

southwest side of the island, along the South Channel, is shallow, sheltered, not exposed to large 

vessel wakes, and has limited scour potential from swift currents, which occur in the Savannah 

River main stem. As a result, the South Channel side of Elba Island is stable and almost free of 

rip-rap (Applied Technology & Management, Inc. [ATM], 2006). 

Bedrock is located at a significant depth below ground surface, where limestone is present 

(WPC, 2006a). Based on the proposed design of the Terminal Expansion facilities, the blasting 

of bedrock would not be required. 

Geotechnical investigations conducted by Southern LNG indicate that the subsurface sediments 

underlying the site of the proposed Terminal Expansion site consist of about 4 feet of dredged 

and man-made fill. Below this are a 34-foot-deep soft clay layer, followed by layers of sand, 

very stiff sandy clay, very dense clayey sand, and very dense silty sand, to a depth of -140 feet 

MLW (WPC, 2006a). 

Elba Express Pipeline

The proposed pipeline route begins in the extensive Coastal Plain Province trending to the 

northwest toward the Fall Line, which is the physiographic and geologic boundary contact 

between the younger sediments of the Coastal Plain and the older crystalline rocks of the 

Piedmont Physiographic Province. The Fall Line roughly follows a straight line extending 

between the cities of Columbus, GA and Augusta, GA. Notable conditions are stream 

characteristics, more rapids and shoals near this geologic contact, compared to the wider, 
 4-3 4.0 –Environmental Impact Analysis 

meandering floodplains of the Coastal Plain (UG-CVIG, 2006). The relief of the pipeline route 

ranges from 25 feet to approximately 1,000 feet with gentle to moderate slopes, each increasing 

as the pipeline trends to the northwest (UG-CVIG, 2006). 

The thick sequence of alluvium in the Coastal Plain Province contains areas of semi-consolidated 

alluvium as the pipeline approaches the Fall Line and the Piedmont Province, where crystalline 

rock is locally present closer to the surface. In the Piedmont, a complex mix of igneous and 

metamorphic bedrock is covered by nearly continuous layer of unconsolidated material called 

regolith (UG-CVIG, 2006). 

Along a majority of the pipeline route, subsurface construction can be completed with 

conventional excavation equipment. However, in areas of shallow bedrock likely to be 

encountered in the Piedmont, there is a potential need for bedrock blasting. EEC is in the 

process of completing a geotechnical investigation to determine the need for blasting along the 

pipeline route. 

EEC has prepared a Blasting Specification Plan to support blasting activities. We recommend 

that prior to the commencement of blasting, EEC file with the Secretary of the Commission 

(Secretary) a revised Blasting Specification Plan that includes: 

a. the locations (by MP) where bedrock blasting would be required; 

b. any applicable state blasting regulations; and 

c. a pre-blast survey assessment of structures, wells, and utilities within 150 feet 

of the proposed construction ROW. 

In the event property owners identify any damage or change to the properties, or if 

excessive peak particle velocities have been recorded during the blasting operations, EEC 

shall complete follow-up surveys of the potentially impacted property. 

4.1.2 Mineral Resources 

Terminal Expansion

No mineral resources that are currently or potentially exploitable have been identified at the 

Terminal site (USGS, 2004; WPC, 2006a). 

Elba Express Pipeline

Mineral resources along the pipeline route include crushed stone, sand, gravel, dimensional 

granite, and kaolin. Currently or potentially exploitable mineral resources are primarily limited 

to the Fall Line and the Piedmont areas of the pipeline route. Mining appears to be limited to 

surface mining (GMA, 2006; USGS, 2004). 

In Elbert County, Georgia, the proposed pipeline passes within 2,500 feet of six mining 

operations. However, the proposed pipeline would not impact any current or potential mining 

activities.
 4-4 4.0 –Environmental Impact Analysis 

4.1.3 Geologic Hazards 

Seismicity and Faulting

Georgia and South Carolina are located in an area with potential for intraplate earthquakes to 

occur. Many are relatively minor, however, strong earthquakes, such as the 1886 magnitude 7.0 

earthquake centered in Charleston, South Carolina can occur in the Southeastern U.S. (UGA, 

2006b; WPC, 2006b). 

The U.S. Geological Survey (USGS) produces Hazard Maps for the United States with 

probabilistic peak ground acceleration values represented as a factor of “g”. The factor “g” is 

equal to the force on an object at the surface relative to gravity. The scale runs from 0-2 percent 

g (lowest hazard) to 350 percent g (highest hazard). Engineers and designers utilize these 

probabilistic ground motion values, representing hard rock beneath site soils, when designing 

earthquake resistant structures. 

Terminal Expansion

The Terminal Expansion site is located in Seismic Zone 2A of the Uniform Building Code and 

requires completion of a seismic hazard study. USGS Seismic Hazard Maps for the Terminal 

indicate a 10 percent probability of a 5.72 percent g exceedance in 50 years, and a 2 percent 

probability of a 19.66 percent g exceedance in 50 years (USGS, 2002a). 

Southern LNG conducted a site-specific field exploration study to further assess the geotechnical 

characteristics of the underlying sediments for foundation design and information needed to 

accurately assess seismic risks at the Terminal. The evaluation included probabilistic seismic 

hazard analysis that incorporated the potential contribution to the hazard from both regional and 

distant earthquake sources. The results of this study indicate the relative seismic risk is low for 

the Terminal site, and that structures can be designed to survive the site-specific design criteria 

(WPC, 2006a; WPC, 2006b). The site-specific design criteria are contained in the September 15, 

2006 Geotechnical Engineering Investigation Report, prepared by WPC on Southern LNG’s 

behalf. 

Critical components (Seismic Category I) of the proposed project would be designed in 

accordance with the Seismic Design Requirements of National Fire Protection Association 

Standard (NFPA) 59A-2001, and the guidance set forth in FERC Staff’s Draft Seismic Design 

Guidelines and Data Submittal Requirements for LNG Facilities (2007). 

Non-critical facilities or structures would be designed in accordance with the seismic design 

criteria in American Society of Civil Engineers (ASCE) Standard, ASCE 7-98, Minimum Design 

Loads for Buildings and Other Structures. 

FERC staff has sought additional information and clarification of certain details regarding the 

seismic design criteria through its June 13, 2007 Environmental Data Request. Southern LNG 

has responded stating that several pieces of information would be provided “by middle to end of 
 4-5 4.0 –Environmental Impact Analysis 

July, 2007.” Because the outstanding information has not yet been filed, we recommend that 

prior to construction, Southern LNG file, for review and approval by the Director of OEP, 

the seismic design and geotechnical information requested in Questions 13, 14, 16, 17, 18, 

and 19, of staff’s June 13, 2007 Environmental Data Request. The filing should also 

include the list of Seismic Category assigned to each structure, component, and system 

constructed as part of the Elba III facility expansion.

Elba Express Pipeline

The pipeline route also was reviewed on the USGS Seismic Hazard Maps for “percent g” values 

and the probability of exceedance in a 50-year period. For pipeline route there is a 10 percent 

probability of a 5-6 percent g exceedance in 50 years, and a 2 percent probability of a 16-20 

percent g exceedance in 50 years (USGS, 2002b). Therefore, the potential seismic hazard to the 

pipeline facilities is considered low. 

Soil Liquefaction 

Soil liquefaction is a process whereby the strength and stiffness of a soil is reduced by 

earthquake shaking or other rapid loading. The result is a transformation of soil to a liquid state. 

Typically, three general factors are necessary for liquefaction to occur and can be used as a 

liquefaction hazard screening. They are (USGS, 2006): 

• Young (Pleistocene) sands and silts with very low or no clay, naturally deposited (beach, 

river deposits, wind blown deposits), or man-made land (hydraulic fill, backfill). 

• Soils must be saturated. The space between individual particles is completely filled 

with water. This water exerts a pressure on the soil particles that influences how tightly 

the particles themselves are pressed together. This is most commonly observed near 

bodies of water such as rivers, lakes, bays, oceans, and wetlands. 

• Severe shaking. This is most commonly caused by a large earthquake. Prior to an 

earthquake, the water pressure is relatively low. However, earthquake shaking can cause 

the water pressure to increase to the point where the soil particles can readily move with 

respect to each other. This factor is limited by the distance from the earthquake’s 

epicenter. That is, liquefaction potential decreases as distance from the epicenter of an 

earthquake increases. 

Terminal Expansion

Southern LNG conducted a site-specific hazard analysis for liquefaction potential for the 

Terminal Expansion facilities. Ground motion values obtained from the Seismic Hazard Study 

completed for the Terminal Expansion site and the geotechnical data (standard penetration tests, 

cone penetration tests, and shear wave velocity measurements) gathered during the site 

investigation were used for the analysis. Analysis of the results indicates localized zones within 

the sand layer located 30 to 50 feet below ground surface have the potential for liquefaction at a 

5,000 year safe shutdown earthquake and no potential during an operating basis earthquake 

(WPC, 2006a). 
 4-6 4.0 –Environmental Impact Analysis 

A liquefaction impact analysis was subsequently completed for the sand layer and an 

unacceptable level of deformation and stability concern was not identified (WPC, 2006a). 

Based on the site-specific liquefaction impact analysis, age of the locally potentially liquefiable 

sands, seismic setting, and prove-out design mitigation measures, we believe the risk of a 

liquefaction event impacting the Terminal Expansion facilities is low. 

Elba Express Pipeline

Areas along the proposed pipeline contain saturated, non-cohesive soils of Pleistocene age, and 

there is a 10 percent probability of a 5-6 percent g seismic event exceedance in 50 years (USGS, 

2002b). This is considered a relatively low seismic hazard area, and below the 10 percent g 

threshold criteria commonly used for liquefaction hazard screening purposes. As a result, the 

potential for a liquefaction event at the pipeline facilities is considered low. 

Subsidence 

Ground subsidence in the southeastern United States is typically associated with natural geologic 

processes, compaction, and solution; and, man-made processes such as subsurface mining and 

removal of groundwater from aquifer systems. 

Terminal Expansion

Factors resulting in regional subsidence are not present on Elba Island. Minor subsidence 

associated with the placement of dredge spoils was noted (WPC, 2006a) and historically, the 

Savannah area was known for minor subsidence due to groundwater withdrawals. Georgia has a 

program in-place to actively control groundwater withdrawals in the underlying aquifer systems. 

Accordingly, regional subsidence is not likely a geologic hazard for the Terminal Expansion 

facilities. However, significant local subsidence has occurred at the site as evidenced by the 

elevations of certain on-site foundations originally constructed at grade. Since all major 

components of the facility are supported on pile foundations the localized subsidence has not 

been a significant safety concern. 

Southern LNG’s analysis of existing subsurface soil conditions indicates that the soft sediments 

located beneath the proposed LNG tanks is highly compressible, has low undrained strength, and 

would not be capable of supporting the tanks using shallow foundation systems. Therefore, to 

support the tanks and prevent localized settlement, Southern LNG proposes for each tank 

foundation to drive up to 1,941 steel or pre-stressed concrete piles into the sediment to a depth of 

about 74 feet, and for all building foundations, equipment, and pipe racks to a depth of about 45 

feet. This would minimize the potential for settlement of the facilities due to the presence of soft 

natural and fill soils found at the site, typically 26 to 56 feet below the ground surface. 

Elba Express Pipeline

Areas prone to natural subsidence processes were not identified along the pipeline route (AMEC, 

2001; UG-CVIG, 2006; USGS, 1990). Georgia and South Carolina have programs in-place to 
 4-7 4.0 –Environmental Impact Analysis 

actively control groundwater withdrawals in the underlying aquifer systems. No subsurface 

mining was identified along the proposed pipeline route (GMA, 2006; USGS, 2004). The 

potential for known geologic and man-made conditions contributing to subsidence along the 

pipeline route were not identified at levels that may be considered an engineering concern for the 

pipeline. As a result, the potential subsidence hazard to the pipeline is considered low. 

Flooding/Storm Damage 

A flood is a high stream or river level that overflows the natural or man-made bank. A 100-year 

flood is a statistical average of historic flooding events on a stream or river. A 100-year flood 

does not occur on average every 100 years. Rather, it is the probability that a big flood would 

occur in a given year. A 100-year flood can occur in successive years. Many streams and rivers 

have enough historical data that scientists can provide a flood elevation for a given location. 

This helps with the planning and construction of infrastructure and buildings. 

Another type of flood is a flash flood. A flash flood can develop quickly without any signs of 

rain. A severe, slow moving thunderstorm can provide heavy, localized rain contributing to this 

effect. A flash flood can carry large volumes of water and debris such as rocks and mud. 

Storm surge is a coastal phenomenon associated with low pressure weather systems, typically 

intense hurricanes and winter storms. The surge of ocean water in-land above the high tide mark 

is a result of high winds pushing on the ocean surface causing the water to “pile up” higher than 

ordinary sea-level. Low pressure at the center of the storm contributes to this effect, as does 

bathymetry (i.e., narrow bays, gentle seaward slopes). The storm surge effect is enhanced if it 

occurs at the time of high tide (USAFR, 2006). 

Terminal Expansion

The Terminal Expansion site is subject to flooding from hurricanes, tropical storms, and other 

weather systems. Downstream flooding from the Savannah River and ocean storm surge are 

possible at Elba Island. The Terminal Expansion site has not been struck by a Category 3-5 

hurricane in the past century; however, a severe hurricane and an associated storm surge is 

possible (CEMA, 2006). 

A review of the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map 

for the Terminal location indicates Elba Island is within the 100-year flood zone, with a coastal 

flood hazard (including storm surge) and velocity hazard with wave action. The base flood 

elevation, still water and wave action, is 18 feet National Geodetic Vertical Datum (NGVD) of 

1929. 

ATM completed a site specific storm surge analysis to address storm surge levels during various 

return periods. The study evaluated mean and high tide events. Additionally, a wind wave 

analysis was completed for the site to determine the potential extreme wave heights under 

tropical storm conditions. 
 4-8 4.0 –Environmental Impact Analysis 

During a 100-year flood event with wave action, the shoreline would flood to 3.3 feet above 

existing grade. Over-land flood water is estimated at 2.6 feet (ATM, 2006). 

Outside of the MSE walls for the new LNG storage tanks, waves would break at the MSE wall 

and run up the slope (wave runup). ATM used modeling software to estimate the maximum 

wave runup, calculated at 7 vertical feet, which is equivalent to an elevation of 21.3 feet NGVD. 

The perimeter MSE walls are proposed at 26 feet NGVD, which are not anticipated to be 

overtopped during a 100-year flood event. Waves breaking on the perimeter MSE walls would 

cause minor, repairable, erosion (ATM, 2006). 

Because hurricane storm surge and wave action could potentially cause damage to the stone 

armored shoreline at the recessed berth, Southern LNG would armor this area with vertical 

sheetpile to prevent significant erosion. 

Our analysis indicates that issues of concern and potential hazards associated with surficial fill, 

soft sediments, and soil liquefaction underlying areas that would be developed by Southern LNG 

for the Terminal Expansion facilities would be adequately addressed with its engineering design 

and our recommendations. Additionally, due to the relatively shallow construction depth of the 

pipeline, we conclude that the pipeline also would not have an affect on deep sediment loading 

or stability. 

Localized Scour and Shoreline Erosion 

Terminal Expansion

Proposed modifications in the recessed berthing slip include dredging of approximately 72,000 

cubic yards of sediment, installation of 900 linear feet of vertical sheetpiling, and installation of 

four mooring piles. The recessed berthing slip currently experiences relatively low currents and 

sediment deposition (ATM, 2006). Southern LNG’s proposed expansion of this slip would 

create a slight increase in sediment dredging maintenance. No modifications are proposed 

outside of the protected, recessed berthing slip. No impacts to wave and current patterns in the 

Savannah River are anticipated and any potential shoreline erosion from increase vessel traffic 

would be negligible. 

Waterway for LNG Marine Traffic

During normal operation, the increase in vessel traffic due to the terminal expansion would have 

no significant adverse impact on geologic resources within the Zones of Concern (described in 

section 4.12.4.3). LNG marine traffic, including LNG vessels and associated escort vessels, 

would be far from shore from the majority of the route and operating at speeds of 9-11 knots. 

Because vessel traffic would be operating at low speeds, wakes would not significantly increase 

the potential for shoreline erosion along the transit waterway. Impacts associated with shoreline 

erosion are further addressed in section 4.3.3. Because LNG is less dense than water and would 

vaporize upon contact with water and air, there would be no significant adverse impacts to 

geologic resources along the transit route from intentional or accidental, ignited or unignited 

LNG spills. 
 4-9 4.0 –Environmental Impact Analysis 

4.1.4 Paleontology 

Construction of the proposed facilities would primarily disturb Holocene deposits, which 

typically do not contain Paleozoic age fossils. The dredged material making up much of the 

structure of Elba Island is known to contain fossil fragments. However these fossils are of little 

value for providing significant new paleontological data. Any significant fossil finds 

encountered during construction would be reported to the GDNR in order to solicit suggestions 

for proper recovery and/or preservation. If paleontological resources are discovered during 

construction on land owned by or managed by the USACE, the local USACE land manager 

would be contacted in order to solicit mitigation measures recommended to ensure protection of 

such resources. 

4.2 SOILS 

Soils characteristics that can affect construction or increase the potential for soil impacts include: 

drainage class, hydric soils, presence of shallow bedrock or coarse fragments, compaction 

potential, erosion potential, revegetation potential, prime farmland and soil contamination. 

4.2.1 Soil Limitations 

We evaluated the potential soil impacts associated with construction and operation of the 

proposed Terminal Expansion facilities, including the waterway for marine traffic to the 

terminal, and Elba Express Pipeline facilities. 

Terminal Expansion

The U.S. Department of Agriculture (USDA), Natural Resources Conservation Service (NRCS) 

has identified soils on Elba Island as made land (Mae) and tidal marsh, salty (Tml). Most areas 

where made land soils occur are formerly marshland, where dredged materials were deposited. 

Dredged materials are a byproduct of dredging activities in coastal streams along the Savannah 

River shipping channel and harbor. Made land soils consist of course sands to clays, sometimes 

with stratified layers of varying thickness (USDA, 1974). All of the soils to be impacted by the 

Terminal Expansion facilities, including the expansion of the existing slip, would be made land 

soils. 

Tidal marsh, salty soil types are tidally influenced and occupied by salt-tolerant vegetation found 

primarily along Elba Island’s coast. Surface layers of this soil type contain many pithy, fibrous 

roots with high organic matter content. Soil series associated with this soil type are Capers, 

Kershaw, and Osier. These soil series are highly variable, but the Capers series most likely 

represents the soils within the tidal marsh areas of Elba Island. Generally, this series is very 

poorly drained and is dominated by salt-tolerant grasses. No tidal marsh areas would be 

impacted by the Terminal Expansion Project. 
 4-10 4.0 –Environmental Impact Analysis 

Elba Express Pipeline

The soils crossed by the pipeline and associated aboveground facilities were analyzed using the 

State Soil Geographic (STATSGO) database. The STATSGO database was developed by the 

NRCS for use in regional, river basin, state, multi-state, and multi-county resource planning. 

STATSGO spatial data are compiled by combining geologically and topographically related soils 

series found in county soil surveys into larger units called Map Unit Identifiers (MUIDs). The 

STATSGO database provides information on soil characteristics that may be used to estimate the 

vulnerability of specific soils to development impacts. 

Table 4.2.1-1 provides a summary of the soil limitations that could be encountered by the 

proposed Elba Express Pipeline route, while table 4.2.1-2 provides a summary of the soil 

limitations associated with the proposed aboveground facilities. 

TABLE 4.2.1-1 

Summary of Soils Limitations – Elba Express Pipeline a/ 

County 

Shallow Depth to 

Bedrock or Coarse 

Fragments 

High 

Compaction 

Potential 

High Erosion 

Potential 

Poor 

Revegetation 

Potential 

Prime Farmland 

Soil 

Chatham 

(4.7 miles) 

0 miles 

0 acres 

0 miles 

0 acres 

0 miles 

0 acres 

0 miles 

0 acres 

0.08 miles 

1.33 acres 

Effingham 

(27.1 miles) 

0 miles 

0 acres 

0.69 miles 

10.45 acres 

0 miles 

0 acres 

0.73 miles 

11.06 acres 

2.48 miles 

37.58 acres 

Screven 

(25.7 miles) 

0 miles 

0 acres 

0 miles 

0 acres 

0.03 miles 

0.45 acres 

15.45 miles 

234.09 acres 

15.86 miles 

240.30 acres 

Jenkins 

(13.3 miles) 

0 miles 

0 acres 

0 miles 

0 acres 

0 miles 

0 acres 

5.89 miles 

89.24 acres 

4.37 miles 

66.21 acres 

Burke 

(23.0 miles) 

0 miles 

0 acres 

0 miles 

0 acres 

0 miles 

0 acres 

15.03 miles 

227.73 acres 

16.65 miles 

252.37 acres 

Jefferson 

(13.9 miles) 

0 miles 

0 acres 

0 miles 

0 acres 

0 miles 

0 acres 

7.65 miles 

115.91 acres 

9.19 miles 

139.24 acres 

Glascock 

(4.9 miles) 

0 miles 

0 acres 

0 miles 

0 acres 

0 miles 

0 acres 

3.53 miles 

53.48 miles 

4.02 miles 

60.91 acres 

Warren 

(7.4 miles) 

0.05 miles 

0.67 acres 

0 miles 

0 acres 

1.06 miles 

14.52 acres 

4.21 miles 

59.50 acres 

2.46 miles 

34.85 acres 

McDuffie 

(15.0 miles) 

0.28 miles 

3.73 acres 

0 miles 

0 acres 

5.11 miles 

68.13 acres 

2.25 miles 

30.00 acres 

3.81 miles 

50.80 acres 

Wilkes 

(26.1 miles) 

0.15 miles 

2.00 acres 

0 miles 

0 acres 

7.53 miles 

100.40 acres 

0.21 miles 

2.80 acres 

8.19 miles 

109.20 acres 

Elbert 

(21.3 miles) 

1.06 miles 

14.13 acres 

0 miles 

0 acres 

4.26 miles 

56.80 acres 

1.36 miles 

18.13 acres 

4.00 miles 

53.33 acres 

Hart 

(5.6 miles) 

0.76 miles 

10.13 acres 

0 miles 

0 acres 

2.09 miles 

27.87 acres 

0.08 miles 

1.07 acres 

0.77 miles 

10.27 acres 

Anderson 

(0.7 miles) 

0.04 miles 

0.53 acres 

0 miles 

0 acres 

0.39 miles 

5.20 acres 

0 miles 

0 acres 

0.10 miles 

1.33 acres 

Overall Project 

Total 

2.34 miles 

31.20 acres 

0.69 miles 

10.45 acres 

20.47 miles 

273.37 acres 

56.39 miles 

843.01 acres 

71.98 miles 

1,057.52 acres 
 4-11 4.0 –Environmental Impact Analysis 

TABLE 4.2.1-1 

Summary of Soils Limitations – Elba Express Pipeline a/ 

County 

Shallow Depth to 

Bedrock or Coarse 

Fragments 

High 

Compaction 

Potential 

High Erosion 

Potential 

Poor 

Revegetation 

Potential 

Prime Farmland 

Soil 

(187.9 miles) _____________________________________________________________________ 

a/ Data based on 125 foot ROW from MP 0.0-114.8 and 110 foot ROW from MP 114.8 to about MP 187.9. 

TABLE 4.2.1-2 

Summary of Soils Limitations – Elba Express Aboveground Facilities 

Proposed 

Facility 

Soil 

Mapping 

Unit 

Drainage 

Class 

Hydric 

Soil 

Shallow 

Depth to 

Bedrock or 

Coarse 

Fragments 

High 

Compaction 

Potential 

High 

Erosion 

Potential 

Poor 

Revegetation 

Potential 

Prime 

Farmland 

Soil 

Elba 

Compressor 

Station 

GA054 Well No No No Yes Yes No 

Port Wentworth 

Meter Station GA073 Poorly Yes No No Yes No No 

McIntosh Meter 

Station and 

EEC/Cypress 

Meter Station 

GA068 Poorly Yes No No Yes No No 

Effingham 

Meter Station GA068 Poorly Yes No No Yes No No 

Wrens Meter 

Station GA046 Well No No No Yes Yes Yes 

Transco Zone 4 

Meter Station GA026 Well No Yes No Yes No No 

Transco Mixing 

Station SA006 Well No Yes No Yes No No 

Plant Rainey 

Meter Station SA006 Well No Yes No Yes No No 

Transco Zone 5 

Meter Station SA006 Well No Yes No Yes No No 

4.2.3 Erosion Control Plans 

Terminal Expansion

Southern LNG would adopt FERC’s Plan during the construction and operation of the proposed 

Terminal Expansion facilities. Southern LNG’s Plan includes provisions for erosion control, 

revegetation and managing of saturated soils. We believe that adherence to its Plan would 

minimize erosion during construction and operation. 
 4-12 4.0 –Environmental Impact Analysis 

Elba Express Pipeline

EEC would comply with their project-specific Upland Erosion Control, Revegetation, and 

Maintenance Plan during the construction and operation of the proposed Elba Express Pipeline 

facilities. EEC’s Plan includes provisions for erosion control, revegetation, and special 

construction techniques for saturated soils and agricultural areas. We have evaluated the EEC 

Plan and believe adherence to their plan would minimize erosion during construction and 

operation. 

4.2.3 Soil Resources 

Prime Farmland Soils 

Prime farmland is defined as “land that is best suited to food, feed, fiber and oilseed crops” 

(USDA, 2005). This designation includes cultivated land, pasture, woodland, or other lands that 

are either used for food or fiber crops or are available for these uses. Prime farmland typically 

contains few or no rocks, is permeable to water and air, is not excessively erodible or saturated 

with water for long periods, and is not subject to frequent, prolonged flooding during the 

growing season. Soils that do not meet the above criteria may be considered prime farmland if 

the limiting factor is mitigated (e.g., artificial drainage). 

Terminal Expansion

Prime farmland soils are not located on the proposed Terminal Expansion site; therefore, no 

impacts to prime farmland soils would result from the proposed expansion. 

Elba Express Pipeline

The pipeline would impact approximately 1,057.52 acres of prime farmland soils, which 

comprises 38 percent of the total route. The Effingham Meter Station at MP 10.3 would disturb 

approximately 3.03 acres of prime farmland soils during construction and 0.89 acre would be 

permanently occupied by the station during operation. EEC would minimize impacts on prime 

farmland by constructing the pipeline in accordance with the EEC Plan (see appendix E). These 

mitigation measures would include restoration of agricultural drainage systems, topsoil 

segregation, decompaction, and removal of rocks greater than four inches in diameter from the 

soil surface. We believe EEC’s implementation of their Plan during construction and operation 

would minimize potential impacts on prime farmland soils and restore the areas to 

preconstruction conditions. 

Hydric Soils 

Hydric soils are prone to compaction and rutting due to extended periods of saturation and high 

clay content. If construction of the pipeline occurs when these soils are saturated, compaction 

and rutting could occur. Furthermore, high groundwater levels that accompany hydric soils 

could create a buoyancy hazard for the pipeline. Special construction techniques such as 
 4-13 4.0 –Environmental Impact Analysis 

concrete coating and other weighting methods would be used to overcome buoyancy hazards 

during operation of the pipeline. 

Terminal Expansion

Elba Island does contain hydric soils; however, none would be impacted by the Terminal 

Expansion facilities. 

Elba Express Pipeline

The pipeline would cross hydric soils. Hydric soils are prone to compaction and rutting due to 

extended periods of saturation and high clay content. If construction of the pipeline occurs when 

these soils are saturated, compaction and rutting could occur. Furthermore, high groundwater 

levels that accompany hydric soils could create a buoyancy hazard for the pipeline. Special 

construction techniques such as concrete coating and other weighting methods would be used to 

overcome buoyancy hazards during operation of the pipeline. During construction of the 

proposed pipeline, EEC would comply with its Procedures, which include provisions for wetland 

crossings and special construction techniques in areas of saturated soils. We believe that EEC’s 

implementation of their Procedures during construction would minimize impacts to hydric soils. 

Compaction Potential 

Soil compaction modifies the structure and reduces the porosity and moisture-holding capacity of 

the soil. The degree of compaction is dependent on moisture content and soil texture. Fine 

textured soils with poor internal drainage and high shrink-swell potential are the most susceptible 

to compaction. Construction equipment traveling over wet soils could disrupt soil structure, 

reduce pore space, increase runoff potential, and cause rutting. Compaction and rutting impacts 

would be more likely to occur when soils are moist or saturated. 

Terminal Expansion

Based on the historic dredge and fill operations used to create most of the site, the soils at the 

Terminal site are considered to be compacted. During most dredge and fill operations, fill 

material is excavated, placed onto the land surface, and then compacted using heavy machinery. 

These operations result in moderately to highly compacted soils intended to facilitate 

construction at the elevated land surface. Some soils within the LNG terminal site footprint of 

the project facilities would be compacted permanently to form foundations for the project 

facilities. 

Elba Express Pipeline

Due to the presence of sandy clay loam, or finer soils, with poor drainage characteristics along 

the pipeline, several areas have the potential to experience some level of soil compaction. The 

pipeline would impact approximately 10.45 acres of soil that may be susceptible to soil 

compaction. EEC would minimize unavoidable soil compaction and rutting by adhering to 

measures in their Plan, which includes testing topsoil and subsoil for compaction at regular 
 4-14 4.0 –Environmental Impact Analysis 

intervals in agricultural areas. After construction, any severely compacted agricultural areas 

would be tilled with a paraplow or other deep tillage tool, or planting and plowing-in a green 

manure crop may be used to improve soil bulk density. With implementation of the compaction 

minimization measures contained in EEC’s Plan, we believe that impacts due to soil compaction 

would be minimized. 

Erosion 

Erosion is a continuing natural process that can be accelerated by human disturbance. Factors 

that influence the degree of erosion include soil texture, structure, length and percent of the 

slope, vegetative cover, and rainfall or wind intensity. Soils most susceptible to water erosion 

are typified by bare or sparse vegetative cover, non-cohesive soil particles with low infiltration 

rates, and moderate to steep slopes. Wind erosion processes are less affected by slope angles. 

Clearing, grading, and equipment movement could accelerate the erosion process and, without 

adequate protection, result in discharge of sediment into waterbodies and wetlands. Soil loss due 

to erosion could also reduce soil fertility and impair vegetation. 

Terminal Expansion

Because the existing Terminal site is essentially flat and currently a combination of maintained 

grassy areas and graveled or asphalted areas, the potential for erosion of soils and discharge of 

sediments off the site would be relatively low during construction. We believe Southern LNG’s 

implementation of the FERC Plan during construction and restoration would avoid or minimize 

erosion. 

Elba Express Pipeline

The pipeline would disturb approximately 273.37 acres of soil susceptible to erosion. For the 

pipeline, EEC would utilize erosion control methods such as slope breakers, sediment barriers 

such as silt fencing and hay bales, mulch, erosion control fabric, and revegetate within 20 days of 

backfilling the trench in accordance with the EEC Plan. We believe that implementation of these 

measures during construction and restoration would minimize overall soil erosion. 

Revegetation 

Successful restoration and revegetation in areas that are not permanently developed is important 

to maintain ecosystem productivity and to protect the underlying soils from potential damage, 

such as erosion. 

Terminal Expansion

Southern LNG would implement the requirements of the FERC Plan for revegetation of 

disturbed areas following construction, including seeding disturbed areas with native vegetation 

as recommended by soil conservation authorities and monitoring disturbed areas for up to three 

years to ensure successful revegetation. We believe that if upland revegetation is conducted in 
 4-15 4.0 –Environmental Impact Analysis 

accordance with these measures, areas disturbed by construction would be successfully 

revegetated to preconstruction conditions. 

Elba Express Pipeline

The pipeline would cross approximately 843.01 acres of soil with low revegetation potential. 

Table 4.2.1-1 identifies areas along the pipeline route where revegetation potential may be low 

due to soils with coarse surface textures and high drainage capacity. EEC would revegetate the 

non-cultivated portions of the construction areas in accordance with the mitigation measures in 

the EEC Plan and any specific landowner requests. In addition, EEC would use seed mix and 

fertilizer/lime applications described in EEC’s Plan in conjunction with NRCS critical area 

planting standards for Georgia and South Carolina. We believe that if upland revegetation is 

conducted in accordance with these measures, areas disturbed by construction would be 

successfully revegetated to preconstruction conditions. 

Soil Contamination 

Contamination from spills or leaks of fuels, lubricants, and coolant from construction equipment 

could adversely affect soils. The contamination effects would typically be minor because of the 

low frequency and volumes of spills and leaks. Southern LNG and EEC have developed a joint 

project-wide Spill Plan (see appendix D). This plan identifies cleanup procedures to be 

implemented in the event of soil contamination from spills or leaks of fuel, lubricants, coolants, 

or solvents. We have evaluated this plan and believe that the implementation of the project-wide 

Spill Plan would avoid or minimize soil contamination during construction and operation of the 

Project. 

Terminal Expansion

The existing Terminal site has been in operation for more than 25 years and has been subject to 

frequent internal environmental audits. A soil chemistry evaluation was conducted on the 

Terminal site in 2002 (ATM, 2002). This study indicated the material that was sampled had 

concentrations of elevated metals and organics consistent with the dredge material that underlies 

the Terminal. The COE Savannah District, Planning Division, Environmental Branch reviewed 

the 2002 study report and found no contaminant related issues with regard to the dredged 

material for the marine slip or sediments proposed to be dredged and placed in the Elba Island 

CDF. 

The proposed excavation of 72,000 cubic yards of sediment to modify the marine slip involves 

material in the same area and disposal in the same CDF, as approved in 2002. Dredging of the 

existing berthing slip and turning basin would result in impacts similar to current COE activities 

required to maintain the Savannah Harbor. Dredging would stir up sediment and temporarily 

degrade the water quality in the immediate area of the berthing slip. Modifications to the 

existing berthing slip would be completed under the guidelines established by Southern LNG and 

the COE. The COE indicated that Southern LNG would be able to perform this work by 

modifying its existing 404/Section 10 permit. Therefore, we conclude that excavation of 
 4-16 4.0 –Environmental Impact Analysis 

sediment in the marine slip would not result in the temporary suspension of contaminated 

sediment. Water quality is discussed further in section 4.3.3 of this EIS.

Elba Express Pipeline

EEC conducted a regulatory database search to determine if contaminated soils associated with 

hazardous wastes sites or other solid waste sites occur within 0.25 mile of the pipeline corridor. 

No landfills, hazardous waste sites, quarries, or mines were identified within 0.25 mile of the 

proposed pipeline (ESRI, 2006 and EPA, 2006a). 

Waterway for LNG Marine Traffic

On the open seas, no significant impact on soil resources would result from either an increase in 

routine LNG vessel and escort vessel traffic, the use of larger LNG vessels, or a marine spill 

(either unignited or ignited) of LNG. Nor would a significant impact on soil resources result 

from an increase in routine operations within the onshore portion of the Savannah River channel 

(from the eastern shoreline of Tybee Island westward to the Elba Island Terminal). The LNG 

vessel traffic associated with the Terminal Expansion would travel at speeds of 9 to 11 knots 

along the Savannah River transit route. Any wave induced shoreline erosion resulting from the 

increased LNG vessel traffic along the waterway at these slow speeds would be less than 

significant. Therefore, the following discussion focuses on potential impacts associated with 

non-routine incidents occurring within the onshore portion of the channel. 

 

Soils within the Zones of Concern (described in section 4.12.4.3) along the Savannah River 

vessel transit route are consistent with soils present at the Terminal and along the pipeline route. 

If an unignited marine spill of LNG were to result in a LNG pool that contacted soils along the 

Savannah River, shore side soils would be temporarily affected by the extremely cold 

temperatures. These cold temperature effects would be temporary as the LNG would vaporize 

quickly and disperse in the atmosphere; therefore, no significant impact on shoreline soils would 

be anticipated. If not ignited, no impacts on soils would be expected outside of Zone 1 from a 

marine spill of LNG. 

If a pool fire were to occur in association with a marine LNG spill, soil surfaces in Zones 1 and 2 

could be impacted from radiant heat (see figure 4.12-1). The increased temperatures would 

briefly raise soil surface temperatures; damage or destroy vegetation exposing soils to increased 

erosion potential (described in section 4.5.1); and contribute to nutrient loss, a short-term 

suspension of biological activity, and evaporation of available water from the surface of the soil. 

No significant or long-term soil impacts would result. The impacts from a LNG marine spill and 

an associated pool fire within Zone 2 would be expected to be less than those in Zone 1. No 

impacts would be expected to occur on soils within Zone 3. However, the maximum flammable 

range for a vapor cloud could extend to the outer limits of Zone 3. If the vapor cloud were to 

come in contact with an ignition source, the resulting fire could burn back to the spill and 

temporarily impact any soils it came in contact with in the Zones of Concern. Because of the 

extensive operational experience of LNG shipping, the structural LNG vessel design, and the 

navigational safety and security controls further described in the section 4.12, the likelihood of 
 4-17 4.0 –Environmental Impact Analysis 

the above marine LNG spill scenarios occurring are extremely remote and therefore are highly 

unlikely to impact soil resources.

4.3 WATER RESOURCES 

4.3.1 Groundwater 

Terminal Expansion

Existing Groundwater Resources 

The proposed Terminal Expansion site is located in the Atlantic Coastal Plain Physiographic 

Province and is underlain by the Floridian Aquifer and Southeastern Coastal Plain Aquifer. 

These aquifers are used extensively for agricultural, commercial, industrial and public/domestic 

water supplies. 

The Floridian Aquifer (Tertiary limestone aquifer) consists of a thick sequence of carbonate rock 

(limestone and dolomite) of Tertiary age and is the most productive aquifer in the region. The 

Floridian Aquifer underlies an area of about 100,000 square miles in southern Alabama, 

southeastern Georgia, southern South Carolina, and all of Florida. Within the proposed Terminal 

Expansion site, the Floridian Aquifer is thought to be approximately 700 feet thick. It is widely 

used as a public water supply and supports several large municipalities, including Savannah, 

Georgia (USGS, 1990). In the vicinity of the Terminal Expansion site, the Floridian Aquifer 

overlies the Southeastern Coastal Plain Aquifer but the lack of a confining unit between the two 

aquifers results in a free flow of groundwater in many areas. 

The Southeastern Coastal Plain Aquifer underlies an area of approximately 90,000 square miles 

in the coastal plains of Alabama, Georgia, South Carolina and northern Florida. The proposed 

Terminal Expansion site is underlain by the Pearl River, Chattahoochee River, and Black 

Warrior River regional aquifers. The Pearl River Aquifer is predominately a thick sequence of 

sand with minor sandstone, gravel, and limestone beds extending over coastal Alabama, Georgia, 

and South Carolina. The Chattahoochee River Aquifer is isolated from the Pearl River Aquifer 

by the Chattahoochee River confining unit and consists mostly of sand beds with clay lenses and 

local deposits of glauconitic sand and limestone ranging in age from later Cretaceous to late 

Paleocene. The Black Warrior River Aquifer is isolated from the Chattahoochee River Aquifer 

by the Black Warrior River confining unit and consists of Upper Cretaceous sands and clays that 

extend from North Carolina to southwestern Alabama. The Black Warrior River Aquifer is 

absent in a wide band adjacent to the inner coastal plain margin of South Carolina and eastern 

Georgia, including portions of the proposed Terminal Expansion site. 

The Terminal Expansion site is also underlain by a shallow, surficial aquifer within the Georgia 

Coastal Plain which consists mainly of beds of unconsolidated sand, shelly sand, and shell 

(coquina) materials less than 100 feet thick. These materials are continental and/or marine 

deposits from the Cretaceous to Holocene ages. Complex layering of free and/or coarse sand, 

sandy shell, shell, and clay are typical of the system as continental and marine influences 

fluctuated over time. Groundwater in this surficial aquifer is typically unconfined, but confined 
 4-18 4.0 –Environmental Impact Analysis 

or semi-confined conditions may occur locally due to the presence of impermeable or semiimpermeable clay beds or lenses. Water quality and yield within the shallow aquifer are 

extremely variable. Water enters the surficial aquifer as precipitation, quickly moving along 

short flowpaths, and is often discharged quickly as base flow to surface waterbodies. In addition, 

a large percentage of the water is lost through evapotranspiration from the forests that occupy 

large portions of the Georgia Coastal Plain. Water that is not lost to evapotranspiration or 

discharged to surface waterbodies infiltrates to the Floridian Aquifer. 

Because recharge to the shallow, surficial aquifer is via local precipitation, water levels tend to 

fluctuate seasonally. Despite fluctuations in water level, water quality, and yield, this aquifer 

represents a valuable resource in many areas providing for domestic water supplies (e.g., water 

used for indoor and outdoor household purposes such as drinking, food preparation, bathing, 

laundry, and gardening). Local yields, occurring within highly permeable deposits, may exceed 

500 gallons per minute (gpm) allowing support of higher demand uses. 

The U.S. Environmental Protection Agency (EPA) defines a sole- or principal-source aquifer as 

one that supplies at least 50 percent of the drinking water consumed in the area overlying the 

aquifer. These areas can have no alternative drinking water source(s) that could physically, 

legally, and economically supply all those who depend upon the aquifer for drinking water. 

None of the aquifers within the Terminal Expansion site are designated as sole-source aquifers. 

Groundwater Construction and Operation Impacts 

No significant impacts are expected to occur to groundwater resources from construction and 

operation of the proposed Terminal Expansion. Potential impacts to groundwater would be 

avoided or minimized through the use of standard and specialized construction techniques, and 

implementation of Southern LNG’s Plan, Procedures, and the project-wide Spill Plan. 

The average depth to groundwater within the Terminal Expansion site is between 70 and 100 

feet. Pile driving associated with construction of the mooring dolphins would occur to a depth of 

74 feet, potentially intruding into the groundwater table. A potential impact associated with 

driven pilings is the contamination of aquifer layers through seepage from one layer to another. 

Keeping the pilings within one layer of the aquifer system and not crossing multiple aquifer 

layers minimizes the potential for cross-contamination. Because the piles would be confined to 

one layer of the aquifer system, we feel pile driving impacts, if any, to groundwater would be 

minimal. 

Our February 2003 EA for the Elba Island Expansion Project (Elba II Project) in Docket Nos. 

CP02-379-000 and CP02-380-000, and the COE’s January 23, 2003 Case Document and EA for 

the Elba II Project, concluded that dredging the berthing slip to 42 feet below MLW for the Elba 

II Project would not impact the Floridian Aquifer. About 72,000 cubic yards of material would 

be dredged for the proposed Elba III Project, as opposed to the 3.3 million cubic yards that was 

dredged for the Elba II Project. The dredging proposed for the Elba III Project would expand the 

existing berthing slip by removing a sloped area at the toe of slip, but would not increase the 

depth of the berthing slip as was proposed for the Elba II Project. Therefore, the Terminal 
 4-19 4.0 –Environmental Impact Analysis 

Expansion facilities would not pose any increased impact to the Floridian Aquifer, or other 

aquifers, underlying the existing terminal site. 

Southern LNG would require about 300,000 gallons of fresh water to wash down the interior of 

each proposed LNG storage tank. The source of the freshwater would either be from the existing 

water system on Elba Island, or from sources trucked to Elba Island. We believe, if groundwater 

is used to wash down the interior of the LNG storage tanks, the one time groundwater 

withdrawals would not lower or otherwise affect the water table. 

The greatest potential for impacts on groundwater resources would be an accidental spill, leak, or 

other releases of hazardous substances. Subsurface conditions at the Terminal Expansion site are 

characterized by alluvial deposits consisting mostly of stiff, to very stiff clays, and any small 

accidental spills or leaks or other releases would not present an immediate threat to significant 

aquifers in the area if recovered in a timely manner. 

Southern LNG and EEC have developed a project-wide Spill Plan. The Spill Plan portion

addresses actions to be used to prevent spills and specifies actions that would be taken should 

any spills occur, including emergency notification procedures. On-site EIs would be responsible 

for ensuring that contractors implement and maintain spill control measures during construction. 

The Waste Management Plan portion provides information that would be used as a contractor’s 

guidance tool when generating wastes at a construction site and would assist the contractor in 

developing a waste management plan which would be submitted to Southern LNG before 

construction. The Container Management Policy portion would be applied to all containers used 

to accumulate: (1) non-hazardous, non-regulated waste, (2) hazardous waste, (3) hazardous toxic 

substances, and (4) store products of 1 gallon container size or larger. 

Southern LNG’s would minimize the potential for adverse effects to occur from a spill or release 

by implementing the project-wide Spill Plan. It contains provisions to ensure that the unforeseen 

impacts to groundwater resources are responded to and addressed properly. In addition, 

Southern LNG would adhere to federal and state water quality standards (e.g., CWA, Sections 

401, 402, and 404, and the Safe Drinking Water Act) to ensure that there would be no adverse 

effects on the quality of groundwater resources. We believe that implementing the measures 

detailed in the project-wide Spill Plan would minimize or eliminate the potential for adverse 

impacts on groundwater. 

 

Groundwater withdrawal volumes for the operation and maintenance of the proposed Terminal 

Expansion facilities would be similar to current volumes and would not add impacts to the water 

table. 

Waterway for LNG Marine Traffic

No significant impacts to groundwater would be expected from the terminal out to the territorial 

sea from the normal operations associated with an increase in LNG marine traffic and use of 

larger vessels for the proposed expansion of Elba Island facilities. Further, no significant 

impacts would be expected to occur to groundwater from an accidental release of LNG or an 
 4-20 4.0 –Environmental Impact Analysis 

associated fire within the Zones of Concern (described in section 4.12.4.3 of this EIS) along the 

LNG marine transit route. 

Public and Private Water Supplies Wells and Springs 

Southern LNG operates two potable water wells within the boundaries of the terminal. No 

public or municipal water supply wells, springs or domestic wells are within 150 feet of the 

proposed of the Terminal Expansion facilities. 

Elba Express Pipeline

Existing Groundwater Resources 

The proposed Elba Express Pipeline would cross the Coastal Plain, Blue Ridge, and Piedmont 

Physiographic Provinces of the southeastern United States and is underlain by a shallow, 

surficial aquifer, the Upper and Lower Brunswick Aquifers, and the Floridian Aquifer. None of 

the aquifers in the project area are EPA designated sole-source aquifers (EPA, 2006b). 

Within the Coastal Plain Physiographic Province, the shallow, surficial aquifer consists of 

intermixed layers of unconsolidated clays, silts, and sands that are typically under unconfined or 

semi-confined layers of silt and clay in coastal areas. Withdrawals from this aquifer are 

generally used for domestic (e.g., water used for indoor and outdoor household purposes as 

described above) and livestock supplies in rural area. It ranges in depth from 11 to 72 feet and 

yields 2 to 25 gpm. 

In southeast Georgia, the Upper and Lower Brunswick Aquifers underlie the shallow, surficial 

aquifer. The Brunswick aquifer system consists of discontinuous lens-shaped bodies of sand, 

generally 50 to 80 feet thick, comprised of Miocene deposits. These deposits are not a major 

source of groundwater along the Elba Express Pipeline route but are considered a supplemental 

supply to the Floridian Aquifer. The Upper and Lower Brunswick Aquifers range in depth from 

85 to 390 feet and yields between 10 and 30 gpm. 

The Floridian Aquifer (described above), ranges in depth from 40 to 900 feet and yields between 

1,000 to 5,000 gpm. The Floridian Aquifer is largely confined throughout the Elba Express 

Pipeline Project area. The Floridian Aquifer is the most productive aquifer in the region and 

extends under southern Alabama, southeastern Georgia, southern South Carolina, and all of 

Florida. 

Groundwater Construction and Operation Impacts 

Although proposed pipeline construction activities could affect groundwater resources, most 

potential impacts would be avoided or minimized by the use of standard and specialized 

construction techniques, and EEC adhering to its project specific Plan, Procedures, and the 

project-wide Spill Plan. Shallow aquifers could sustain minor impacts from changes in overland 

water flow and recharge caused by clearing and grading of the proposed ROW. Near-surface 

soil compaction caused by heavy construction vehicles could reduce the soil’s ability to absorb 
 4-21 4.0 –Environmental Impact Analysis 

water, which could increase surface runoff and the potential for ponding. In forested areas, water 

infiltration normally enhanced by vegetation would be reduced until vegetation is reestablished. 

These minor impacts would be temporary and would not significantly affect groundwater 

resources or quality. Upon completion of construction, EEC would restore the ground surface as 

closely as practicable to original contours, conduct decompaction, if necessary, and revegetate 

the ROW to ensure restoration of preconstruction overland flow and recharge patterns. 

Construction of the proposed pipeline would require trenching to a depth of about 7 feet below 

the ground surface. In areas where the water table is near the ground surface, trench excavation 

could intersect the water table, requiring trench dewatering. Trench dewatering may result in 

localized, minor changes to the water table, as well as to springs and wetland areas. Because 

pipeline construction at a given location would be completed within a short period of time, 

potential impacts from dewatering would be temporary and water table elevations would be 

quickly reestablished. At locations where the trench may be continually flooded and dewatering 

would not be feasible, the pipe would be floated into place using the push-pull method as 

described in section 2.6.3. 

Blasting would likely be required where bedrock is encountered along the construction ROW. 

Because no areas of potentially contaminated groundwater have been identified immediately 

adjacent to the proposed pipeline route, there is little potential for blasting to affect contaminated 

groundwater migration pathways. Further, because blast charges used would be the minimum 

required to excavate to a depth of about 7 feet below the ground surface, any impacts to 

groundwater flow would be minor and localized. 

Construction of the pipeline necessitates the use of heavy equipment and associated fuels, 

lubricants, and other potentially hazardous substances that, if spilled, could affect shallow 

groundwater and/or unconsolidated aquifers. Potential contamination due to accidental spills or 

leaks of hazardous materials associated with vehicle fueling, vehicle maintenance, and 

construction materials storage presents the greatest potential threat to groundwater resources. 

To ensure that potential impacts to groundwater resources are prevented and minimized to the 

extent practicable, and to avoid spills and leaks, Southern LNG and EEC have developed a 

project-wide Spill Plan and would implement its Procedures which include spill prevention and 

response guidelines. EEC’s preventative measures include instructions for construction 

personnel on spill prevention, spill response procedures, and spill response materials, plus 

guidance and protocols for refueling operations and regular inspection of containers and 

equipment for signs of deterioration. EEC’s EIs would be responsible for the approval of proper 

locations of equipment refueling and lubrication activities. We have reviewed Southern LNG 

and EEC’s project-wide Spill Plan and find that they adequately address the storage and transfer 

of hazardous materials and the response to be taken in the event of a spill. By following the 

project-wide Spill Plan, the potential impacts on groundwater due to spills or leaks would be 

minimized. 
 4-22 4.0 –Environmental Impact Analysis 

Public and Private Water Supplies Wells and Springs 

Public and private water supply wells were identified from existing databases and records 

maintained by respective state and water management districts, and surveys conducted by EEC. 

No public water supply wells or wellhead protection areas would be within 150 feet of the 

construction ROW. Should any previously unidentified wells or wellhead protection areas be 

identified, EEC has agreed to comply with mitigative measures recommended by the GDNR and 

Department of Health and/or Environmental Control (DHEC) to monitor and protect those 

resources. EEC, in consultation with the GDNR, is in the process of determining if the Elba 

Express Pipeline route would encroach on 1,000-foot buffers that have been established for four 

wellhead protection areas near the City of Tignall in Wilkes County, Georgia (about 0.5 mile 

west of MP 153.5). 

Sixty-seven private water supply wells have been identified within 150 feet of the construction 

ROW and workspace (listed in appendix G). EEC states that survey work has not been 

completed for the entire pipeline route and it will continue to investigate the presence of private 

wells during the remaining civil surveys. Therefore, there is potential for additional water wells 

or springs to occur within 150 feet of construction work areas. Based on the ongoing efforts by 

EEC to identify springs, seeps, and wells near the construction work areas, we recommend that 

prior to construction, EEC file with the Secretary the locations by MP of all springs, seeps, 

and wells identified within 150 feet of its construction ROW. 

In addition to further ensure that water supply wells/systems are adequately protected we 

recommend that EEC file a report within 30 days of placing the pipeline facilities in 

service, identifying all water supply wells/systems damaged by construction and how they 

were repaired. The report should include a discussion of any complaints concerning the 

well yield or quality and how each problem was resolved. 

Blasting in proximity to groundwater wells during excavation activities could cause temporary 

changes in water level and turbidity (Froedge, 1980). EEC would implement its Blasting 

Specification Plan and Procedures to minimize impacts on groundwater wells within 150 feet of 

construction work areas. EEC has committed to: 

• Monitor all wells within 150 feet of the construction work areas for water quality and 

flow before, during, and after construction. 

• Provide alternative sources of water or otherwise compensate the owner if construction 

activities temporarily impair well water. 

• Compensate the owner for damages or fund installation of a new well if permanent well 

damage is caused by construction. 

4.3.2 Floodplains 

According to the FEMA Flood Insurance Rate Maps (FEMA, 1987), the Terminal Expansion site 

falls within Zone VE, a 100-year flood hazard zone susceptible to coastal flooding. The 100-

year flood elevation for Elba Island is 18 feet above the NGVD of 1929. The Terminal 
 4-23 4.0 –Environmental Impact Analysis 

Expansion facilities would be designed to withstand storm forces so that factors such as flooding, 

water damage, and land erosion would have minimal affects on the operation and safety of the 

facilities. Southern LNG has incorporated certain design elements into its facilities to address 

potential flooding and storm damage at the terminal site (see sections 2.6.1 and 4.1.3). 

See section 4.12.2 for additional information regarding safety from hurricane events. 

No aboveground facilities for the proposed Elba Express Pipeline are within a 100-year 

floodplain. 

4.3.3 Surface Water 

Terminal Expansion

A number of artificial, intermittent drainage ditches occur on the site and are part of the existing 

stormwater management system which discharges water into the Main and South Channels of the 

Savannah River. The Terminal Expansion facilities would use the existing stormwater 

management system to collect drainage from the new facilities. 

Elba Island is within Savannah Harbor, approximately 5 miles east of the City of Savannah, 

Georgia, and 8.5 miles upstream from the mouth of the Savannah River. The Savannah River, 

the major water feature adjacent to the site, is located in eastern Georgia. Its headwaters 

originate in the Blue Ridge province of Georgia, North Carolina, and South Carolina. The river 

comprises the Georgia and South Carolina border and travels through the Piedmont Province and 

upper and lower Coastal Plains before reaching the Atlantic Ocean. The Savannah River forms 

at the confluence of Georgia’s Tugaloo River and South Carolina’s Seneca River and is 

approximately 300 miles long. The portion of the Lower Savannah River affected by the 

proposed Elba III Project (i.e., transit corridor) is a part of a major shipping port and has been the 

subject of many modifications. The Savannah River has been extensively channelized 

(approximately 500 feet wide and 42 feet deep) throughout the extent of the Terminal Expansion 

facilities area. The channel is maintained by the COE. Much of the Lower Savannah River 

within Chatham County is tidally influenced. During ebb tide, some of the flow from the main 

Savannah River Channel is diverted down the South Channel, located on the south side of Elba 

Island. The South Channel has depths ranging from 3 to 14 feet. 

Water and sediment quality within the Lower Savannah River, including the transit corridor, 

have been impacted by point source discharges including municipal waste water treatment plant 

discharges, industrial wastewater discharges, sewer overflows, land application systems and 

leachate from landfills. Other sources of pollutants include non-point source contributions from 

land use activities, and physical habitat alteration. Non-point sources include sediment, 

fertilizers, animal waste, pesticides, herbicides, septic systems and underground storage tanks. 

Although portions of the Savannah River are listed on the Nationwide River Inventory (NRI) by 

the National Park Service, adjacent to the proposed Terminal Expansion site is not within the 

NRI-designated reach. The GDNR has designated the Savannah River and South Channel as a 

“Fishing” use which is defined as being suitable for the propagation of fish, shellfish, game and 
 4-24 4.0 –Environmental Impact Analysis 

other aquatic life; secondary recreation in and on the water; or any other use requiring water of a 

lower quality. The Savannah River has been designated EFH for several species. See section 

4.6.3 and appendix J for a discussion on EFH. 

No potable water intakes are located within 3 miles downstream of the proposed Terminal 

Expansion site. In addition, none of the drainage ditches affected by the proposed Terminal 

Expansion facilities are considered “sensitive surface waters”. 

Construction Impacts 

On July 26, 2001, the COE issued a permit (Permit No. 200016440) to Southern LNG to deepen 

an existing deep berthing area that runs parallel to Elba Island and lies in-between Elba Island 

and the Savannah River Channel and to construct a new turning basin located directly across 

from Southern LNG’s existing terminal facilities, on the northeast side of the Savannah River 

Channel and bank of the Savannah Harbor in Jasper County, South Carolina. The permit also 

authorized routine maintenance of the deep berthing area and the turning basin which requires 

the annual removal of up to approximately 700,000 cubic yards of accumulated sediments. 

On January 24, 2003, the COE issued a permit (Permit No. 200200640) to Southern LNG to 

construct a new berthing slip located immediately west and south of the deep berthing area 

described above. The new berthing slip consists of a North and South Dock. The permit also 

authorized routine maintenance of the berthing slip which requires the annual removal of up to 

approximately 230,000 cubic yards of accumulated sediments. 

On July 14, 2006, Southern LNG submitted a permit application to the COE and GDNR 

requesting authorization to modify the existing berthing slip described in and constructed under 

Permit No. 200200640. Construction of the proposed Terminal Expansion facilities would 

require the dredging of approximately 72,000 cubic yards of material to modify the slope at the 

toe of the existing berthing slip and install a sheet pile bulkhead. In addition, four mooring 

dolphins would be installed in the existing berthing slip area. In its July 14, 2006 permit 

application, Southern LNG also requested authorization to conduct routine maintenance of the 

modified berthing slip which would continue to require the annual removal of approximately 

230,000 cubic yards of accumulated sediments, previously authorized under Permit No. 

200200640. 

Southern LNG indicated that it would attempt to coordinate “project dredging” with the routine 

maintenance dredging activities authorized under Permit No. 200200640. Southern LNG also 

indicated that the COE is expected to authorize “project dredging” as a modification to Permit 

No. 200200640. 

We expect that the COE and GDNR will continue to authorize routine maintenance of the both 

the turning basin and berthing slip which would require the total annual removal of 

approximately 930,000 cubic yards of accumulated sediments. 

The turning basin size requirements may change as a result of the Project. The expectation is 

that any such change would lead to an overall reduction in its size, and result in less of the basin 
 4-25 4.0 –Environmental Impact Analysis 

being dredged. Southern has modeled the turning basin and submitted this modeling to the Coast 

Guard for their review and approval.

Dredging of the existing berthing slip and turning basin would result in impacts similar to current 

COE activities required to maintain the Savannah Harbor. Dredging would stir up sediment and 

temporarily degrade the water quality of the immediate area surrounding the existing berthing 

slip. Modifications to the existing berthing slip would be completed under the guidelines 

established by Southern LNG’s Plan and Procedures. 

The sediments excavated from the existing berthing slip could contain pollutants from point and 

non-point sources; however, these sediments would not be different from those sediments 

dredged during COE maintenance of the Savannah River near Elba Island. The COE indicated 

that Southern LNG would be able to perform this work by modifying its existing 404/Section 10 

permit. The dredged sediments would be piped into one of two upland CDFs owned and 

operated by Southern LNG on the northwest end of Elba Island (see sections 4.2.3 and 4.5.1). 

Land disturbing activities associated with the Terminal Expansion facilities would be confined to 

a previously disturbed area within the terminal and berthing slip. During site preparation for the 

expansion facilities, disturbed soils would be exposed to potential erosion. To minimize the 

impacts of erosion and sedimentation on surface waters, construction activities at the terminal 

would be conducted in accordance with Southern LNG’s Plan and Procedures. Southern LNG 

would install all necessary erosion and sedimentation control structures and any stormwater 

would be directed toward existing drainage ditches, filtered, and settled before entering the 

Savannah River. 

Surface water quality could be adversely affected by a spill, leak, or other release of hazardous 

materials during construction activities. Transport of these hazardous materials into the 

Savannah River by stormwater runoff would degrade water quality and could impact aquatic 

organisms. To minimize the potential for a spill or release and to establish procedures for 

handling a spill or release during construction of the expansion facilities, Southern LNG would 

implement the project-wide Spill Plan. 

Construction of the proposed Terminal Expansion facilities would increase the amount of 

impervious surfaces at the terminal site, which would increase stormwater runoff volumes. The 

existing stormwater system would be modified, as necessary, to accommodate the additional 

runoff from the proposed expansion facilities. 

Hydrostatic Testing

Southern LNG would hydrostatically test the Terminal Expansion facilities prior to placing them 

in service to verify their integrity. These tests consist of pressurizing the facilities with water 

and checking for pressure losses due to leakage. Hydrostatic testing would be performed in 

accordance with API Standard 620, Appendix Q.8. API Standard 620 deals with the design and 

construction of large, welded, field-erected low-pressure carbon steel aboveground storage tanks 

(including flat-bottom tanks) with a single vertical axis of revolution, and Appendix Q deals with 
 4-26 4.0 –Environmental Impact Analysis 

low-pressure storage tanks for liquefied hydrocarbon gases at temperatures not lower than -

270°F (ICH, 2007). 

A total of 63,250,000 gallons of water would be required for the hydrostatic testing of the new 

LNG storage tanks (31,625,000 gallons per tank). Hydrostatic test water would be pumped from 

the Savannah River and at rate of up to 5,000 gpm. Southern LNG proposes to withdrawal water 

for the hydrostatic testing of Tank D-5 and D-6 place in January 2010 and July 2012, 

respectively. Southern LNG would file for a temporary water withdrawal permit with GDNR 

prior to withdrawing water from the Savannah River. 

Pump intakes would be appropriately screened with a 1/2-inch wire-mesh to prevent the 

entrainment of large particles during hydrostatic test water withdrawal. To prevent the 

impingement/entrainment of fish species on the screens, screen boxes would be sized such that 

the velocity of the inflowing water at the screen surface would be significantly less than the 

typical maximum swimming velocities of adult fish species of concern in the Savannah River 

(less than 0.5 foot per second). Additionally, Southern LNG has agreed to place intakes at a 

depth recommended by appropriate agencies to further reduce the possibility of entraining eggs, 

ichthyoplankton, and fish larvae. However, the potential still exists for fish eggs and larvae to 

pass through the intake filter and be destroyed during the testing process. Therefore, we 

recommend that Southern LNG not conduct hystrostatic test water withdrawals for LNG 

storage tank testing in estuarine habitats from April 1 through July 31.

A total of 600,000 gallons (300,000 gallons per tank) of fresh water from the existing water 

system on Elba Island, or from water trucked to the site, would be used to wash the interior 

surface of each LNG tank as part of the hydrostatic testing. 

Following the completion of the hydrostatic test, test water and wash water would percolate 

through hay bales and flow into existing drainage ditches before it enters the South Channel of 

the Savannah River. The discharge rate into the hay bales would be approximately 20,000 gpm 

for the hydrostatic test water and 100 gpm for wash water. Discharges would be monitored and 

adjusted to prevent overflow. No chemicals would be added to the hydrostatic test water or wash 

water before or after testing. 

We believe the use of Southern LNG’s Plan and Procedures, and the project-wide Spill Plan, and 

its compliance with National Pollution Discharge Elimination System (NPDES) permits would 

minimize adverse impacts to water quality. 

Operational Impacts 

Terminal Expansion

During normal operation of the proposed Terminal Expansion facilities, surface water discharges 

would include stormwater runoff and condensate from the vaporizers. These discharges would 

be piped underground to recharge the existing firewater pond and would not be considered a 

regulated discharge by the GDNR or the Georgia Environmental Protection Division (GEPD). 
 4-27 4.0 –Environmental Impact Analysis 

Southern LNG would follow its existing spill prevention and control procedures for avoiding, or 

containing and disposal of, spills or releases directly into the Savannah River during offloading 

of LNG vessels. 

Because LNG vessels would be fully loaded with LNG when arriving at Elba Island, there would 

be no ballast water on board, and vessels would not discharge ballast water while docked at the 

terminal. However, the LNG vessels would take on ballast while discharging LNG cargo in 

order to maintain a constant draft at the berth. In addition to water withdrawal for ballast, LNG 

vessels may also withdraw water for cooling vessels boilers. The volume of water taken on by 

an off-loading vessel depends on the vessel. Annual ballast uptake estimates would range from 2 

billion gallons if all deliveries are made using 125,000 cubic meter vessels (2,045,300,000 

gallons) to 0.6 billion gallons if 266,000 cubic meter vessels are utilized (614,400,000 gallons). 

Because LNG vessels at the berth would continue water withdrawals to support shipboard 

operations there is a potential to entrain plankton, fish eggs, and larvae. To minimize ballast 

water uptake, Southern LNG would request through its Port Guidelines that vessels limit ballast 

quantities loaded whenever possible to that required for safety and navigation. Any intake 

and/or discharge of ballast would comply with federal regulations and be in accordance with 

Southern LNG’s Ballast Management Plan. To further minimize the impact that could result 

from the increase of 95 vessels per year, we recommend that Southern LNG work with vessel 

owners to identify and implement methods that have the potential to reduce water 

withdrawal volumes while the vessels are berthed. Southern LNG should provide to the 

Commission an annual report for the first three years, detailing the measures that were 

successfully implemented for each vessel.

These “water conservation” measures could result in a percentage reduction in entrainment 

losses of early lifestages of EFH species as well as planktonic prey that may help offset the 

increased impacts from the expansion of the project. 

Waterway for LNG Marine Traffic

Our discussion of the waterway for LNG marine traffic includes the Elba terminal area of the 

Savannah River out to the territorial sea in the Atlantic Ocean. Water quality for the Lower 

Savannah River has been previously discussed in section 4.3.3 of this EIS. The transit corridor 

through the Atlantic Ocean would consist of similar characteristics as the Lower Savannah River. 

Water and sediment quality have been impacted by point and non-point source discharges. A 

dredged channel (46 feet deep at MLW and 600 feet wide) is maintained for about 7.0 miles 

from the sea buoy to the jetties. No maintenance is required from this point out to the territorial 

sea. Further, there are similar EFH species within this region of the Atlantic Ocean (discussed in 

appendix J). 

LNG vessel activity at the existing berthing slip and along the transit corridor, including LNG 

vessels and associated escort vessels, may result in minor resuspension of bottom sediments into 

the water column resulting in a temporary increase in turbidity within the berthing slip, the 

Savannah River, and offshore. Resuspension of bottom sediments and resulting increases in 

turbidity are considered temporary, short-term impacts that are not significant. Use of shallow 

draft tugs to assist LNG vessels throughout the mooring and departure operations may also result 
 4-28 4.0 –Environmental Impact Analysis 

in some resuspension of bottom sediments and increase turbidity over the short-term until 

sediments become stabilized. The resuspension of bottom sediments could reduce dissolved 

oxygen along the waterway and result in sediment burial. An increase in marine traffic could 

result in the need for additional maintenance dredging within the Savannah River Channel. 

However, the incremental increase associated with the project would not be expected to increase 

the need for maintenance dredging. Additionally, increased vessel traffic could result in a minor 

increase to shoreline erosion caused by vessels wakes or prop wash. However, LNG marine 

traffic would travel at a slow speed within the Savannah River transit corridor and increased 

sedimentation due to hull sheer stress or propeller wash would be expected to be consistent with 

other transiting vessels and would not significantly increase shoreline erosion. Further, the 

major contributors to shoreline erosion are water level variations, wind-generated waves, and 

currents. The sedimentation and erosion impacts associated with the proposed LNG marine 

traffic are consistent with the existing marine traffic in the Savannah River transit corridor, and 

we have determined that the proposed LNG marine traffic would not significantly increase 

shoreline erosion or sedimentation along the transit corridor. The minor increase in total vessel 

traffic (3 percent) would be expected to increase shoreline erosion by less than 0.1 percent, and 

thus, would not impact the shoreline significantly. 

Accidental spills or releases of hazardous materials could also impact the waterway. No oil or 

mixtures containing more than 15 parts of oil per million may be discharged within 50 miles of 

the shore (MARPOL 73/78). No solid debris may be discharged from vessels (30 CFR 250.40 

and MARPOL, Annex V, Public Law 100-220 [101 Statute 1458]). Therefore, although 

additional debris may enter the water column incidentally from the increased vessel traffic, the 

anticipated amount of any additional debris would be small and not significant. Further, the 

LNG vessels would adhere to the protective measures specified in Southern LNG’s offshore 

SPCC Plan. 

LNG marine traffic would intake cooling water for vessels boilers while transiting offshore into 

the Savannah River. Impacts to water quality from these intakes would include increased water 

temperature from engine cooling operations. However, the temperature change would be 

insignificant given the total volume of water within these areas and the limited amount of impact 

to any one given area. 

If an unignited marine LNG spill were to occur along the transit route, given that LNG is lighter 

than water, the LNG would float on the water until it had vaporized. No significant impacts to 

water quality would be expected from an unignited release of LNG because LNG is not soluble 

in water and the cryogenic liquid would vaporize rapidly upon contact with the warm air and 

water. Within Zone 1 (described within section 4.12.4.3 of this EIS), the water’s surface within 

the LNG pool may be temporarily impacted by sudden lowering of temperature until the LNG 

had vaporized. Because cold water is more dense than warm water, the colder water would settle 

to the bottom of the channel and could temporarily impact the benthos in the area beneath the 

pool of LNG. If an associated fire were to occur with the release of LNG, the water’s surface 

temperature could increase within Zone 1 of the vicinity of the fire. If the radiant heat were to 

harm the shoreline vegetation, this could result in increased sedimentation within Zone 2. 

Impacts to Zone 2 would be expected to be considerably less than Zone 1. In addition, given the 

resilience of vegetation in wet warm climates, and that root systems would remain intact, these 
 4-29 4.0 –Environmental Impact Analysis 

impacts would not be expected to be permanent. No surface water impacts would be expected 

within Zone 3 from a pool fire. The maximum flammable range for a vapor cloud could extend 

to the outer limits of Zone 3. If the vapor cloud were to come in contact with an ignition source, 

the resulting fire could burn back to the spill and impact any vegetation within its path, thus 

increasing the likelihood of increased sedimentation. However, because of the marine transit 

safety and security measures, the likelihood of an LNG vessel spill from collisions, allisions and 

terrorist attacks would be extremely remote (as discussed in sections 4.12.4 and 4.12.6 of this 

EIS). Impacts associated with a spill would be expected to be temporary and not significant. 

Elba Express Pipeline

The proposed Elba Express Pipeline would cross the Savannah River and Ogeechee River 

Basins. The Ogeechee River Basin includes the Lower and Upper Ogeechee sub-basins and has 

a drainage area of 5.9 million acres. The Savannah River Basin includes the Brier Creek, Little 

River, Broad River, and Upper and Lower Savannah River sub-basins and has a drainage area of 

3.7 million acres. The Savannah River Basin and the Ogeechee River Basin, would be crossed 

from MP 0.0 to MP 121.3. From MP 121.3 to MP 187.9 the Savannah River Basin would be the 

only basin crossed. 

The proposed Elba Express Pipeline would cross 352 surface waters, including 161 perennial 

stream/river crossings, 150 intermittent/ephemeral stream crossings, 11 ponds and 30 manmade 

ditches. Appendix H provides a list of the waterbodies crossed by the proposed pipeline, 

including location by county, state, and milepost; waterbody name and type; crossing width and 

method; classification; and state fishery classification. Of the total waterbodies that would be 

crossed by the proposed pipeline, 5 are 100 feet wide or greater (major waterbodies), and include 

the Little River at MP 134.9, Broad River at MP 161.0, Beaverdam Creek (Richard B. Russell 

Lake) at MP 170.8, Coldwater Creek at MP 178.0, and the Savannah River at MP 187.5. 

In addition to the waterbodies crossed by the proposed pipeline, contractor yards could 

temporarily affect 2 intermittent stream crossings, 1 pond, and 4 manmade ditches, access roads 

that need improvements could affect 9 waterbodies, and the Port Wentworth Meter Station could 

affect 1 manmade drainage ditch. 

The proposed pipeline route would cross one waterbody within 3 miles upstream of a public 

potable surface water intake. In Elbert County, Georgia, Beaverdam Creek (Richard B. Russell 

Lake) is used for a water supply for the City of Elberton (about 3.0 miles west of MP 170.8). 

Waterbodies may be considered sensitive for a number of reasons including, but not limited to, 

the presence of significant fisheries, habitat for threatened or endangered species, high-quality 

recreational or visual resources, historic value, or the presence of impaired water or 

contaminated sediments. The proposed pipeline route would cross 7 waterbodies considered 

sensitive because of their 303(d) list of impairments or NRI status and include Ogeechee Creek 

at MP 33.9, two crossings of Dry Branch at MP 83.2 and MP 84.2, Brushy Creek at MP 96.6, 

Rocky Creek at MP 139.2, Broad River at MP 161.0, Beaverdam Creek (Richard B. Russell 

Lake), and the Savannah River at MP 187.5. 
 4-30 4.0 –Environmental Impact Analysis 

Big Brier Creek (MP 119.2), Broad River, and Savannah River are listed on the NRI. The NRI 

describes Big Brier Creek as a natural, undeveloped scenic stream with outstandingly remarkable 

values (ORVs) that include scenery, recreation, fish, wildlife, history, and cultural. Broad River 

is described as a scenic piedmont stream that is crossed by the Towaliga Fault and has rugged 

topography, rock outcrops, falls, and rapids. Its ORVs include scenery, recreation, geology, fish, 

and wildlife. The NRI indicates that the Savannah River forms the boundary between Georgia 

and South Carolina and has a topography characteristic of the Lower Piedmont and Coastal Plain 

Province. It is relatively flat and dotted with islands and high banks. Its ORVs include scenery, 

recreation, geology, fish, wildlife, history, and cultural (NRI, 2007). EEC has and continues to 

consult with the National Park Service to determine if any additional measures would be required 

for the crossing of these NRI segments. 

Only Dry Branch and Rocky Creek are listed for impairments similar to the potential impacts of 

the proposed pipeline construction (i.e., erosion and sedimentation). Dry Branch is listed as 

Partially Supporting by the Georgia EPD due to the presence of lower diversity and quality 

within the benthological macroinvertbrate community caused by non-point source pollution and 

sedimentation. Rocky Creek is listed as Not Supporting by the Georgia EPD due to 

benthological community impacts caused by urban runoff. EEC has agreed to meet the 

regulatory agency goals for sedimentation for both Dry Branch and Rocky Creek and meet the 

intent of the total maximum daily load requirements. 

EEC reviewed the Georgia and South Carolina Hazardous Sites Inventory and EPA Superfund 

Site lists to determine if any waterbodies crossed by the proposed Elba Express Pipeline have 

known contaminated water or sediments. No sites with contaminated soil or groundwater would 

be crossed or are immediately adjacent to the pipeline. 

Construction Impacts 

The greatest potential impact on surface waters would result from the temporary suspension of 

sediments during in-stream construction. The extent of the impact would depend on sediment 

loads, stream velocity, turbidity, bank composition, and sediment particle size. These factors 

would determine the density and downstream extent of sediment migration. In-stream 

construction could cause the dislodging and transport of channel bed sediments and the alteration 

of stream contours. Changes in the bottom contours could alter stream dynamics and increase 

downstream erosion or deposition, depending on circumstances. Turbidity resulting from 

resuspension of sediments from in-stream construction or erosion of cleared ROW areas could 

reduce light penetration and photosynthetic oxygen production. In-stream work could also 

introduce chemical and nutrient pollutants from sediments. Resuspension of deposited organic 

material and inorganic sediments could cause an increase in biological and chemical use of 

oxygen, potentially resulting in a decrease of dissolved oxygen concentrations in the affected 

area. Lower dissolved oxygen concentrations could cause temporary displacement of motile 

organisms and could kill non-motile organisms within the affected area. 

Construction could potentially rupture the containing layer of some ponds or wetland areas. 

However, the COE would require EEC to maintain the hydrology of wetland areas by issuance of 

its 404 permit, and EEC would be required to maintain pond hydrology by individual landowner 
 4-31 4.0 –Environmental Impact Analysis 

agreements. Where waterbodies are an integral part of a wetland ecosystem (e.g., natural and/or 

beaver ponds), EEC would implement measures to ensure that the hydrologic regime of the 

waterbody/wetland complex would be maintained. Where the pipeline may drain a 

waterbody/wetland complex, trench breakers could be constructed and/or the trench bottom 

could be sealed to maintain the original wetland hydrology (see section 4.4.2). 

The clearing and grading of streambanks would expose soil to erosional forces and would reduce 

riparian vegetation along the cleared section of the waterbody. The use of heavy equipment for 

construction could cause compaction of near-surface soils, an effect that could result in increased 

runoff into surface waters. The increased runoff could transport additional sediment into the 

waterbodies, resulting in increased turbidity levels and sedimentation rates in the receiving 

waterbody. 

Refueling of vehicles and storage of fuel, oil, or other hazardous materials near surface waters 

could create a potential for contamination. If a spill were to occur, immediate downstream users 

of the water could experience degradation in water quality. Acute and chronic toxic effects on 

aquatic organisms could also result from such a spill. 

EEC would follow its Procedures for waterbody crossings to ensure that adequate water flow 

rates would be maintained at all crossing locations and interruption of downstream uses would be 

prevented. EEC’s Plan and Procedures include requirements for preconstruction planning, 

environmental inspection, construction methods, sediment and erosion control, restoration, 

decompaction, and post-construction maintenance. It includes provisions to handle stormwater 

and protection of waterbodies and wetlands from accidental spills of fuels or hazardous 

materials. In addition, EEC would implement the measures contained in the project-wide Spill 

Plan, and other mitigation, as appropriate. 

EEC proposes to open-cut all perennial waterbody crossings except two manmade ditches and 

two unnamed intermittent streams associated with the crossing of Georgia State Highway 21 at 

MP 0.1. These waterbodies would be conventionally bored. Additionally, EEC has proposed to 

cross the Broad River at MP 161.0 and the Savannah River at MP 187.5 by the HDD method. 

EEC is in the process of conducting geotechnical feasibility investigations for these proposed 

HDD crossings which include drilling multiple bore holes along the proposed pipeline 

alignment, review of boring logs, and soil and core sampling laboratory testing. We 

recommend that EEC file with the Secretary the results of its HDD geotechnical feasibility 

investigations for crossing the Broad River and the Savannah River. If its planned HDD 

crossing is not feasible, then EEC should develop a site-specific alternative crossing plan 

and sediment control plan for activities within these waterbodies in consultation with all 

relevant agencies (e.g., COE, GDNR, FWS, NPS, and NMFS). EEC’s plan should be filed 

for review and written approval by the Director of OEP prior to construction at each 

waterbody location.

In its comments on the draft EIS, EEC provided a feasibility evaluation of using the HDD 

method to cross the Little River at MP 134.9, Beaverdam Creek at MP 170.8, and Coldwater 

Creek at MP 178.0. EEC evaluated three crossing methods (i.e., aerial, HDD, and open cut) and 

considered waterbody characteristics, geotechnical considerations, pipeline size, environmental 
 4-32 4.0 –Environmental Impact Analysis 

sensitivities, constructability, and costs. Based on its evaluation, EEC determined that crossing 

these waterbodies using the open cut method would be more feasible than using the HDD 

method. EEC indicted that it has consulted with the FWS and GDNR regarding its proposed 

crossing methods and stated that although the FWS and GDNR would prefer the use of a HDD, 

neither agency objected to EEC’s plan to employ the open cut crossing method at the Little 

River, Beaverdam Creek, and Coldwater Creek. 

The HDD method involves boring a pilot hole beneath the waterbody to the opposite bank and 

then enlarging the hole with one or more passes of a reamer until the hole is the necessary 

diameter. A prefabricated pipe segment is then pulled through the hole to complete the crossing. 

A successful drill generally results in no impact on the stream bed or banks of the waterbody 

being crossed. For this reason, directional drilling is generally considered to be a preferred 

crossing method for sensitive waterbodies. However, there are certain impacts that could occur 

as a result of the drilling, such as an inadvertent release of drilling mud. This could occur in the 

area of the mud pits or tanks, or along the path of the drill due to unfavorable ground conditions. 

Drilling mud is most often comprised of naturally occurring materials, such as bentonite, which 

in small quantities would not be detrimental to vegetation, fish, or wildlife. However in larger 

quantities, the release of drilling mud into a waterbody could affect fisheries and vegetation; 

although impacts would generally be less than those associated with an open-cut crossing. 

EEC would implement its HDD Contingency Plan and Feasibility Assessment that describes how 

the drilling operations would be conducted and monitored to minimize the potential for 

inadvertent drilling mud releases (frac-out) or failure of the drill. The HDD Contingency Plan 

and Feasibility Assessment also discusses procedures for clean-up of drilling mud releases and 

for sealing the drill hole if a drill cannot be completed. 

EEC would minimize impacts on surface waters during an open-cut crossing by implementing 

the waterbody construction and mitigation procedures contained in its Procedures, which 

include: 

• limiting clearing of vegetation between extra work areas and the edge of the waterbody to 

preserve riparian vegetation; 

• constructing the crossing as close to perpendicular to the waterbody as site conditions 

allow; 

• maintaining adequate flow rates throughout construction to protect aquatic life and 

prevent the interruption of existing downstream uses; 

• locating equipment staging areas, soil stockpile areas, and equipment refueling areas at 

least 50 feet from surface waters; 

• requiring construction across waterbodies to be completed as quickly as possible and 

during the windows specified in its Procedures or required by applicable permits; 

• developing and adhering to any required site-specific construction plan for each 

waterbody greater than 100-feet-wide at the crossing location (major waterbody); 

• requiring temporary erosion and sediment control measures to be installed across the 

entire width of the construction ROW after clearing and before ground disturbance; 

• requiring maintenance of temporary erosion and sediment control measures throughout 

construction until streambanks and adjacent upland areas are stabilized; 
 4-33 4.0 –Environmental Impact Analysis 

• requiring bank stabilization and reestablishment of bed and bank contours and riparian 

vegetation after construction; 

• limiting post-construction vegetative maintenance of buffer strips adjacent to streams; 

and 

• implementing the project-wide Spill Plan if a spill or leak occurs during construction. 

In addition to the use of the measures described above, EEC would need to obtain and comply 

with all conditions of its COE Section 404 permit and Section 401 state water quality 

certifications. 

The intermittent/ephemeral waterbodies are expected to be dry at the time of construction, during 

the summer months. These waterbodies do not typically support fisheries or provide critical 

aquatic habitat or migratory passage for aquatic organisms. After construction, EEC would 

restore all contours to preconstruction conditions. Impacts on intermittent/ephemeral 

waterbodies would be limited to temporary alteration of channel beds and banks and possibly 

increased sediment load during initial storm events following construction. If 

intermittent/ephemeral waterbodies are flowing at the time of construction, EEC states it would 

install the pipeline using the open-cut method in accordance with the measures in its Procedures. 

The seven waterbodies that would be crossed by the Elba Express Pipeline that are considered 

sensitive because of their 303(d) list of impairments or NRI status would not be further impaired 

since these waterbodies would be crossed using EEC’s Procedures. Impacts to the Broad River 

and Savannah River would be avoided by EEC’s use of the HDD method. 

We believe that implementation of the measures and the procedures contained in Southern LNG 

and EEC’s project-wide Spill Plan, HDD Contingency Plan and Feasibility Assessment, and 

Procedures would avoid or minimize potential impacts on surface waters, and no long-term 

impacts on surface water quality would occur. 

Hydrostatic Testing 

EEC would hydrostatically test the Elba Express Pipeline facilities prior to placing them in 

service to verify their integrity. These tests consist of pressurizing the facilities with water and 

checking for pressure losses due to leakage. Hydrostatic testing would be performed in 

accordance with the pipeline safety regulations identified in 49 CFR Part 192, “Transportation of 

Natural and Other Gas by Pipeline: Minimum Federal Safety Standards.” 

Sources of hydrostatic test water are expected to be surface waterbodies in close proximity to the 

pipeline. EEC would require approximately 21,705,500 gallons of water to hydrostatically test 

the Elba Express Pipeline (see table 4.3-1). 

The withdrawal of large volumes of hydrostatic test water from the surface water sources could 

temporarily affect the recreational and biological uses of the resource if the withdrawals 

constitute a large percentage of the source’s total flow or volume. The withdrawal of large 

volumes of water from waterbodies could also result in the temporary loss of habitat, changes in 
 4-34 4.0 –Environmental Impact Analysis 

water temperature and dissolved oxygen levels, and entrainment or impingement of fish or other 

aquatic organisms. 

TABLE 4.3-1

Hydrostatic Test Water Volumes for the Elba Express Pipeline 

Primary Sources Sites Approximate Volume 

(gal) 

City of Port Wentworth – water hydrant used by Southern (MP 0.0) 1,500,000 

County of Effingham – water hydrant used by Southern (MP 9.0) 1,500,000 

Existing water well at the Effingham Bus. Maintenance Shop 

adjacent to Southern ROW (MP 16.3) 1,402,100 

Ogeechee Creek (MP 33.9) 1,389,500 

South Fork of the Ogeechee (MP 44.6) 5,402,000 

Rocky Creek (2nd crossing) (MP 86.2) 1,350,500 

Brushy Creek (MP 96.6) 1,181,700 

Little River (134.9) 1,181,700 

Broad River (MP 161.0) 1,856,500 

Beaverdam Creek (Richard B. Russell Lake) (MP 170.9) 2,325,100 

Cedar Creek (MP 185.3) 1,000,000 

Savannah River (MP 187.5) 1,616,400 

Total 21,705,500 

EEC would minimize the potential effects of hydrostatic testing on surface water resources by 

adhering to the measures in its Procedures, including: 

• locating hydrostatic test manifolds outside of wetlands and riparian areas as practical; 

• withdrawing from and discharging to water sources in compliance with appropriate 

agency requirements that consider the protection of fishery and other resources on a 

case-by-case basis; 

• complying with all appropriate permit requirements; 

• screening the water intake manifold to avoid entrainment of fish; 

• suspending the water intake hose with a float to reduce the uptake of sediment from the 

waterbody floor; 

• maintaining adequate flow rates to protect aquatic life and provide for all waterbody uses 

and downstream withdrawals of water by existing users; 

• anchoring the discharge pipe for safety; 

• discharging test water to a suitable receiving body of water, across a well-vegetated 

upland area or filtered through a filter bag or into erosion control barriers; 

• discharging test water against a splash plate or other energy dissipating device; and 

• controlling the rate of discharge in order to prevent flooding or erosion. 

EEC would acquire the necessary permits from state agencies before withdrawing hydrostatic 

test water, including specific approvals from applicable resource agencies. No chemicals would 

be added to the test water. 
 4-35 4.0 –Environmental Impact Analysis 

4.3.4 Sediments 

Terminal Expansion

Geotechnical investigations conducted by Southern LNG indicate that the subsurface sediments 

underlying the proposed Terminal Expansion site consist of about 4 feet of historically-placed 

hydraulic (dredged) and man-made fill. Below this is a 34-foot-deep soft clay layer, followed by 

layers of sand, very stiff sandy clay, very dense clayey sand, and very dense silty sand, to a depth 

of 140 feet below MLW (WPC, 2006a). Table 4.1-1 in section 4.1.1 provides descriptions of the 

surficial material at the Terminal Expansion site. 

Southern LNG’s analysis of existing subsurface soil conditions indicates that the soft sediments 

located beneath the proposed LNG tanks are highly compressible, have low undrained strength, 

and would not be capable of supporting the tanks using shallow foundation systems or ground 

improvement measures such as stone columns, dynamic compaction, and surcharge. Therefore, 

to support the tanks and prevent localized settlement, Southern LNG would support each tank’s 

foundation on 1,941 steel or pre-stressed concrete piles driven into the sediment to a depth of 

about 74 feet, with each building’s foundation, equipment, and pipe racks driven to a depth of 

about 45 feet. These depths would minimize the potential for settlement of the facilities due to 

the presence of soft/weak natural and fill soils typically found 26 to 56 feet below the site’s 

ground surface. 

Made land sediments to be dredged from the back slope of the existing berthing slip would be 

placed into the existing spoil disposal area on the north end of Elba Island, adjacent to the 

Terminal. In order to accommodate larger LNG vessels, a total of 72,000 cubic yards of material 

would be dredged from the back of the slip, creating a steep 90-degree angle at the back of the 

slip and dredging to the current depth of the existing slip (-42 feet MLW). A sheetpile bulkhead 

would be installed at the back of the slip to stabilize the sediment. 

4.4 WETLANDS 

Wetlands are areas that are inundated or saturated by surface or groundwater at a frequency and 

duration sufficient to support, and that under normal circumstances do support a prevalence of 

vegetation typically adapted for life in saturated soil conditions, commonly known as 

hydrophytic vegetation (Environmental Laboratory 1987). Wetlands can be a source of 

substantial biodiversity and serve a variety of functions that include providing wildlife habitat, 

recreational opportunities, flood control, and naturally improving water quality. 

Wetlands affected by the Terminal Expansion and Elba Express Pipeline facilities are regulated 

at the federal and state levels. On the federal level, the COE has authority under Section 404 of 

the CWA to review and issue permits for activities that would result in the discharge of dredged 

or fill material into waters of the United States, including wetlands. Section 401 of the CWA 

requires that proposed dredge and fill activities under Section 404 be reviewed and certified by 

the designated state agency (the GDNR in Georgia and the South Carolina Department of 

Natural Resources [SCDNR] in South Carolina) to ensure that the proposed project would meet 

state water quality standards. 
 4-36 4.0 –Environmental Impact Analysis 

Southern LNG and EEC identified wetlands within the project areas by field delineations 

conducted in 2005 and 2006. EEC will complete additional delineations and report amendments 

as necessary to address areas where survey access has not been obtained prior to the initiation of 

construction. Delineations followed the 1987 COE Wetland Delineation Manual (Environmental 

Laboratory, 1987). Additionally, qualitative assessments were conducted for each wetland. The 

COE requires that qualitative assessments be based on five ecological parameters that include: 

quality of wetland vegetation; soils; hydrology; presence of plant and animal species of concern; 

and level of disturbance within the wetland and adjacent areas. The COE would take jurisdiction 

on all wetlands included in Southern LNG’s and EEC’s delineation reports. Wetland types were 

classified into one of three types according to Cowardin et al. (1979), including: 

• palustrine forested wetlands (PFO), which are dominated by tree species at least 6 meters 

tall; 

• palustrine scrub-shrub wetlands (PSS), which are dominated by woody vegetation less 

than 6 meters tall; or 

• palustrine emergent wetlands (PEM), which are dominated by erect, rooted herbaceous 

hydrophytes. 

The wetland delineation reports are accessible as part of the Terminal Expansion and Elba 

Express Pipeline project’s public files in Docket Nos. CP06-471-000, CP06-472-000, and 

CP06-473-000 using the e-library link on the FERC’s Internet website. 

4.4.1 Affected Wetlands 

Terminal Expansion

No wetlands would be affected by the proposed facilities at the Terminal Expansion site. 

Waterway for LNG Marine Traffic 

No wetlands along the Savannah River transit route are expected to be impacted by the proposed 

increase in vessel traffic. Wave action and sedimentation rates from LNG marine traffic would 

be expected to be consistent with current levels with a minimal overall impact given the limited 

increase in number of vessels. Locations of wetlands along the marine traffic route are shown in 

figure 4.12.-2. 

 

Wetland plant species within the Zones of Concern (described in section 4.12.4.3) along the 

Savannah River are consistent with species present at the terminal and along the pipeline route, 

and are present along the entire LNG marine traffic route. If an unignited release of LNG were 

to occur along the LNG marine traffic route, given that LNG is lighter than water, the LNG 

would float on the water until it had vaporized. If the LNG were to contact any wetland plants 

along the Savannah River, those species above the water line could be impacted by the extremely 

low temperatures. While impacts within Zone 1 could be significant, no wetland impacts would 

be expected outside of Zone 1 from the resulting pool of LNG. 
 4-37 4.0 –Environmental Impact Analysis 

If an associated fire were to occur with a marine LNG spill, and wetland vegetation exists within 

Zone 1, those wetlands could be impacted by the high radiant heat. Impacts on wetland 

vegetation within Zone 1 would be significant. In Zone 2, wetland vegetation could be impacted 

from radiant heat. Those species could dry out due to the extreme heat. Impacts on wetland 

vegetation within Zone 2 would likely be less severe than those in Zone 1. In addition, given the 

resilience of wetland species in wet warm climates, and that root systems would remain intact, 

these species would be expected to reestablish rapidly in the affected areas. Zone 3 would not be 

expected to experience any significant impacts from a pool fire. The maximum flammable range 

for a vapor cloud could extend to the outer limits of Zone 3. If the vapor cloud were to come in 

contact with an ignition source, the resulting fire could burn back to the spill and impact any 

wetlands within its path. However, because of the marine transit safety and security measures 

(as described in sections 4.12.4 and 4.12.6 of this EIS), the likelihood of an LNG carrier spill 

from collisions, allisions and terrorist attacks would be extremely remote. 

Elba Express Pipeline

PFO wetlands crossed by the Elba Express Pipeline Project consist of an overstory dominated by 

deciduous broad-leaved tree species, some conifer species, and a variety of herbaceous plant and 

vines in the herbaceous layer. Common vegetation in forested wetlands along the pipeline route 

include: water oak, laurel oak, sweet gum, sweet bay, tulip poplar, red maple, black gum, bald 

cypress, and loblolly pine in the over- and under-story and bushy bluestem, giant cane, sedges, 

soft rush, dwarf palmetto, and greenbrier in the herbaceous layer. 

PSS wetlands crossed by the Elba Express Pipeline Project typically occur in areas of periodic 

mowing that prevents the establishment of tree species, but allow for the establishment of shrubs 

and herbaceous species (ex. existing ROWs). PSS wetlands are vegetated with true shrubs, 

young trees, and trees or shrubs that are small or stunted because of environmental conditions. 

They may represent a successional stage leading to a forested wetland or they may be relatively 

stable communities. Common vegetation in scrub-shrub wetlands along the pipeline route 

include: red maple, eastern false willow, black willow, yaupon holly, and southern bayberry. 

The herbaceous layer includes those common species found forested wetlands. 

PEM wetlands are present for most of the growing season in most years and usually are 

dominated by perennial plants. Common vegetation in emergent wetlands along the pipeline 

route include: bushy bluestem, Virginia button-weed, spikerush, soft rush, redroot, maidencane, 

pickerelweed, meadow-beauty, hooded pitcher plant, and bulrush. 

Construction of the Elba Express Pipeline would temporarily disturb approximately 237.09 acres 

of wetland. Of this amount, approximately 119.45 acres are emergent wetlands; 11.37 acres are 

scrub-shrub wetland; and 106.27 acres are forested wetland. No permanent impacts to emergent 

wetlands are anticipated. Appendix I lists each wetland that would be crossed by the Elba 

Express Pipeline, as identified during EEC’s field delineations, along with wetland identifier and 

quality, milepost, wetland types, and approximate area affected by construction. 

Two contractor yards (0.46 acre of scrub-shrub and 0.18 acre emergent) and three meter station 

sites (0.23 acre forested wetland and 0.90 acre emergent wetland) would also affect wetlands. 
 4-38 4.0 –Environmental Impact Analysis 

Access roads that need improvements could affect 5 wetlands. EEC has identified six ATW 

areas that would be required in wetlands due to site-specific construction conditions to allow 

conventional bore of roadways and a railroad. 

The primary impact of pipeline construction and ROW maintenance activities on wetlands would 

be the temporary and permanent conversion of wetland vegetation. These effects would be 

greatest during and immediately following construction. Generally, the wetland vegetation 

community would eventually transition back into a community with a function similar to that of 

the wetland before construction. In emergent wetlands, the impact of construction would be 

relatively brief, since the herbaceous vegetation would regenerate quickly (generally within 1 to 

2 years). Scrub-shrub wetlands could take 2 to 4 years to reach functionality similar to 

preconstruction conditions depending on the age and complexity of the system. In forested 

wetlands, the impact of construction would be much longer due to the longer regeneration period 

of these vegetative types. Given the species that dominate the forested wetlands crossed by the 

Elba Express Pipeline, regeneration to preconstruction conditions may take up to 30 years. 

Other impacts associated with construction of the pipelines could include temporary changes to 

wetland hydrology and water quality. During construction, failure to segregate topsoil over the 

trenchline in non-saturated wetlands could result in the mixing of the topsoil with the subsoil. 

This disturbance could result in altered biological activities and chemical conditions in wetland 

soils and could affect the reestablishment and natural recruitment of native wetland vegetation 

after restoration. In addition, inadvertent compaction and rutting of wetland soils during 

construction could result from the movement of heavy machinery and the transport of pipe 

sections and temporary stockpiling of wetland soils. Surface drainage patterns and hydrology 

could be temporarily altered during construction and the pipeline trench could act as a drainage 

channel. Increased siltation and turbidity could result from trenching activities. In addition, 

trenching could penetrate or remove impervious soil layers under the wetland and, consequently, 

drain perched water tables. This in turn, could result in drier soil conditions that inhibit the 

reestablishment of wetland vegetation. Disturbance of wetlands also could affect the wetland’s 

capacity to control erosion and floods. 

4.4.2 Wetland Construction Procedures 

In general, wetland impacts need to be avoided, minimized, rectified, reduced, and mitigated in 

accordance with federal and state regulations. These steps are commonly referred to as 

“sequencing” because one step must be completed before the next step is started. As described 

in section 2.6.3, the Elba Express Pipeline has been routed to avoid wetlands to the extent 

feasible. In addition, wetland impacts would be minimized by the proposed pipeline routing 

adjacent to existing maintained ROWs to the extent practicable. This would minimize impacts 

on previously undisturbed wetlands. 

EEC would further minimize the potential environmental impact of construction on wetlands by 

implementing its Procedures during construction and restoration of all of its proposed facilities. 

EEC’s Procedures contain wetland mitigation measures that are designed to minimize the overall 

area of wetland disturbance, minimize the duration of wetland disturbance, reduce the amount of 
 4-39 4.0 –Environmental Impact Analysis 

wetland soil disturbance, and enhance wetland restoration following construction. Examples of 

some of the wetland impact minimization measures specified in EEC’s Procedures are: 

• limiting the width of the construction ROW to 75 feet through non-cultivated wetlands; 

• limiting the operation of construction equipment within wetlands to that equipment 

essential for clearing, excavation, pipe installation, backfilling, and restoration; 

• limiting grading in wetlands to directly over the trenchline, except where necessary to 

ensure safety; 

• minimizing the length of time that topsoil is segregated and the trench is open; 

• installing trench breakers at the boundaries of wetlands as needed to prevent draining of a 

wetland and to maintain original wetland hydrology; 

• prohibiting storage of hazardous materials, chemicals, fuels, and lubricating oils within a 

wetland or within 100 feet of a wetland boundary; and 

• limiting post-construction maintenance of vegetation within herbaceous wetlands to a 10-

foot wide strip of vegetation centered over the pipeline; and in forested areas, limiting 

tree removal to those that are greater than 15 feet in height and within 15 feet of the 

pipeline centerline. 

EEC would use a 75-foot-wide construction ROW in wetlands. EEC has attempted to locate 

ATWs at least 50 feet from wetlands; however, six ATWs locations along the pipeline ROW 

have been preliminarily identified as having wetlands located in them. The ATWs are required 

for conventional bores used to cross roadways, an access road, and stream crossing. Deviations 

from this 50-foot setback would require our approval prior to construction. 

When unavoidable wetland impacts are proposed, the COE would require in its permit that all 

appropriate and practicable actions be taken to avoid or mitigate those impacts. We have 

reviewed the route and alternatives to minimize the level of impact to wetlands. Additionally, 

we have reviewed EEC’s Procedures for crossing wetlands and found them acceptable. 

GDNR and the FWS asked about EEC’s plans for crossing “grady” type wetlands within the DiLane Plantation WMA in Burke County between MPs 74.4 and 78.1. EEC indicated that soil 

segregation was discussed with the GDNR as a way to ensure that these wetland areas are 

properly restored. Further, EEC stated that it would take core samples every 2.5 feet near 

“grady” type wetlands to determine the soil conditions down to about 20 feet below ground 

surface. Where the proposed pipeline crosses the Di-Lane Plantation WMA, it would parallel 

two existing SNG pipelines. Although construction would require clearing 70 feet of temporary 

workspace along the edge of the existing pipeline corridor, EEC would require no additional 

permanent ROW to cross the WMA. We believe potential impacts on “grady” type wetlands 

would be minimized because the proposed route follows an established corridor across this 

WMA and EEC has agreed to develop additional mitigation beyond its Plan and Procedures 

(which constitute Best Management Practices) in consultation with the COE and the GDNR 

before construction. 
 4-40 4.0 –Environmental Impact Analysis 

On-Site Mitigation

EEC indicated in section C.4 of its Procedures that it does not intend to revegetate wetlands by 

planting native species rather it would allow wetlands to revegetate naturally. However, as 

indicated in section C.5 of its Procedures, EEC presented its proposed wetland restoration 

methods in its Wetland and Waterbody Delineation Report and Mitigation Plan, that was 

submitted to the COE as part of its permit approvals, and specified that it does not intend to 

revegetate scrub-shrub and emergent wetlands by planting native species rather it would allow 

wetlands to revegetate naturally. Mitigation measures for forested wetland impacts are described 

below. EEC would implement the restoration measures for wetlands (e.g., natural revegetation) 

as described in its Wetland and Waterbody Delineation Report and Mitigation Plan and in 

accordance with its COE permit conditions. 

EEC has stated it would comply with federal and state permit conditions regarding wetland 

restoration and mitigation. EEC would be required to abide by any conditions in the COE permit 

regarding construction, restoration, revegetation, and maintenance of the proposed pipeline.

Off-Site Mitigation

EEC has stated it would also comply with the conditions of applicable authorizations such as 

from the COE under Section 404. When unavoidable impacts would result from the proposed 

action, the COE would require that all practicable actions be taken to mitigate those impacts. 

Typically, mitigation for temporary impacts on emergent or scrub-shrub wetlands would need to 

be “in-kind, in-place” (i.e., rehabilitation of the wetlands that are impacted) as opposed to 

compensatory mitigation. Active planting or seeding in emergent and scrub-shrub wetlands 

would not be required as long as the wetlands are adequately restored within two growing 

seasons. The COE could require mitigation requirements for temporary impacts on forested 

wetlands including planting to reestablish the forest vegetation as well as compensatory 

mitigation for the long-term impacts. Planting would include the use of live plants of specific 

sizes planted at specified densities with certain survival rates required. Where permanent 

wetland impacts would occur (e.g., at aboveground facility sites), the COE would require 

compensatory mitigation. 

The COE has a policy of “no net loss” of wetlands of the United States. This means that every 

wetland impact must be offset by the creation, restoration, enhancement, or preservation of at 

least an equal amount of wetlands, which is referred to as compensatory mitigation. 

Compensatory mitigation is considered when the regulatory agencies have evidence that 

sequencing has been carried out. Residual wetland impacts that are not or cannot be mitigated 

within the project area are accounted for using compensatory mitigation to ensure that there is a 

full replacement of both wetland area and functions. Compensatory mitigation would be 

achieved by the purchase of credits from a wetland mitigation bank approved by the COE or by 

providing funding (i.e., in-lieu fees) for an approved, agency-sponsored wetland preservation, 

enhancement, or creation project. Mitigation would be required to occur within the same 

watershed where the impacts occurred. 
 4-41 4.0 –Environmental Impact Analysis 

In its Wetland and Waterbody Delineation Report and Mitigation Plan, EEC indicted that, to 

mitigate forested wetland impacts associated with the Elba Express Pipeline, it proposes to 

purchase credits from a wetland mitigation bank that manages large areas of existing forested 

wetlands or has the potential to restore forested wetlands within the watersheds that would be 

crossed by the proposed pipeline. 

EEC, in consultation with the COE, determined that it would have to purchase a total of 81.00 

mitigation credits from a mitigation bank to compensate for the anticipated loss of forested 

wetlands associated with Elba Express Pipeline (71.00 credits) and any additional impacts to 

forested wetlands that could occur, due to unforeseen minor route variations, during the 

construction phase (10.00 credits). 

Possible mitigation banks and projects in Georgia that EEC could use to satisfy its mitigation 

requirements are the (1) Quacco Canal Wetland Restoration Project in Chatham County; (2) 

Millhaven Mitigation Bank in the Savannah River basin; (3) Pine South Wetland Mitigation 

Bank in Jefferson County, and (4) Phinizy Swamp Wetland Mitigation Bank that services most 

of the Savannah River basin including all counties crossed by the proposed pipeline. 

In its comments on the draft EIS, the EPA stated that the Quacco Canal Wetland Restoration 

Project is not a COE approved commercial mitigation bank and has expressed concern about its 

development into a commercial bank. The Pine South Wetland Mitigation Bank consists of a 

wetland type not likely requiring mitigation for the Elba III Project while the Phinizy Swamp 

Wetland Mitigation Bank does not match the Piedmont wetland impacts. The EPA indicated that 

it is uncertain if the Millhaven Mitigation Bank remains active or has available credits; however, 

this bank better matches the coastal plain riverine wetlands that would be affected by the Project. 

Therefore, we recommend that EEC reevaluate the local wetland mitigation options, in 

consultation with the COE, in order to determine one or more suitable banks that provide 

in-kind mitigation in the same watershed as project impacts. EEC should file its 

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

EEC’s compensatory mitigation plan for forested wetland impacts is still under development and 

review by the COE. EEC will file it with the FERC once it is complete. 

Vegetation maintenance would not be conducted over the full width of the permanent ROW in 

wetlands. However, to facilitate periodic pipeline corrosion/leak surveys, a corridor centered on 

the pipeline and up to 10 feet wide would be maintained in an herbaceous state. In addition, 

trees within 15 feet of the pipeline greater than 15 feet in height may be selectively cut and 

removed from the permanent ROW. 

The COE would require mitigation for habitat losses on both existing mitigation land as well as 

other COE project lands. In its comments on the draft EIS, EEC stated that COE presented its 

proposed mitigation requirements for COE projects lands which include a 3:1 acreage mitigation 

ratio for permanent impacts and a 0.5:1 to 1:1 acreage mitigation ratio for temporary impacts. 

EEC has agreed to coordinate with the COE to determine appropriate mitigation requirements. 
 4-42 4.0 –Environmental Impact Analysis 

4.5 VEGETATION 

4.5.1 Vegetation Resources 

Terminal Expansion

The proposed Terminal Expansion facilities would be constructed on previously disturbed areas 

of Elba Island. The island, within the Savannah River, has been used as a CDF for dredging 

activities conducted on the Savannah River. Due to the historic use of the island as a CDF site, it 

is considered to be highly disturbed, and comprised of exotic species that are not productive as 

agricultural land, grazing land, or wildlife habitat. 

The northwest end of the island is currently used as a CDF. The vegetation community types for 

the Terminal Expansion site includes a maintained grassy area that is vegetated with Bahia grass 

and two, small, low-lying, non-wetland areas are vegetated with water purslane. The vegetation 

communities in areas to the south of the terminal, outside of the proposed construction area, 

include a mixture of low quality hardwood stands, maintained grass, and strips of emergent 

marsh. Areas of the existing terminal site that are not developed are covered by asphalt, crushed 

rock, or maintained grass. 

Construction of the proposed Terminal Expansion facilities would affect about 176.8 acres of 

land, of which, 93.4 acres are maintained grassy areas and 83.4 acres are paved or graveled 

areas. The loss of this vegetation is not seen as significant due to the non-native species 

composition. 

Waterway for LNG Marine Traffic

Aquatic and shoreline habitats adjacent to the vessel transit corridor include open water, salt and 

brackish marshes, and exposed tidal flats. Potential impacts on these habitats that result from 

increased LNG marine traffic associated with the project along the transit corridor would be 

similar to those resulting from other vessels using the navigation channel. No significant 

impacts on aquatic and shoreline habitats are expected within the transit corridor as a result of 

normal operation of increased LNG marine traffic. 

Vegetation species within the Zones of Concern (described in section 4.12.4.3 of this EIS) along 

the Savannah River are consistent with species present at the terminal and along the pipeline 

route. If an unignited marine LNG spill were to result in a pool that contacted any vegetation 

along the Savannah River, plants could be temporarily impacted by the extremely cold 

temperature. In addition, given the resilience of vegetation species in wet warm climates, and 

that root systems would remain in tact, vegetation would be expected to reestablish rapidly. 

However, tree species would take longer to reestablish. No impacts to vegetation would be 

expected outside of Zone 1 from a release of LNG. If an associated fire were to occur with the 

release of LNG, plants within Zone 1 in the vicinity of the fire would either burn or combust due 

to the radiant heat. Impacts within Zone 2 would be expected to be less than those in Zone 1. 

Some plants within Zone 2 may be harmed by the radiant heat, while others would be unaffected. 
 4-43 4.0 –Environmental Impact Analysis 

No impacts would be expected to occur to vegetation species within Zone 3 from a pool fire. 

The maximum flammable range for a vapor cloud could extend to the outer limits of Zone 3. If 

the vapor cloud were to come in contact with an ignition source, the resulting fire could burn 

back to the spill and impact any vegetation species within its path. However, because of the 

marine transit safety and security measures (as described in sections 4.12.4 and 4.12.6 of this 

EIS), the likelihood of an LNG vessel spill from collisions, allisions and terrorist attacks would 

be extremely remote. 

Elba Express Pipeline

Vegetation types that would be affected by the Elba Express Pipeline include forest, pine 

plantation, and open land (see table 4.5-1). Wetlands are discussed in section 4.4 of this EIS. 

Portions of the Elba Express Pipeline Project route contain southern mixed pine-oak forest. 

Common overstory species of this forest cover type include long-leaf and shortleaf pine, loblolly 

pine, slash pine, live oak, myrtle oak, laurel oak, water oak, willow oak, red maple, black gum, 

sweet gum, elm, beech, sycamore, magnolia, and hollies. The understory is typically vegetated 

with shrubs including saw palmetto, southern bayberry, and winged sumac, while the herbaceous 

layer includes grass species such as bluestem grass, yellow stargrass, wiregrass, redroot, Spanish 

moss, and colic root. 

Planted pine plantations are dense pine forests that have been planted primarily for timber or 

wood pulp production. Loblolly pine, slash pine, shortleaf pine, and long-leaf pine are common 

overstory species. The understory is sparse and is often controlled through maintenance 

activities. 

TABLE 4.5-1

Estimated Impacts on Vegetation Communities Along the Elba Express Pipeline (acres) a/

Upland Forest Planted Pine Open Land Total 

Project Component 

Temp Perm Temp Perm Temp Perm Temp Perm 

ELBA EXPRESS PIPELINE 

921.30 337.28 534.78 161.26 625.45 215.78 2,081.53 714.32 

ELBA EXPRESS COMPRESSOR STATION 

0.00 0.00 23.21 23.21 0.37 0.37 23.58 23.58 

ABOVEGROUND FACILITIES (Meter Stations, Mixing Station, and Launcher/Receiver) 

7.85 4.64 3.76 1.37 0.68 0.68 12.29 6.69 

CONTRACTOR YARDS 

11.89 0.00 0.03 0.00 109.03 0.00 120.95 0.00 

Project Totals 941.04 341.92 561.78 185.84 735.53 216.83 2,238.35 744.59 

________________________________________________________________ 

a/ Estimated impacts on wetlands are discussed in section 4.4. Vegetation totals do not include wetland cover types. 

Construction impacts include ATW. 

About 44.5 acres of existing access roads would be improved. 

Temp = temporary 

Perm = permanent 
 4-44 4.0 –Environmental Impact Analysis 

Open lands are typically vegetated with grasses, forbs, and shrubs. Agricultural, industrial, and 

residential lands are further discussed in section 4.8 of this EIS. 

EEC’s proposed construction ROW and temporary extra workspaces would disturb 

approximately 921.30 acres of upland forest, 534.78 acres of pine plantation, and 625.45 acres of 

open land. These impact areas reflect the entire length of the 125-foot-wide construction ROW 

for the 42-inch-diameter pipeline and the 110-foot-wide construction ROW for the 36-inchdiameter pipeline, as well as identified temporary extra workspaces. Newly identified or revised 

temporary extra workspaces could also affect acreage totals. 

The primary impact on vegetation from construction of the Elba Express Pipeline facilities 

would be the cutting, clearing, and/or removal of existing vegetation within the construction 

work area. The degree of impact would depend on the type and amount of vegetation affected, 

the rate at which vegetation would regenerate after construction, and the frequency of vegetation 

maintenance conducted on the ROW during pipeline operation. 

The ROW revegetation rate would depend on several factors, including local climate, soil type, 

vegetation maintenance practices, land use, and the existing and seeded vegetation. The amount 

of time required for complete recovery of vegetation to predisturbance levels would depend on 

these factors as well as the size and age of pre-existing vegetation when cleared. The relative 

impact of clearing would be greatest in forested areas because the removal of this vegetation 

would result in the greatest change in the structure and environment of the plant community. 

Moreover, the effect of clearing would be of longer duration in forested areas than in other areas 

(e.g., open land) and, in the case of the maintained ROW would be permanent. On temporary 

work areas where forest regeneration would be allowed, the re-establishment of forest to 

preconstruction conditions could take between 25 and 150 years. In contrast, the reestablishment of open lands following construction would probably take one to three years. 

Conversion of woodland to an herbaceous cover would be a long-term effect of construction. 

Where its proposed pipelines would cross upland forest and pine plantations, EEC would 

maintain the entire permanent ROW (50-feet-wide in most cases) in a grassy condition. Of the 

1,502.82 acres of forest that would be cleared during construction of the pipelines and 

aboveground facilities, about 498.54 acres would be maintained in herbaceous cover following 

construction, and the remaining 975.06 acres would be allowed to revert to forest. The 527.76 

acres of green space (defined here as upland forest and planted pine) permanently converted 

from forested lands to herbaceous cover represent about 16 percent of the total project land 

disturbance, and on a regional scale would result in a minor conversion of about 0.002 percent of 

a Georgia state total of 24 million forested acres (Georgia Forestry Commission, 2007). Forested 

wetlands within the maintained permanent ROW would be converted to emergent or scrub/shrub 

wetlands (see section 4.4). There would be minimal change in open lands because it would be 

maintained in vegetative cover similar to that found before construction. 

Vegetation removal would result in alteration to the vegetation structure, especially in forested 

habitats. Following installation of the pipeline and recontouring of the ROW, EEC would reseed 

all disturbed areas in accordance with its Plan (seed mixes were recommended by the NRCS). 
 4-45 4.0 –Environmental Impact Analysis 

Revegetation of the temporary ROW and extra work areas would occur at varying rates 

depending on site-specific conditions such as the amount of disruption of the soil and species 

composition of adjacent habitats. Wooded habitats would take much longer to regrow to 

preconstruction conditions than herbaceous habitats. Species composition of the ROW after 

construction and restoration could be different from pre-construction composition, although 

given sufficient time, species composition likely would resemble pre-construction conditions. 

Species composition of adjacent habitats, particularly along the edges of the ROW, could be 

altered by changes in abiotic conditions such as sunlight and wind levels. Increased light would 

favor growth of shade intolerant species that typically do not inhabit the forest interior. Higher 

wind levels could lead to increased windthrow in adjacent forested areas, especially forested 

wetlands. 

Construction of EEC’s aboveground facilities, including the compressor station, meter stations, 

and launcher/receivers would affect upland forest, pine plantation, open land, and developed 

land. Construction would permanently remove vegetation at each site during the installation of 

buildings, equipment, and hardened surfaces such as paved or gravel access roads and parking 

areas. Construction of the aboveground facilities would permanently convert about 4.64 acres of 

upland forest, 26.97 acres of pine plantation, and 1.05 acres of open land to natural gas facility 

use (see table 4.5-1). We do not consider this to be a significant impact, as this represents a very 

small percentage of the total available land of similar type in the surrounding project area. 

EEC’s use of contractor yards would temporarily affect about 11.89 acres of upland forest, 0.03 

acre of planted pine, and 109.36 acres of open land. No permanent impacts on vegetation would 

result from the use of these sites. 

4.5.2 Noxious Weeds 

Noxious weeds and other invasive plants are non-native, undesirable native, or introduced 

species that are able to exclude and out-compete desirable native species, thereby decreasing 

overall species diversity. Under the Federal Plant Protection Act of 2000 (formerly the Noxious 

Weed Act of 1974 [7 USC SS 2801-2814]), a noxious weed is defined as “any plant or plant 

product that can directly or indirectly injure or cause damage to crops, livestock, poultry, or other 

interests of agriculture, irrigation, navigation, the natural resources of the United States, the 

public health, or the environment.” The Federal Plant Protection Act contains a list of 137 

federally restricted and regulated federal noxious weeds, as per CFR Title 7, Chapter III, Part 

360, including 19 aquatic and wetland weeds, 62 parasitic weeds, and 56 terrestrial weeds. Each 

state is federally mandated to uphold the rules and regulations set forth by this Federal Plant 

Protection Act and manage its lands accordingly. 

Noxious weeds are addressed by Executive Order 13112, which directs federal agencies to 

prevent the introduction of invasive species; provide for their control; and minimize the 

economic, ecological, and human health impacts that invasive species can cause. The executive 

order further specifies that federal agencies shall not authorize, fund, or carry out actions likely 

to cause or promote the introduction or spread of invasive species in the United States or 

elsewhere unless it has been determined that the benefits of such actions outweigh the potential 
 4-46 4.0 –Environmental Impact Analysis 

harm caused by invasive species and that all feasible and prudent measures to minimize the risk 

of harm would be taken in conjunction with the actions. 

Vegetation removal and soil disturbance during construction could create optimal conditions for 

the establishment of invasive or noxious weed species. Construction equipment traveling from 

weed-infested areas into weed-free areas could disperse invasive or noxious weed seeds and 

propagates, resulting in the establishment of noxious weeds in previously weed-free areas. To 

control the spread of noxious weeds, EEC has agreed to develop an Exotic, Nuisance, and 

Invasive Plant Management Plan prior to construction and in consultation with the appropriate 

agencies and would file this Plan with the Director of OEP. EEC indicated that examples of 

some of the impact minimization measures that would be specified in its Exotic, Nuisance, and 

Invasive Plant Management Plan are: 

• areas of disturbed soils would be planted as described in EEC’s Plan and Procedures 

using herbaceous species recommended by local NRCS offices; 

• exotic plant growth in revegetated areas would be monitored by the EI and/or other 

designated EEC personnel as part of the project’s wider revegetation monitoring 

program; 

• ROW inspections would occur annually and would be documented in accordance with 

EEC’s Plan and Procedures; 

• the EIs would assess the progress and recommend measures to eradicate or control 

noxious weeds; and 

• inspections in upland areas would occur for at least two growing seasons after pipeline 

construction, and in wetlands for 5 years (or until revegetation efforts are successful) 

after pipeline construction. 

4.5.3 Vegetation Communities of Special Concern 

No vegetative communities of special concern have been identified along the proposed Elba 

Express Pipeline route. Potential habitat for special-status plant species have been identified 

along the pipeline route and are discussed in section 4.7. 

4.6 WILDLIFE AND AQUATIC RESOURCES 

4.6.1 Wildlife Habitats 

Terminal Expansion

The proposed Terminal Expansion site has two areas that contain wildlife habitat: the existing 

terminal site and berthing slip area. Wildlife habitat on the existing terminal site has been 

degraded due to previous construction activities. The terminal site habitat is that of a 

homogenized ecosystem managed in a grassed state, which occupies portions of the site that are 

not occupied by terminal facilities or paved areas. Wildlife species potentially utilizing the site 

are limited to various small rodents, lizards, insects, and possibly some passerine species. 

Grassed areas outside the fenced portion of the terminal facilities are used as grazing areas by 

deer. 
 4-47 4.0 –Environmental Impact Analysis 

Wildlife habitats at the existing berthing slip area is comprised mainly of subtidal soft sediments 

and unconsolidated intertidal flats. Subtidal soft sediment provides feeding habitat for demersal 

fish, worms, and mollusks living on and in the sediments (see section 4.6.2). Unconsolidated 

sediments found in the Savannah River Channel are considered early successional due to the 

constant disturbance from dredging maintenance, propeller wash, vessel traffic, and natural 

sedimentation. Unconsolidated subtidal habitat has been designated as EFH for penaeid shrimp 

and the snapper/grouper complex species (see section 4.6.3 and appendix J). 

Construction of the proposed Terminal Expansion facilities would affect about 179.8 acres of 

previously disturbed land. Of which, 96.4 acres are maintained grassy areas and 83.4 acres are 

paved or graveled areas. About 33.3 acres of open water, including subtidal soft sediments and 

unconsolidated intertidal flats, would also be affected at the existing berthing slip area. 

Construction of the proposed Terminal Expansion facilities would have little impact on wildlife 

due to the lack of wildlife habitat existing on the site. The maintained grass areas do not provide 

sufficient habitat to support diverse wildlife populations. Some species such as small rodents, 

lizards, and insects may be affected by the construction due to alteration in habitat and direct 

contact with construction equipment. Current and proposed routine maintenance activities at the 

terminal site would have similar but less extensive effects on wildlife species in the area, 

depending on the time of year. However, the overall impact on general wildlife would not be 

substantial because of the short duration of the activities and availability of similar habitats 

adjacent to the terminal site from which the affected species could return and recolonize the 

nearby areas. 

Dredging and pile driving activities at the existing berthing slip during construction could cause 

an increase in turbidity and noise; however, these impacts would be short-term and localized, 

thus minimizing the effect on open water species that may be in the vicinity of the slip. 

Operation of the Terminal Expansion facilities would result in a potential increase of 95 

additional LNG vessels docking and unloading LNG cargo at the Elba Island Terminal and is not 

expected to affect wildlife at and near the terminal site. 

Waterway for LNG Marine Traffic 

Potential impacts on wildlife that result from increased LNG marine traffic associated with the 

project along the transit corridor would be similar to those resulting from other vessels using the 

navigation channel. No significant impact on wildlife resources as a result of increased LNG 

marine traffic is expected within the transit corridor. Tybee National Wildlife Refuge is an 

important resting and feeding area for migratory birds including gulls, terns, neotropical 

migratory songbirds, least terns, black skimmers, Wilson’s plovers, and several other shorebird 

species have nested on the spoil deposits. The refuge’s shoreline and open spoil deposits are 

used as resting sites for brown pelicans, gulls, and terns. However, because no impacts to Tybee 

National Wildlife Refuge have been reported with Elba’s previous expansion, no impacts to any 

migratory birds would be expected by the incremental increase in LNG vessels transiting the 
 4-48 4.0 –Environmental Impact Analysis 

navigation channel. Other wildlife species along the LNG marine traffic route are discussed in 

sections 4.6.1 and 4.7 of this EIS. Sensitive wildlife areas are depicted in figure 4.12-2. 

Wildlife species within the Zones of Concern (described in section 4.12.4.3) along the Savannah 

River are consistent with species present at the terminal and along the pipeline route. If an 

unignited marine LNG spill were to occur along the transit route and contact any wildlife within 

Zone 1, it could be injured or expired. However, any mobile species would generally move 

away from the incident of LNG, thereby lessening any impacts the spill may cause to wildlife. 

Because the vaporized gas that would be released would be a cold, heavier-than-air, vapor cloud, 

birds flying over the area at the time of release could experience asphyxiation from the lack of 

oxygen. No wildlife impacts outside of Zone 1 would be expected from an unignited release of 

LNG. 

If an associated fire were to occur with the release of LNG, wildlife within Zone 1 in the vicinity 

of the fire would likely be injured or expired. Impacts to wildlife offshore would be limited to 

species that may be on the water’s surface or flying overhead at the time of a release. Impacts to 

wildlife within Zone 2 would be expected to be less than those in Zone 1. Some species may be 

impacted by radiant heat, while others may be impacted by being displaced from its home range. 

Wildlife not directly impacted by the fire may lose nesting, foraging, or mating habitat until the 

impacted area is revegetated. No impacts would be expected within Zone 3 from a pool fire. 

The maximum flammable rang for a vapor cloud could extend to the outer limits of Zone 3. If 

the vapor cloud were to come in contact with an ignition source, the resulting fire could burn 

back to the spill and impact any wildlife within its path. However, because of the marine transit 

safety and security measures (as described in sections 4.12.4 and 4.12.6 of this EIS), the 

likelihood of an LNG vessel spill from collisions, allisions and terrorist attacks would be 

extremely remote. Additionally, wildlife would be expected to return to the affected area as the 

vegetation reestablishes. 

Elba Express Pipeline

Vegetation types that provide wildlife habitat include forest, agriculture, open land, industrial 

and residential land, and wetlands. Below are some of the species that could be expected to be 

within the project area, but are not all-inclusive. 

The southern mixed hardwood-pine forests and pine plantations that would be crossed by the 

Elba Express Pipeline provide habitat for mammals including the armadillo, opossum, whitetailed deer, gray fox, short-tailed shrew, eastern cottontail rabbit, mice, eastern mole, gray 

squirrel, southern flying squirrel, bobcat, and coyote. Resident and migratory non-game bird 

species include cardinal, Carolina wren, and vultures. Game species include wild turkey, 

bobwhite quail, and mourning dove. Small songbirds utilize the forests, thickets, wetlands, and 

fields of the southern mixed hardwood-pine forests to rest and feed during migration, and in 

some cases breed. Amphibians and reptiles that can be found in the forest habitat type include 

spotted salamander, marbled salamander, ornate chorus frog, spring peeper, southern leopard 

frog, southeastern five lined skink, cricket frog, eastern fence lizard, southern ring-neck snake, 

southern black racer, eastern king snake, and eastern diamondback rattlesnake. 
 4-49 4.0 –Environmental Impact Analysis 

Open land along the pipeline route consists mainly of grasses, forbs, and shrubs. Wildlife 

associated with these areas include small mammals such as the harvest mouse, eastern mole, 

least shrew, and the eastern cottontail rabbit. Bird species include mourning dove, common 

grackle, red-winged blackbird, eastern bluebird, and red-shouldered hawk. Reptiles and 

amphibians include garter snake, southern black racer, skinks, and frogs. Industrial and 

residential areas provide limited wildlife habitat for species that utilize wooded yards and 

landscape shrubbery for forage and shelter. 

Forested and scrub/shrub wetlands provide habitat for waterfowl, wading birds, raptors, and 

large and small mammals. Typical wildlife associated with these habitats include wood ducks, 

egrets, great blue heron, hawks, eagles, white-tailed deer, swamp rabbit, raccoon, muskrat, 

beaver, and fox. Emergent wetlands provide habitat for herbivorous mammals, waterfowl, 

wading birds, fish, mussels, insects, and amphibians. 

Open water habitats are utilized by beaver, river otter, and nutria. Bird species including 

anhinga, belted kingfisher, brown pelican, wood stork, osprey, snowy egret, wood duck, and 

marsh wren and reptiles such as American alligator, cottonmouth, and turtles can be found in 

open water habitats. 

Construction of the Elba Express Pipeline, including temporary extra workspaces, would 

temporarily disturb about 2,747.96 acres of wildlife habitat during construction and would 

permanently disturb about 960.56 acres through pipeline ROW maintenance related to ongoing 

operation. Construction and operation of the aboveground facilities would permanently disturb 

about 32.00 acres of wildlife habitat. 

The impact of the Elba Express Pipeline Project on wildlife species and their habitats would vary 

depending on the requirements of each species and the existing habitat present along the pipeline 

route. The general disturbance of the ROW associated with construction activities would likely 

result in the temporary displacement of most wildlife from the immediate vicinity of the 

construction zone and adjacent areas. Clearing of the temporary construction ROW would 

reduce cover, nesting, and foraging habitat for some species and may result in mortality to less 

mobile forms of wildlife, such as small rodents and reptiles. Larger or more mobile wildlife, 

such as birds and large mammals, would leave the vicinity of the ROW as construction activities 

approach. Some nesting species and tree cavity nesting species may suffer mortality during 

ROW clearing. For those adult birds that are able to disperse from the working ROW, nesting 

success may be denied or diminished for one annual breeding cycle. The relatively slow 

regeneration of forested communities within the temporary ROW would result in the long-term 

reduction in habitat for those species that utilize these communities. However, abundant similar 

habitats are available adjacent to the proposed construction corridor. Further, species that use 

early successional shrub or forest communities may benefit from the regeneration process. 

Additionally, the non-woody vegetation may provide seeds and foliage for food for small 

mammals and birds, as well as habitat for ground-nesting birds, mammals, and reptiles. 

A variety of migratory bird species, including songbirds and raptors, utilize the vegetation 

communities found within the project area. Migratory birds are species that nest in the United 
 4-50 4.0 –Environmental Impact Analysis 

States and Canada during the summer, and then migrate south to the tropical regions of Mexico, 

Central and South America, and the Caribbean for the non-breeding season. 

The Elba Express Pipeline project is within the Southeastern Coastal Plain Bird Conservation 

Region, which includes extensive riverine swamps and marsh complexes along the Atlantic 

Coast, as well as interior forest vegetation. Priority bird species include the red-cockaded 

woodpecker, painted bunting, Bachman’s sparrow, Swainson’s Warbler, and swallow-tailed kite. 

Coastal intertidal habitats provide critical wintering areas for the American oystercatcher and 

important wintering and spring migration habitats for large numbers of herons, egrets, ibis, terns, 

and other species, as well as winter habitat for large numbers of canvasback, mallard, American 

widgeon, redhead, and the majority of the continent’s population of tundra swans. 

The Migratory Bird Treaty Act of 1918 serves to protect migratory birds from deleterious 

impacts. The project would result in a temporary reduction of habitat available to migratory 

birds. However, this effect would be mitigated by the restoration of disturbed areas following 

construction, which would make them available for use by migratory birds during the next 

nesting season following construction. Numerous wetlands and riparian systems would be 

crossed by the Elba Express Pipeline. These areas are important as year long habitats for 

numerous resident wildlife species and are used seasonally as stopovers for migrating waterfowl 

along migratory flyway routes. The degree of impact for some species using these habitats 

would depend on the season of construction. Impact on migratory waterfowl from construction 

within stopover habitat would generally only occur only if these habitats were disturbed during 

migration. Wetland and riparian habitats are also important breeding habitat for amphibians, and 

impact on breeding amphibians would generally be greater if construction took place in these 

habitats during the spring breeding season. Disturbance to these habitats would be minimized 

through implementation of EEC’s Procedures, and except for the conversion of forested riparian 

and wetland vegetation to herbaceous vegetation within the ROW, there would not be a 

permanent impact on these habitats. Construction is scheduled to begin during the summer 

months. This construction schedule could potentially result in the loss of nests. However, due to 

the availability of similar habitat types adjacent to the proposed construction right-of-way, 

locating the pipeline adjacent to existing rights-of-way for over 50 percent of the route to the 

extent practicable, and the absence of federally and state listed bird species along the pipeline 

route, we believe that impacts to migratory birds would be minimized. 

Suitable nesting habitat occurs throughout the Elba Express Pipeline Project area. Although the 

project activities could cause some migratory birds to avoid the construction areas, this impact 

would be limited to the relatively short period of active construction and is not expected to result 

in a significant or long-term change in migration patterns through the area. 

Many animals would relocate into similar habitats nearby. However, if there were a lack of 

adequate territorial space, some individuals could be forced into suboptimal habitats. This could 

increase inter- and intra-specific competition and lower reproductive success and survival. The 

influx and increased density of animals in some undisturbed areas caused by these dislocations 

could also reduce the reproductive success of animals that are not displaced by construction. 

These effects, however, would cease after completion of construction, and wildlife could return 
 4-51 4.0 –Environmental Impact Analysis 

to the newly disturbed areas and adjacent, undisturbed habitats after ROW restoration is 

completed. 

The cutting, clearing, and/or removal of existing vegetation would also affect wildlife by 

reducing the amount of available habitat. The degree of impact would depend on the type of 

habitat affected and the rate at which vegetation regenerates after construction. The impact on 

species that commonly inhabit agricultural land would be relatively minor and temporary 

because these areas are regularly disturbed and would be replanted during the next growing 

season following installation of the pipeline. The impacts on grass and shrub-dwelling species 

would be less than that of forest-dwelling species. Although the structural component of shrubdominated habitats could recover more slowly, successful restoration of non-woody vegetation 

may improve the values of forage for some wildlife within a relatively short time. 

In forested areas, the principal impact on wildlife of the increased or new ROW clearing would 

be a change in species using the ROW from those favoring large forested tracts (e.g., southern 

flying squirrel) to those using edge habitats and more open areas (e.g., white-tailed deer). The 

edges between open and wooded habitats, often termed the “edge effect,” could increase the 

diversity and density of organisms that are often found in the transitional zones where two 

ecosystems come together. Many species adapt well to this habitat reversal and take advantage 

of the increased populations of small mammals that prefer open areas. Predatory species such as 

the red-tailed hawk, coyote, and fox commonly use utility ROWs for hunting. 

Although the project may be advantageous for some species, it would create new cleared ROWs 

or widen existing cleared ROWs, which may affect some forest interior species, or species that 

prefer large tracts of unbroken forest. The breeding success of some forest interior bird species 

(e.g., warblers and thrushes) has been shown to be limited by the size of available unbroken 

forest tracts (Robbins, 1979; Robbins et al., 1989). For these species, additional loss of forest 

habitat in tracts of already marginal size could further reduce breeding success. The cleared 

ROWs may also encourage population expansion of parasitic species, such as the brown-headed 

cowbird which parasitize songbird species. The potential for this type of impact would be 

greatest where the pipelines would traverse smaller, isolated woodlots (Galli et al., 1976). It 

may also encourage population expansion of exotic species, such as the English sparrow and 

European starling, which compete with many native species. In addition, southern pine beetle is 

a persistent nuisance pest that has infested mature and dense pine plantations weakened by 

natural and human disturbances. The affects of forest fragmentation would be reduced because 

the Elba Express Pipeline route would parallel existing ROWs for approximately 56 percent of 

its length. Additionally, the southern pine beetle only impacts tree species that are injured or 

dying. EEC has committed to minimizing the damage to vegetation adjacent to the corridor, 

thereby reducing the likelihood of impacts from the southern pine beetle. The brown-headed 

cowbird, English sparrow, and European starling currently occur throughout the project range, 

and therefore would not add new impacts. 

The loss of forest habitat and the creation of open early successional and induced edge habitats in 

these woodlots could decrease the quality of habitat for forest interior species for distances up to 

300 feet from the ROW (Anderson et al., 1977; Temple, 1986). This may reduce the density and 

diversity of forest interior species in a corridor wider than the actual cleared ROWs. It is not 
 4-52 4.0 –Environmental Impact Analysis 

likely that new permanently cleared 20- to 50-foot-wide ROWs would impede the movement of 

most forest interior species, although it could reduce the breeding habitat of these species. 

Because EEC would make use of existing ROWs as much as possible and would adhere to its 

Plan and Procedures, and other measures discussed in this EIS, we believe that the Elba Express 

Pipeline Project would not substantially alter local wildlife populations, and that the impact of 

habitat fragmentation on wildlife would be minimal. 

4.6.1.1 Managed and Sensitive Wildlife Areas 

The proposed Elba Express Pipeline would cross two WMAs in Georgia: The Di-Lane 

Plantation WMA in Burke County between MPs 74.4 and 78.1 and the Clarks Hill WMA in 

Warren and McDuffie Counties between MPs 134.8 and 135.3. 

The Di-Lane Plantation WMA consists of 8,100 acres of land owned by the COE and managed 

by the GDNR. Wildlife management practices within this WMA include a 3,500 acre forest 

thinning and burning management program to enhance wildlife species (e.g., bobwhite quail), 

prescribed burning, fallow field management, hardwood control, and dove field management. 

Recreational activities include hunting, camping, interpretive trails, fishing, hiking, and bird 

watching. The Di-Lane Plantation WMA is on Georgia’s list of Important Bird Areas (IBA). An 

IBA is a place that provides essential habitat for one or more species of bird, whether in breeding 

season, winter, or during migration and are considered to be exceptionally important for bird 

conservation. In addition to providing habitat for game birds, such as bobwhite quail, mourning 

doves, and wild turkeys, the Di-Lane Plantation WMA provides habitat for many nongame birds 

such as bluebirds, sparrows, and warblers. During the late fall and early spring, large numbers of 

hawks use open fields in the area to hunt. Numerous wood ducks and a variety of other 

waterfowl roost throughout the area during the winter. Other common winter wetland birds 

include great blue and green herons and occasionally wood storks. 

The Clarks Hill WMA consists of 12,700 acres of land also owned by the COE, as part of its J. 

Strom Thurmond Project (see section 4.8.5) and managed by the GDNR. Recreational activities 

within Clarks Hill WMA consist of hunting, fishing, hiking, and bird watching. Several goose 

grazing pastures within the Clarks Hill WMA have been created by and are managed under the 

Ducks Unlimited MARSH Project (enhancement of waterfowl habitat and hunting opportunities 

in Georgia). In addition, waters within the J. Strom Thurmond Project, including the Little River 

crossed at MP 134.9, have recently been designated as an IBA. Some of the Clarks Hill pastures 

have been recently renovated and planted in a fresh mixture of pasture grasses and legumes. 

These areas are regularly limed and fertilized to provide soil nutrients for optimum plant growth 

and offer an attractive site for geese to feed and congregate during the late waterfowl season. 

EEC stated that it has initiated consultation with the Di-Lane Plantation and Clarks Hill WMA 

managers regarding field surveys, easement acquisitions, and permitting processes. Our review 

of the pipeline route in these areas indicates that active construction could impact recreational 

activities within these WMAs. See section 4.8.5 for further information on these sensitive areas 

and our recommended mitigation measures. About 53.7 acres of COE Project and Mitigation 

Lands would be crossed by the proposed project at the crossings of Di-Lane Plantation WMA, 
 4-53 4.0 –Environmental Impact Analysis 

Little River, Richard B Russell Lake/Beaverdam Creek, Coldwater Creek, and Savannah River. 

These crossings would be done in accordance with EEC’s Plan and Procedures, as well as any 

landowner agreements. 

4.6.2 Aquatic Resources 

Terminal Expansion

Surface waters affected by the construction of the proposed Terminal Expansion facilities are 

intertidal estuarine environments that support an estuarine fishery. Typical recreational fish 

species are listed in table 4.6-1. Impacts on sensitive fisheries and EFH are further described in 

section 4.6.3 below. Impacts on surface waters and special status species are discussed in detail 

in sections 4.3.3 and 4.7, respectively. 

TABLE 4.6-1

Recreational Fish Species near the Proposed Terminal Expansion Facilities 

Common Name Scientific Name Classification 

SPECIES 

Spotted Sea Trout Cynoscion nebulosus Warmwater/Recreational 

Red Drum Sciaenops ocellatus Warmwater/Recreational 

White Shrimp Penaeus aztecus Warmwater/Recreational 

Brown Shrimp Penaeus setiferus Warmwater/Recreational 

Blue Crab Callinectes sapidus Warmwater/Recreational 

Striped Bass Morone saxatilis Recreational 

Cobia Rachycentron canadum Recreational 

Spanish Mackerel Scomberomorus maculatus Recreational 

Bluefish Pomotomus saltatrix Recreational 

Summer Flounder Paralichthys dentatus Recreational 

Atlantic Sharpnose Shark Rhizoprionodon terraenovae Recreational 

Snapper/Grouper Lutjanus/Epinephelus, Mycteroperca Recreational 

With the exception of spotted sea trout, blue crab, and striped bass all of the recreational fish 

species identified in table 4.6-1 are further discussed in section 4.6.3 and appendix J. 

Spotted seatrout occur from Cape Cod, Massachusetts to the Florida Keys, but are most abundant 

from the Chesapeake Bay southward. They are found primarily in estuaries, but move into 

nearshore ocean waters during cold periods. In general, spotted seatrout appear to be nonmigratory and spend their entire life within five to ten miles of their natal estuary. Small tidal 

marsh creeks and shallow grass beds are the most important nursery grounds for the young, 

while larger juveniles are widely distributed in estuarine areas and along coastal beaches. Adults 

frequent grass beds, live oyster beds, creek mouths, drop-offs, and structures such as jetties, 

stumps, pilings, and wrecks, where they primarily feed on shrimp and fish. They are most 

abundant in depths of less than ten feet, prefer a temperature between 60 to 80° F, tolerate a 
 4-54 4.0 –Environmental Impact Analysis 

range of salinities. Spotted seatrout spawn from April to September around inlets (Species 

Profile: Spotted Seatrout, 2007). 

Blue crab occur from Nova Scotia to Florida and Texas; Bermuda; West Indies to Uruguay. 

Blue crabs are estuarine dependent and its life history involves a complex cycle of planktonic, 

nektonic, and benthic stages, which occur throughout the estuarine-nearshore marine 

environment. Spawning females and larval stages inhabit lower estuarine and adjacent marine 

waters and later stage larvae exist mainly in more open waters. Juvenile blue crabs exhibit wide 

seasonal and aerial distribution within the estuary but are associated with waters of low to 

intermediate salinity and soft-mud sediment bottom types, often adjacent to vegetated habitats. 

Adult blue crabs are widely distributed and occur on a variety of bottom types in fresh, estuarine, 

and shallow oceanic waters. Larger sized blue crabs are more prevalent in larger bays and 

bayous. Although adult blue crabs are ubiquitous throughout an estuarine system, they are 

distributed seasonally with respect to salinity and sex (Blue Crab Home Page, 2007). 

Striped bass are anadromous species. In Georgia waters, spawning occurs during April and May. 

They migrate from their salt water habitat as much as 180 miles upstream to find swift, 

freshwater currents suitable for spawning. At least 50-miles of free-flowing river are necessary 

for striped bass eggs to hatch successfully. Striped bass stocked into freshwater lakes also make 

spawning migrations to the headwaters. Striped bass congregate in schools which roam the open 

waters of lakes, coastal rivers, and embayments to forage. Striped bass management efforts in 

Georgia include annual population surveys, setting protective size and creel limits, protecting 

spawning habitat and water quality, and producing fingerling striped bass in hatcheries for 

stocking into reservoirs and coastal rivers. Coastal populations of striped bass in the Savannah 

River, in southeast Georgia, are maintained by annual stocking (GDNR, 2007). 

Elba Express Pipeline

The proposed Elba Express Pipeline would cross 352 surface waters, including 161 perennial 

stream/river crossings, 150 intermittent/ephemeral stream crossings, 11 ponds and 30 manmade 

ditches. Appendix H provides a list of the waterbodies crossed and state fishery classification. 

Of the total waterbodies that would be crossed by the proposed pipeline, 5 are 100 feet wide or 

greater and are considered major waterbodies (Little River, Broad River, Beaverdam Creek 

[Richard B. Russell Lake], Coldwater Creek, and the Savannah River. The Savannah River is 

the only waterbody known to contain federally listed species. Special status fish species are 

discussed in section 4.7. 

With the exception of the Savannah River, all waterbodies crossed by the Elba Express Pipeline 

are warmwater fisheries. Typical warmwater fish species found in the project area include 

largemouth bass, spotted bass, bream, black crappie, spotted suckers, blue and channel catfish, 

darters, minnows, drum, spotted gar, and eels. Warmwater invertebrates include mussels, and 

white river crayfish. The waters of the Savannah River downstream of the Lake Hartwell Dam 

to the headwaters of Richard B. Russell Lake are considered a Trout-Put, Grow, and Take by the 

South Carolina Department of Health and Environmental Control. The GDNR considers these 

waters a “Secondary Trout Stream” which are capable of supporting trout year-round but there 

has been no evidence of reproduction. 
 4-55 4.0 –Environmental Impact Analysis 

4.6.2.1 Fish and Invertebrates 

Fish and invertebrate species found in the Savannah River and South Channel near the Terminal 

Expansion site and waterbodies crossed by the Elba Express Pipeline are presented in section 

4.6.2. No coral reefs occur within the Terminal Expansion site or along the waterway for LNG 

marine traffic. 

The NOAA Fisheries, the South Atlantic Fishery Management Council (SAFMC), and the MidAtlantic Fishery Management Council (MAFMC) have identified EFH in the vicinity of the 

proposed Terminal Expansion facilities. Impacts on sensitive fisheries and EFH are further 

described in section 4.6.3 and appendix J. 

4.6.2.2 Construction Impacts to Aquatic Resources 

Terminal Expansion

Construction of the proposed Terminal Expansion facilities would require the dredging of 

approximately 72,000 cubic yards of material from Southern LNG’s existing berth on the 

Savannah River, to modify the slope at the toe of the berthing slip and install a sheet pile 

bulkhead. In addition, four mooring dolphins would be installed in the existing berthing slip 

area. Impacts to aquatic resources would occur as a result of these modifications to the existing 

berthing slip area. Impacts on sensitive fisheries and EFH are further described in section 4.6.3 

and appendix J. Impacts on surface waters and special status species are discussed in detail in 

sections 4.3.3 and 4.7, respectively. No other waterbodies that support aquatic resources occur 

on the terminal site. 

Construction activities along the boundaries of the existing berthing slip area could result in 

siltation at the water’s edge and temporarily increase turbidity and/or the suspension of solids 

within the water column. Increases in turbidity can affect fish physiology and/or behavior. 

Potential physiological effects include mechanical abrasion of surface membranes, delayed larval 

and embryonic development, reduced bivalve pumping rates, and interference with respiratory 

functions. Possible behavioral effects from increased turbidity include interference with feeding 

for sight-foraging fish and area avoidance. Alternately, the reduced visibility of predatory fish 

could lower vulnerability to predation for prey species. Turbidity tends to interfere with light 

penetration and thus reduces photosynthetic activity by phytoplankton. Such reductions in 

primary production would be localized around the immediate area of the existing berthing slip 

and would be limited to the duration of the sedimentation plume at the existing berthing slip. 

Excessive nutrient loading from sediment resuspension could also have an adverse impact upon 

the harbor because it could cause dramatic increases in the productivity of planktonic algal 

populations. The particles that would be resuspended as a result of dredging are fine silt and 

clays that would wash out of the channel before settling. If particles are suspended higher in the 

water column, or in deeper water, the settling time and distance would be greater. EEC would 

comply with any project-specific recommendations or requirements to minimize suspension of 

sediments that are attached to dredging permits. In general, impacts of dredging on water 
 4-56 4.0 –Environmental Impact Analysis 

turbidity are expected to be localized, short-term, and minor. These impacts would likely be 

similar to current maintenance dredging impacts associated with the berthing slip. 

Southern LNG would use a hydrolic cutterhead dredge for its proposed berth modifications. 

This activity within the existing berthing slip would cause some sediment to become suspended 

and would increase turbidity temporarily, lowering the water quality within a localized area of 

the dredging activities. The Savannah River has a naturally high suspended sediment load 

which, during storm events, is expected to increase well beyond the 200 mg/L increase typically 

created by a hydraulic dredge. In addition, during storm events the higher suspended sediment 

loads would likely be more uniform throughout the water column due to mixing as the sediment 

proceeds downstream. Therefore, the potential effects of increased suspended sediments would 

be short term and insignificant, due to the relatively short duration of construction. 

Southern LNG would conduct water sampling before and throughout dredging operations to 

ensure that standards specified in its previous COE permit would not be exceeded for total 

suspended solids or dissolved oxygen. 

In its comments on the draft EIS, Southern LNG indicated that it would use a vibratory hammer 

to install sheet piling at the toe of the existing berthing slip and conventional diesel pile drivers 

to install two mooring dolphins located in open water at the mouth of the slip, about 0.3- and 0.4- 

mile from the South Carolina shoreline. Pile driving activities, in some cases, can generate 

intense underwater sound pressure waves that can adversely affect nearby marine organisms 

including marine mammals, sea turtles, and fish. Although the effects of pile driving are poorly 

studied and there appears to be substantial variation in a species’ response to sound, intense 

sound pressure waves can change fish behavior or injure/kill fish through rupturing swim 

bladders or causing internal hemorrhaging. The degree to which an individual fish exposed to 

sound waves would be affected is dependent upon variables such as the peak sound pressure 

level and frequency as well as the species, size, and condition of a fish (e.g., small fish are more 

prone to injury by intense sound waves than are larger fish of the same species). In some cases, 

sound pressure levels greater than 155 decibels can elicit avoidance behaviors or stun small fish 

(NOAA Fisheries, 2003). Sounds greater than 190 decibels are thought to physically injure some 

fish (Hastings, 2002). The presence of predators can also influence how a fish might be affected 

by pile driving (e.g., fish stunned by pile driving activities may be more susceptible to 

predators). 

The Atlantic bottlenose dolphin is common along the coast of Georgia and near the mouth of the 

Savannah River. Southern LNG indicated that pile driving activities could affect local bottlenose 

dolphin populations by masking dolphin vocalizations; however, these impacts would be 

minimized due the bottlenose dolphin’s directional hearing and ability to adjust vocalization 

amplitude and frequency, and the structured content of bottlenose dolphin echolocation signals. 

Since bottlenose dolphins are known to inhabit the Savannah River area, where construction and 

operational noise from other sources already exists, it is expected that this species will continue 

to forage within and near the Savannah River despite the additional noise generated from pile 

driving activities at the Terminal Expansion site. 
 4-57 4.0 –Environmental Impact Analysis 

The intensity of the sound pressure levels produced during pile driving depends on a variety of 

factors including, but not limited to, the type and size of the pile, the firmness of the substrate 

into which the pile is being driven, the depth of water, and the type and size of the pile driving 

hammer. For example, driving hollow steel piles with impact hammers produce intense, sharp 

spikes of sound that can injure fish. In some cases, fish may be startled by the first few strikes of 

an impact hammer. However, this response can wane and the fish may remain in the area 

(NOAA Fisheries, 2001). As such, the potential effect on fish from impact hammers could be 

magnified since fish would not only be exposed to intense sound waves but may not avoid pile 

driving activities, which would prolong their exposure to the potentially harmful sounds and 

increase their risk of injury or death. In a review of studies documenting fish kills associated 

with pile driving, NOAA Fisheries (2003) reported that all fish kills were during use of an 

impact hammer on hollow steel piles. 

Driving steel pipe piles with an impact hammer in similar settings has been shown to generate 

sound levels from 192 to 194 decibels, above the level that is thought to injure some fish. 

Depending on the specific conditions at the site, these sounds can have a transmission loss rate of 

0.021 to 0.046 decibels per foot (Nedwell and Edwards, 2002; Nedwell et al., 2003). Based on 

these values, the use of an impact hammer could generate underwater sound levels great enough 

to affect some fish as far as 190 feet (i.e., 190 decibels) and 1,860 feet (i.e., 155 decibels) from a 

steel pile. Although the sound waves of the greatest intensity would be limited to the immediate 

vicinity of the piles within the existing berthing slip, sound levels of 155 decibels could extend to 

the far shore of the Savannah River while piles are being driven. Southern LNG indicated that it 

would use concrete piles which generate less noise that steel piles because concrete has a less 

resonant quality than steel, an octagonal or square shaped concrete pile is less efficient at 

transmitting sound than a cylindrical steel pile, and concrete piles are typically smaller than steel 

piles. Typically, steel hammers to drive steel piles generate more noise (220 decibel peaks at 33 

feet) than steel hammers used to drive concrete piles (180 to 195 decibel peaks at 33 feet). 

Southern LNG indicated in its filing that the sound level at 50 feet from the pile driving 

equipment would be 210 db re 1μPa which is greater than the 195 1μPa which would be 

expected to elicit avoidance behavior in most species. Therefore, we believe impacts from pile 

driving activities could be exceeded. 

In its comments on the draft EIS, Southern LNG and NMFS indicated that they were in 

consultation regarding these pile driving concerns and are determining mitigation measures to 

further reduce the potential to harm fish in the vicinity of pile driving activities at the two open 

water mooring dolphins located at the mouth of the berthing slip, about 0.3- and 0.4- mile from 

the South Carolina shoreline. These measure could include a start-stop procedure which would 

allow the operator to control the vibration frequency of pile driver apparatus or a soft-start 

procedure in which pile driving would be initiated at an energy level less than full capacity (i.e., 

approximately 40 to 60 percent energy levels) for at least 5 minutes before gradually escalate to 

full capacity. 

Although the area may be used for foraging, the impact area would be small and any behavioral 

avoidance would not be expected to reduce the foraging success of any listed species since ample 

foraging habitat is available in the surrounding area. However, the potential for auditory injury 

exists for any animals within close range of the pile driving activity. In addition to the potential 
 4-58 4.0 –Environmental Impact Analysis 

for harm from pile driving noise and other general marine construction activities are expected to 

occur intermittently over a period of several months. During this period, sea turtles and fish may 

be affected by the operation of boats and equipment associated with expansion of the marine 

terminal. To reduce the potential of harm from pile driving and any long-term, intermittent 

disturbance to these species resulting from the construction activities, Southern LNG has 

developed a Marine Species Protection Plan that would reduce any potential impacts to 

discountable levels. This plan includes the following measures: 

• inform all construction personnel associated with the Project that there are civil and 

criminal penalties for harming, harassing, or killing sea turtles and/or dolphins, which are 

protected under the ESA and the MMPA and the responsible party would be held 

accountable for any sea turtle or dolphin harmed, harassed, or killed as a result of pile 

driving activities; 

• all vessels associated with pile driving work would operate at “no wake/idle” speeds at all 

times while in water where the drafts of the vessels provide less than 4 feet clearance 

from the bottom and would follow routes of deep water whenever possible; 

• the power (or fuel setting) of the hammer should be reduced to the minimum energy level 

required to drive the piles thereby reducing the amount of noise produced in the marine 

environment; 

• ensure that no impact hammering in open water would be initiated upon the sighting of 

sea turtles or dolphins within 328 feet of the Project area. Surveillance of the 328-foot 

boundary would start 10 to 15 minutes prior to pile driving as this distance would provide 

a buffer zone three times the area over which it has been concluded is the potential 

physical harm distance. If observed, impact hammering would be delayed until the sea 

turtles or dolphins have not been seen in the Project area for at least 30 minutes. 

• any collision with or noted injury to a sea turtle or dolphin would be reported 

immediately to the COE, GDNR, and the NMFS; 

• the pile driving contractor would keep a log detailing sightings, collisions, or injury to sea 

turtles or dolphins that occur during the contract period; 

• if dead or injured protected species are observed and are unrelated to the Project, they 

would be reported, as requested, to the local stranding network contacts while all other 

observed dead or injured protected species would be reported to NMFS’s Southeast 

Regional Office; and 

• upon Project completion, a report summarizing all incidents and sightings would be 

submitted to the NMFS’s Southeast Regional Office. 

Because consultation is not yet complete, we recommend that Southern LNG continue to 

consult with NMFS to minimize noise impacts associated with pile driving activities and file 

the results of this consultation with the Secretary prior to construction.
 4-59 4.0 –Environmental Impact Analysis 

Hydrostatic test water intakes would be appropriately screened with a 1/2-inch wire-mesh to 

prevent the entrainment of large particles during hydrostatic test water withdrawal. To prevent 

the impingement/entrainment of fish species on the screens, screen boxes would be sized such 

that the velocity of the inflowing water at the screen surface would be significantly less than the 

typical maximum swimming velocities of adult fish species of concern in the Savannah River 

(less than 0.5 foot per second). Additionally, Southern LNG has agreed to place intakes at a 

depth recommended by appropriate agencies to further reduce the possibility of entraining eggs, 

ichthyoplankton, and fish larvae. Further, we have recommended that Southern LNG not 

conduct hydrostatic test water withdrawals for LNG storage tank testing in estuarine habitats 

from April 1 through July 31. Hydrostatic testwater discharges would be into an aboveground 

structure and allowed to flow into the South Channel of the Savannah River in accordance with 

permit requirements. Hydrostatic testing is further discussed in section 4.3.3. No chemicals 

would be added to the hydrostatic test water before or after testing. Therefore, we believe there 

would be no significant impacts on aquatic species or habitats as a result of discharging 

hydrostatic test water. 

Elba Express Pipeline

Impacts on fisheries resources resulting from pipeline construction activities at waterbody 

crossings can include sedimentation and turbidity, alteration or removal of instream and stream 

bank cover, introduction of water pollutants, or entrainment of small organisms during 

hydrostatic testing. Studies generally have indicated that pipeline construction through 

waterbodies results in temporary impacts on streams and rivers, and that there are no long-term 

effects on water temperature, pH, dissolved oxygen, benthic invertebrate populations, or fish 

populations (Vinkour and Shubert, 1987; Blais and Simpson, 1997). 

EEC proposes to open-cut all perennial waterbody crossings except two manmade ditches and 

two unnamed intermittent streams associated with the crossing of Georgia State Highway 21 at 

MP 0.1, which would be conventionally bored, the Broad River at MP 161.0 and the Savannah 

River at MP 187.5, which would be crossed by the HDD method. 

An open-cut crossing would result in short-term increases in turbidity and siltation downstream 

of the pipeline crossing sites. The concentration of suspended solids would decrease rapidly 

following the completion of in-stream work. The increased siltation may cause decreased flow 

of oxygenated water to benthic organisms and fish eggs, resulting in degradation of benthic and 

spawning habitat. Direct loss of spawning habitat, benthic invertebrates, and protective cover 

may occur at the pipeline crossing location due to trenching and backfilling. However, any 

sedimentation and turbidity resulting from construction would be short-term. Where feasible, 

waterbody crossings would occur during periods of low or no-flow. EEC would construct all 

waterbody crossings in accordance with the construction and mitigation measures in its 

Procedures. EEC’s Procedures require completion of most instream work within 24 hours for 

waterbodies 10 feet wide or less, and within 48 hours for streams between 10 and 100 feet 

in width. 
 4-60 4.0 –Environmental Impact Analysis 

EEC has requested permission from the FWS, GDNR, and SCDNR, to conduct stream crossings 

in warmwater fisheries during all months of the year. In its comments on the draft EIS, EEC 

indicated that GDNR provided authorization for construction in warm water fisheries during all 

months of the year provided construction takes place during normal or low water levels. In 

South Carolina, EEC would cross the Savannah River and an intermittent stream by the HDD 

method. EEC states within its Procedures, it would use its discretion to utilize the most 

appropriate crossing method for the location during a time period within its construction 

schedule. This is in accordance with our Wetland and Waterbody Construction and Mitigation 

Procedures which state, construction within warmwater streams should occur from June 1 

through November 30 unless expressly permitted by the appropriate state agencies (i.e., GDNR) 

in writing on a site-specific basis to provide these waterbodies greater protection. 

Use of EEC’s Procedures would reduce impacts on fisheries from construction-induced 

sedimentation and turbidity. Trench spoil would be stored within the approved ROW on or 

above the stream banks at least 10 feet from the water’s edge. Temporary erosion control 

devices would be installed around spoil piles to minimize the potential for sediment-laden water 

to enter the stream. Additionally, all staging and temporary workspace areas would be located at 

least 50 feet back from the water’s edge where topographic conditions permit (unless otherwise 

permitted), thus minimizing the potential for erosion and sedimentation along the stream banks. 

Impacts on water quality from the open-cut crossing would be short-term and suspended 

sediment concentrations would be expected to return to pre-construction levels soon after 

construction across the waterbody is completed. Because of EEC’s proposed use of its 

Procedures, impact on fish and other freshwater aquatic organisms is expected to be very 

localized and short-term. 

Hydrostatic testing the integrity of the completed pipelines would occur following construction, 

which would require water to be withdrawn from surface waterbodies in close proximity to the 

pipeline (see table 4.3-1). Water withdrawal could potentially entrain fish eggs and juvenile fish. 

To minimize the potential for this impact, EEC would implement its Procedures, which include 

covering the intake hose with an adequately sized mesh screen to reduce the potential for fish 

and fish egg entrainment. Therefore, impacts to the fisheries resources from hydrostatic testing 

would be minimal with the use of these preventative measures. 

To minimize the potential for spills, EEC would implement the project-wide Spill Plan, and it’s 

Procedures which include spill prevention and response guidelines. 

4.6.2.3 Operational Impacts to Aquatic Resources 

Terminal Expansion

Species at the terminal and along the vessel transit route are described above in sections 4.6.2, 

4.6.3, and 4.7. Operation of the proposed Terminal Expansion facilities would result in a 

potential increase of 95 additional LNG vessels docking and unloading LNG cargo at the Elba 

Island Terminal. The additional LNG vessels would traverse the Savannah River transit 

corridor, dock, and offload LNG cargo in the same manner as existing LNG marine traffic that 
 4-61 4.0 –Environmental Impact Analysis 

currently calls on the terminal. However, the LNG vessels would take on ballast water while 

discharging LNG cargo in order to maintain a constant draft at the berth. Aquatic species in the 

immediate vicinity of the vessels berth could be impacted by entrainment during ballast water 

intake. Ballast water intakes on LNG vessels are near the bottom of the vessels, therefore 

entrainment would be limited to organisms in the deeper water column (25-30 feet below the 

surface) near the bottom of the basin. Ballast water intake by additional vessels at the terminal 

would be similar to ballast water intake by vessels that currently call on the terminal, as well as 

others that unload cargo at other points of call along the Savannah River and this impact would 

not add appreciably to current impacts. In addition to water withdrawal for ballast, LNG vessels 

may also withdraw water for cooling vessels boilers. Steam-powered vessels require more 

cooling water than comparably sized diesel-powered vessels. It is estimated that a steampowered LNG vessel moored at the terminal would intake and discharge approximately 9,842 

cubic meters per hour, or a total of 57 million gallons, to completely off-load (an operation 

lasting approximately 22 hours). Southern LNG has stated that it would minimize the volume of 

water that would be used for vessel operations while at the berth. 

Southern LNG indicated that striped bass and red drum were identified as particular species with 

eggs and larvae that could be affected by ballast and cooling water intakes, and the withdrawal of 

hydrostatic test water. Although spawning within the Savannah River could occur for red drum, 

no specific spawning grounds or migration patterns are known to exist (see appendix J). In its 

comments on the draft EIS, NMFS indicated that red drum larvae from eggs released near the 

mouth of the Savannah River are likely to be carried up river to the terminal location. Since red 

drum larvae are buoyant and float on or near the waters surface, impacts from water withdrawals 

at or near the bottom of vessels for ballast or cooling water would not be expected to have a 

significant impact on this species. NMFS also indicated that juvenile white shrimp may use 

adjacent salt marsh and subtidal mudflats for feeding and nursery. As stated in appendix J, white 

shrimp are common in the project area and prefer a more unconsolidated muddy substrate. No 

Habitat Areas of Particular Concern have been identified for shrimp in the proposed project area. 

Further, impacts from dredging operations (such as turbidity) would be minimal, localized, and 

short term. Impacts associated with vessel water withdrawal activities would be similar to those 

currently existing at the terminal and along the Savannah River. In addition, no salt marsh 

habitat would be disturbed by the expansion of Southern LNG’s terminal. The GDNR’s 

recovery program for striped bass includes restoration of the fishery to the Savannah River. It is 

unlikely that viable striped bass eggs or larvae would be affected by ballast water intake, or 

withdrawal of the hydrostatic test water, since eggs and larvae require lower salinities than is 

found around Elba Island. Southern LNG indicated that during a 2003 USGS study conducted 

near the southern end of Elba Island, no juvenile or adult striped bass were caught. All larvae 

were caught in oligohaline and tidal freshwater habitats which do not occur near Elba Island. 

This finding was further confirmed in a study conducted by the Georgia Cooperative Fish and 

Wildlife Research Unit during 2001. Therefore, we do not believe that striped bass would be 

affected by ballast and cooling water intakes, or the withdrawal of hydrostatic test water. 

The LNG vessels would take on seawater ballast while discharging LNG cargo in order to 

maintain a constant draft at the berth. Aquatic species in the immediate vicinity of the vessel 

berth could be impacted by entrainment during ballast water intake. Ballast water intakes on 

LNG vessels are near the bottom of the vessels, therefore entrainment would be limited to 
 4-62 4.0 –Environmental Impact Analysis 

organisms in the deeper water column (25-30 feet below the surface) near the bottom of the 

basin. Additionally, the ballast water intakes have bars spaced 0.5-inch apart to further reduce 

the entrainment of fish species. Egg and larvae counts along major rivers indicate they are 

mainly concentrated along the river banks. However, the potential to entrain plankton, fish eggs, 

and larvae still exists. Ballast water intake by additional vessels at Southern LNG’s Terminal 

would be similar to intake by vessels that currently call on the terminal, as well as others that 

unload cargo at other points of call within the Savannah River. While it is unknown as to the 

total impact from ballast and cooling water to eggs and larvae, we would not expect these 

additional vessels to add appreciably to current impacts. In addition to water withdrawal for 

ballast, LNG vessels may also withdraw water for cooling vessels boilers. The specific volumes 

needed for this operation are not available; however, based on the limited annual LNG vessel 

traffic, it would not result in appreciative impacts beyond that described for ballast water intake. 

Cooling water intakes are typically located adjacent to and at the same approximate depth as 

ballast water intakes. Based on the fact that the screening and flow control measures used for 

ballast water uptake would also be used for cooling water uptake to allow most juvenile and 

adult fish species to escape the intakes, we do not believe that impingement and entrainment 

would be a significant concern. 

LNG vessels calling from international ports could potentially introduce aquatic invasive species 

into U.S. waters. However, LNG vessels would be fully loaded with LNG when arriving at Elba 

Island. No releases of ballast water would occur within the Savannah River from these LNG 

vessels; therefore, no impacts on aquatic species or habitats would occur as a result of discharge 

of LNG vessel ballast water. It is expected that any LNG vessels calling on the terminal would 

be in full compliance with the domestic requirements for ballast water management as specified 

in the National Invasive Species Act of 1996 and international standards that were adopted on 

February 13, 2004. 

In addition, the Coast Guard has developed responses to exotic/invasive species associated with 

foreign vessels and its Office of Operating and Environmental Standards developed Mandatory 

Practices for All Vessels with Ballast Tanks on All Waters of the United States. The mandatory 

practices include requirements to rinse anchors and anchor chains during retrieval to remove 

organisms and sediments at their place of origin and to remove fouling organisms that may be 

affixed to vessel hulls, piping, and tanks. The removal of organisms would be conducted on a 

regular basis and the disposal of any removed substances would be in accordance with local, 

state, and federal regulations. Therefore, we conclude that the introduction of non-indigenous 

attached species via vessel hulls is not likely to significantly alter the local biotic community. 

Potentially adverse effects from the proposed LNG expansion are associated with vessel strikes 

to marine mammals protected under the Marine Mammal Protection Act (MMPA). Adverse 

reactions by whales to vessel activity have been recorded, and all are vulnerable to collisions 

with vessels, with incidents of strikes with juveniles and caves occurring more frequently than 

with adult animals. Some individuals may be able to detect and avoid underway vessels; 

however, the behavior of some individuals and age classes may result in an increased 

vulnerability to disturbance from vessels operating at speeds over 10 knots. 
 4-63 4.0 –Environmental Impact Analysis 

Waterway for LNG Marine Traffic 

Potential impacts on aquatic resources that result from an increase in LNG marine traffic 

associated with the project would be similar to those resulting from current LNG vessels as well 

as other vessels using the navigation channel. Aquatic resources at the terminal and along the 

waterway are described further in section 4.6.2.1. The threatened and endangered species 

discussion is within section 4.7 and Essential Fish Habitat is discussed within section 4.6.3 and 

appendix J. Entrainment of fish eggs and larvae would be possible during transit as a result of 

the withdrawal of water for vessel engine cooling. However, because vessels would be 

constantly moving, this impact would be minimal at any specific location and insignificant along 

the waterway for LNG marine traffic. Section 4.6.2.3 further describes impacts associated with 

cooling water withdrawal. Tybee National Wildlife Refuge is adjacent to the proposed transit 

route. Because the previous LNG terminal expansion appears to have had no effect on Tybee 

National Wildlife Refuge, the small increase in vessel traffic associated with this proposed 

expansion (3 percent) would not be expected to significantly affect the habitat, fish, or wildlife of 

the Tybee National Wildlife Refuge either. No significant impact on aquatic resources as a result 

of increased LNG marine traffic is expected within the transit corridor. Some behavioral effects 

could occur during vessel transit, particularly with dolphins. Dolphins often approach vessels 

that are in transit to bowride. Bottlenose dolphins appear to have longer interbreath intervals, 

decreased interanimal distances, heading changes, and increased swimming speed in response to 

approaching boats. Shipping vessels may increase the noise levels within the water column. 

These noise increases have been shown to impact a variety of species, such as whales, dolphins, 

and manatees. However, the transit corridor entering the Savannah River and the river itself are 

used quite heavily, and the incremental increase in shipping traffic would have minimal effects 

on those species. Further, Southern LNG has agreed to include the NOAA Fisheries Vessel 

Strike Avoidance Policy (see appendix K) as part of its Terminal Use Agreement with LNG 

vessel operators. This would reduce the possibility of marine mammals or sea turtles being 

impacted by the proposed expansion (either by collisions or noise impacts). 

As offshore vessels approach barrier island habitat, there is a potential that vessel wake, 

combined with wind-wave action and scour effects from the channel, could lead to bank erosion. 

This has the potential to disturb shorebird and sea turtle nesting habitat. However, as discussed 

earlier, Southern LNG’s previous expansion project has not been reported to have affected the 

Tybee National Wildlife Refuge located within the river mouth, and this project would result in a 

similar increase in vessel traffic. Increased vessel traffic may temporarily disturb sargassum 

habitat if present within the navigation corridor. However, vessel activities would not result in 

the harvest of sargassum habitat and would be expected to be intermittent with minor and 

localized impacts. 

If an unignited LNG spill were to occur along the transit route, given that LNG is lighter than 

water, the LNG would float on the water until it had vaporized, possibly reaching shore. The 

primary impact on aquatic resources (i.e., fish, turtles, whales, etc.) would be LNG rapidly 

boiling upon contact with water, resulting in the rapid cooling of the water within the LNG pool, 

located within Zone 1 (Zones of Concern are described in section 4.12.4.3 of this EIS). If the 

LNG were to contact any aquatic species within Zone 1, the species could be injured or expired. 

Further, because the colder water would be more dense than the ambient water, it would sink to 
 4-64 4.0 –Environmental Impact Analysis 

the bottom and could affect the benthos in the area of the incident. Mobile species would be 

expected to move from the area until water temperatures return to normal. However, non-mobile 

species, such as oysters, could be subjected to the cold (the further from the spill, the less water 

temperatures would be affected). The oysters within the zones of concern are Crassostrea 

virginica and able to withstand a wide range of temperatures. Sea turtles however are sensitive 

to temperature changes, and would be expected to avoid the area, if possible, until temperatures 

returned to ambient levels. If an associated fire were to occur with the release of LNG, impacts 

to species within Zone 1 would be limited to species on or near the water’s surface in the vicinity 

of the fire. Radiant heat within Zone 2 may impact some species on the water’s surface. Impacts 

to Tybee National Wildlife Refuge (such as burning of vegetation and increased sedimentation 

caused by an associated fire) could impact many species, such as nesting turtles. No impacts 

would be expected on species within Zone 3 from a pool fire. The maximum flammable range 

for a vapor cloud could extend to the outer limits of Zone 3. If the vapor cloud were to come in 

contact with an ignition source, the resulting fire could burn back to the spill and impact any 

species on the surface within its path. However, because of the marine transit safety and security 

measures (as described in sections 4.12.4 and 4.12.6 of this EIS), the likelihood of a LNG vessel 

spill from collisions, allisions and terrorist attacks would be extremely remote. Further, species 

that reside in deep water would likely be unaffected or temporarily affected from a spill or 

resulting fire. 

Elba Express Pipeline

Restoration of the pipeline ROW would minimize erosion potential relative to waterbodies. 

Impacts on aquatic resources are not anticipated during pipeline operation. Adherence to EEC’s 

Plan and Procedures would allow for the continued re-growth of vegetation along the edges of 

the waterbodies minimizing long-term effects to fisheries. 

4.6.3 Essential Fish Habitat 

In 1996, new habitat conservation provisions were added to the MSFCMA that mandated the 

identification of EFH for managed species. EFH is defined as “those waters and substrate 

necessary to fish for spawning, breeding, feeding, or growth to maturity” (16 USC 1802(10)). 

The MSFCMA granted the NOAA Fisheries legislative authority for fisheries regulation in the 

United States within a jurisdictional area located between 3 and 200 miles offshore, depending 

on geographical location. NOAA Fisheries was also granted legislative authority to establish 

eight regional fishery management councils, each responsible for the proper management and 

harvest of finfish and shellfish resources within their respective geographic regions. Fishery 

management councils developed Fisheries Management Plans (FMP), which outline measures to 

ensure the proper management and harvest of finfish and shellfish within these waters. The 

Savannah River estuary associated with the Terminal Expansion site lies within the management 

jurisdiction of the SAFMC and MAFMC. 

Federal agencies that authorize, fund, or undertake activities that may adversely impact EFH 

must consult with the NOAA Fisheries. Although absolute criteria have not been established for 

conducting EFH consultations, NOAA Fisheries recommends consolidated EFH consultations 

with interagency coordination procedures required by other statutes, such as the NEPA and ESA, 
 4-65 4.0 –Environmental Impact Analysis 

to reduce duplication and improve efficiency. Generally, the EFH consultation process includes 

the following steps: 

1. Notification – The action agency should clearly state the process being used for EFH 

consultations (e.g., incorporating EFH consultation into the EIS or Rivers and Harbors 

Act Section 10 permit). 

2. EFH Assessment – The action agency should prepare an EFH Assessment that includes 

both identification of affected EFH and an assessment of impacts. Specifically, the EFH 

should include: 1) a description of the proposed action; 2) an analysis of the effects 

(including cumulative effects) of the proposed action on EFH, the managed fish species, 

and major prey species; 3) the federal agency’s views regarding the effects of the action 

on EFH; and 4) proposed mitigation, if applicable. 

3. EFH Conservation Recommendations – After reviewing the EFH Assessment, NOAA 

Fisheries would provide recommendations to the action agency regarding measures that 

can be taken by that agency to conserve EFH. 

4. Agency Response – The action agency must respond to NOAA Fisheries within 30 days 

of receiving NOAA Fisheries’ recommendations. The response must include a 

description of measures proposed by the agency for avoiding, mitigating, or offsetting the 

impact of the activity on EFH. 

FERC staff proposes to incorporate EFH consultations for the Terminal Expansion facilities with 

the interagency coordination procedures required under NEPA. For purposes of reviewing this 

project under NEPA, the FERC is the lead federal agency and the COE and Coast Guard are 

cooperating agencies (see section 1.2). As such, we requested on April 17, 2007, that NOAA 

Fisheries consider the draft EIS as initiation of EFH consultation. The EFH Assessment includes 

the analysis in section 4.6 as well as the document in appendix J. NOAA Fisheries responded to 

our request with several points of clarification and two conservation recommendations (i.e., 

vessel water withdrawal restrictions and time of year restrictions for hydrostatic test water 

withdrawal). We have added recommendations to this EIS to address both of these concerns 

(section 4.3.3 of this EIS). 

4.7 THREATENED, ENDANGERED AND OTHER SPECIAL STATUS SPECIES 

Special status species are those species for which state or federal agencies afford an additional 

level of protection by law, regulation, or policy. Included in this category are federally listed and 

federally proposed species that are protected under the ESA, as amended, or are considered as 

candidates for such listing by the FWS or NOAA Fisheries, and those species that are state-listed 

as threatened or endangered. 

Southern LNG, acting as the FERC’s non-federal representative for the purpose of complying 

with Section 7(a)(2) of the ESA, initiated informal consultation with the FWS, NMFS, and the 

GDNR on January 26, 2006, regarding federally listed species with the potential to be affected 

by the proposed Terminal Expansion facilities and along the proposed vessel transit route. EEC 

initiated consultation with the FWS, NMFS, GDNR, and SCDNR on January 13, 2006, regarding 

federally listed species with the potential to be affected by the proposed Elba Express Pipeline 
 4-66 4.0 –Environmental Impact Analysis 

Project. Initial consultations concluded that the Georgia Field Office of the FWS would serve as 

the lead FWS office for the project consultations. 

Section 7 of the ESA requires the lead federal agency (in this case, the FERC) to ensure that any 

action authorized, funded, or carried out by the agency does not jeopardize the continued 

existence of a federally listed threatened or endangered species, or result in the destruction or 

adverse modification of the designated critical habitat of a federally listed species. The agency is 

required to consult with the FWS and/or the NMFS to determine whether any federally-listed 

endangered or threatened species or their designated critical habitat are found in the vicinity of 

the proposed project, and to determine the proposed action’s potential effects on those species or 

critical habitats. 

For actions involving major construction activities with the potential to affect listed species or 

designated critical habitats, the federal agency must prepare a BA for those species that may be 

affected. The action agency must submit its BA to the FWS and/or the NMFS and, if it is 

determined that the action may adversely affect a federally listed species, the lead federal agency 

must submit a request for formal consultation to comply with Section 7 of the ESA. In response, 

the FWS and/or NMFS would issue a Biological Opinion as to whether or not the federal action 

would likely jeopardize the continued existence of a listed species, or result in the destruction or 

adverse modification of designated critical habitat. In compliance with Section 7 of the ESA, we 

have previously requested (on April 17, 2006) that the FWS and NMFS consider the draft EIS, 

along with the various survey reports and other information prepared by Southern LNG and EEC 

(submitted separately), as our BA for the proposed Elba III Project. 

For purposes of this environmental analysis, special status species of plants and animals include 

species officially listed by the states of Georgia and South Carolina or the federal government as 

endangered, threatened, or rare; or species noted as sensitive or of special concern by the GDNR, 

SCDNR, FWS, or NMFS. To assist in compliance with Section 7 of the ESA, Southern LNG 

and EEC initiated informal consultation with the FWS and NMFS regarding the presence of 

federally listed or proposed endangered and threatened species along the projects and the vessel 

transit route. Additionally, Southern LNG and EEC have assisted the Commission in meeting its 

Section 7 obligations by conducting surveys for federally listed threatened or endangered species 

and their critical habitats in the project area and along the vessel transit route. Impacts that could 

result from an ignited or unignited spill along the vessel transit route are described at the end of 

this section and the zones of concern are outlined in figures 4.7-1 to 4.7-3. 

Terminal Expansion, LNG Marine Traffic, and Elba Express Pipeline

Agency consultations, together with previous studies and a review of updated lists of threatened 

and endangered species, initially identified 31 federally listed species and 30 state listed species 

that potentially occur along the vessel transit route, at the Terminal Expansion and Elba Express 

Pipeline Projects. These federally listed species identified during surveys or with suitable habitat 

within the project area are described below and in tables 4.7-1 and 4.7-2. No marine protected 

areas or marine sanctuaries occur within the Terminal Expansion site or along the waterway for 

LNG marine traffic. 
 4-67 4.0 –Environmental Impact Analysis 

TABLE 4.7-1

Federal and State Listed Species Eliminated From Detailed NEPA Analysis for 

the Proposed Terminal Expansion and Elba Express Pipeline a/ 

Status 

Common Name 

Federal b/ Georgia b/ South 

Carolina b/

Project Component 

(State) - County Where 

Species May 

Occur in Project Area 

Comments 

Plants 

Climbing buckthorn 

(Sageretia minutiflora) 

-- ST Terminal (GA) - Chatham Suitable habitat is not present 

within the Project area; no 

individuals identified during field 

surveys. 

Dwarf Sumac 

Rhus michauxii 

FE SE -- Pipeline (GA) – Burke, 

Jenkins, Glascock, Warren, 

McDuffie, Wilkes, Elbert, Hart

Suitable habitat is not present 

within the Project area. 

Dwarf witch-alder 

Fothergilla gardenia 

-- ST -- Pipeline (GA) – Effingham, 

Screven, Jenkins, Burke 

Suitable habitat is not present 

within the Project area. 

Mat-forming Quillwort 

Isoetes tegetiformans 

FE SE -- Pipeline (GA) – McDuffie, 

Wilkes 

Suitable habitat is not present 

within the Project area. 

Narrow-leaf Dragonhead 

Tidal Marsh Obedient Plant 

Physostegia leptophylla 

-- SE -- Pipeline (GA) - Chatham 

Terminal (GA) - Chatham 

Suitable habitat is not present 

within the Project area. 

Sandhill Rosemary 

Ceratiola ericoides 

-- ST -- Pipeline (GA) – Screven, 

Jenkins, Burke 

Suitable habitat is not present 

within the Project area. 

Shoals Spiderlily 

Hymenocallis coronaria 

FC SE -- Pipeline (GA) –McDuffie, 

Wilkes, Elbert 

Suitable habitat is not present 

within the Project area. 

Smooth Coneflower 

Echinacea laevigata 

FE SE SE Pipeline (GA) – Hart; (SC) - 

Anderson 

Suitable habitat is not present 

within the Project area. 

Birds 

Bachman’s Warbler 

Vermivora bachmanii 

-- SE -- Pipeline (GA) – Chatham, 

Effingham, Screven, Burke, 

Jefferson, Jenkins, Glascock, 

Warren, McDuffie, Wilkes, 

Elbert, Hart; (SC) - Anderson

Terminal (GA) – Chatham 

Suitable habitat is not present 

within the Project area. No 

individuals identified during field 

surveys. 

Kirtland’s Warbler 

Dendroica kirtlandii 

FE SE -- Pipeline (GA) – Chatham, 

Effingham, Screven, Burke, 

Jefferson, Jenkins, Glascock, 

Warren, McDuffie, Wilkes, 

Elbert, Hart; (SC) - Anderson

Terminal (GA) – Chatham 

Suitable habitat is not present 

within the Project area; no 

individuals identified during field 

surveys. 

Least Tern 

Sterna antillarum 

FE SR ST Pipeline, Terminal (GA) - 

Chatham 

Suitable habitat is not present 

within the Project area; no 

individuals identified during field 

surveys. 

Piping Plover 

Charadrius melodus

FT ST -- Pipeline, Terminal (GA) - 

Chatham

Suitable habitat is not present 

within the Project area; no 

individuals identified during field 

surveys. 
 4-68 4.0 –Environmental Impact Analysis 

TABLE 4.7-1 (continued) 

Federal and State Listed Species Eliminated From Detailed NEPA Analysis for 

the Proposed Terminal Expansion and Elba Express Pipeline a/

Status 

Common Name 

Federal b/ Georgia b/ South 

Carolina b/

Project Component 

(State) - County Where 

Species May 

Occur in Project Area 

Comments 

Red-cockaded 

Woodpecker 

Picoides borealis 

FE SE SE Pipeline (GA) - Chatham, 

Effingham, Screven, Jenkins, 

Burke, Jefferson 

Terminal (GA) - Chatham 

Suitable habitat is not present 

within the Project area; no 

individuals identified during field 

surveys. 

Seaside sparrow 

Ammodramus maritimus 

FPS -- -- Terminal (GA) - Chatham Suitable habitat is not present 

within the Project area; no 

individuals identified during field 

surveys. 

Reptiles

Spotted TurtleClemmys 

guttata 

-- -- ST Vessel Transit Route (SC) - 

Jasper 

Suitable habitat is not present 

within the Project area 

 

Amphibians 

Gopher Frog 

Rana capito 

-- ST SE Pipeline (GA) - Chatham, 

Effingham, Screven, Jenkins, 

Burke 

Suitable habitat is not present 

within the Project area. 

Webster’s Salamander 

Plethodon websteri 

-- -- SE Pipeline (SC) - Anderson Suitable habitat is not present 

within the Project area. 

Dwarf Siren 

Pseudobranchus striatus 

---- -- ST Vessel Transit Route (SC) - 

Jasper 

Suitable habitat is not present 

within the Project area. 

Mammals 

Rafinesque’s Bigeared Bat 

Corynorhinus rafinesquii 

-- SR SE Not listed in any counties 

crossed by the Pipeline or 

Terminal 

Suitable habitat is not present 

within the Project area. 

Round-tailed Muskrat 

Neofiber alleni 

-- ST -- Pipeline (GA) - Chatham, 

Effingham, Screven 

Suitable habitat is not present 

within the Project area. 

________________________________________________________________ 

a/ Source: Georgia’s and South Carolina’s List of Federally Listed Species, the South Carolina Rare, Threatened, and Endangered 

Species Inventory and the List of Georgia “State Protected” Species. 

b/ Legal Statuses: 

Federal: Species with the Statuses of FE (Federal Endangered), FT (Federal Threatened), T(S/A) (Threatened because of 

Similarity of Appearance), FC (Federal Candidate), FPS (Federal Partial Status, Listed in a Portion of its Range) are Legally 

Protected under the U.S. Endangered Species Act of 1973. 

Georgia: Species with the Statuses of SE (State Endangered), ST (State Threatened), SR (Rare Species); SU (State Unusual), 

SPS (State Partial Status, Listed in a Portion of its Range) are Legally Protected under the Georgia Endangered Wildlife (1973) and 

the Georgia Wildflower Preservation Act (1973). 

South Carolina: Species with the Statuses of SE (State Endangered), ST (State Threatened), and LS (Species of Special 

Concern) Are Legally Protected under the South Carolina Code of Laws Section 50. 
 4-69 4.0 –Environmental Impact Analysis 

TABLE 4.7-2 

Federal and State Listed Species Potentially Occurring in the Vicinity of the 

Proposed Terminal Expansion and Elba Express Pipeline a/ 

Status 

Common Name 

Federal b/ Georgia b/ South 

Carolina b/

Project Component 

(State) County 

Where Species May 

Occur in Project Area 

Comments 

Mammals

Blue whale 

Balaenoptera musculus

FE -- -- Vessel Transit Route (GA) Thrive in deep waters off the 

continental shelf. Suitable habitat 

present along the waterway for 

LNG marine traffic. 

Fin whale 

Balaenoptera physalus

FE -- -- Vessel Transit Route (GA) Thrive in deep waters off the 

continental shelf. Suitable habitat 

present along the waterway for 

LNG marine traffic. 

Humpback whale 

Megaptera novaeangliae 

FE SE -- Vessel Transit Route (GA) Suitable habitat present along the 

waterway for LNG marine traffic 

North Atlantic right whale 

Eubalaena glacialis 

FE SE -- Vessel Transit Route (GA) Suitable habitat present along the 

waterway for LNG marine traffic. 

Sei whale 

Balaenoptera borealis

FE -- -- Vessel Transit Route (GA) Thrive in deep waters off the 

continental shelf. Suitable habitat 

present along the waterway for 

LNG marine traffic. 

Sperm whale 

Physeter macrocephalus 

FE -- -- Vessel Transit Route (GA) Thrive in deep waters off the 

continental shelf. Suitable habitat 

present along the waterway for 

LNG marine traffic. 

West Indian Manatee 

Trichechus manatus

FE SE SE Vessel Transit Route (GA) m Suitable habitat is not present 

within the Project area; no 

individuals identified during field 

surveys. 

Reptiles 

American Alligator 

Alligator mississippiensis

T(S/A) -- -- Pipeline -(GA) - All Counties Suitable habitat present along 

pipeline route. 

Eastern Indigo Snake 

Drymarchon corais 

couperi

FT ST -- Pipeline (GA) - Chatham, 

Effingham, Screven 

Terminal (GA) - Chatham

Pipeline - Suitable habitat present

Terminal - No suitable habitat 

present 

Gopher Tortoise 

Gopherus polyphemus

-- ST SE Pipeline (GA) - Chatham, 

Effingham, Screven, Jenkins, 

Burke, Jefferson 

Terminal (GA) - Chatham

Pipeline - Individuals were 

identified within the Project area.

Terminal – No suitable habitat 

present 

Green sea turtle 

Chelonia mydas

FT -- -- Vessel Transit Route (GA) Suitable habitat present along the 

waterway for LNG marine traffic. 

Hawksbill sea turtle 

Eretmochelys imbricata

FE -- -- Vessel Transit Route (GA) Suitable habitat present along the 

waterway for LNG marine traffic. 

Kemp’s Ridley sea turtle 

Lepidochelys kempii

FE -- -- Vessel Transit Route (GA) Suitable habitat present along the 

waterway for LNG marine traffic. 
 4-70 4.0 –Environmental Impact Analysis 

TABLE 4.7-2 (continued) 

Federal and State Listed Species Potentially Occurring in the Vicinity of the 

Proposed Terminal Expansion and Elba Express Pipeline a/

Status 

Common Name 

Federal b/ Georgia b/ South 

Carolina b/

Project Component 

(State) County 

Where Species May 

Occur in Project Area 

Comments 

Leatherback sea turtle 

Dermochelys coriacea

FE -- -- Vessel Transit Route (GA) Suitable habitat present along the 

waterway for LNG marine traffic. 

Loggerhead sea turtle 

Caretta caretta

FT -- -- Vessel Transit Route (GA) Suitable habitat present along the 

waterway for LNG marine traffic. 

Fish 

Atlantic Sturgeon 

Acipenser oxyrhynchus 

oxyrhynchus 

FC -- SSC Pipeline (GA) - Chatham Pipeline - Suitable habitat present

Bluebarred Pygmy 

Sunfish 

Elassoma okatie 

-- SE -- Pipeline (GA) - Burke, 

Jefferson, Warren, McDuffie

Habitat at all crossings of the Brier 

Creek system and its tributaries

Robust Redhorse 

Moxostoma rubustum 

-- SE -- Pipeline (GA) - Effingham, 

Screven, Wilkes, Elbert

Pipeline - Suitable habitat present

Sandbar Shiner 

Notropis scepticus 

-- SR -- Pipeline (GA) - McDuffie, 

Wilkes, Elbert, Hart

Suitable habitat present

Shortnose Sturgeon 

Acipenser brevirostrum

FE SE SE Pipeline, Terminal (GA) – 

Chatham and Vessel Transit 

Route (GA) 

Pipeline - No suitable habitat 

present, 

Terminal – Suitable habitat 

present 

Birds 

Bald Eagle 

Haliaeetus leucocephalis

-- SE SE Pipeline (GA) - Chatham, 

Jefferson, McDuffie, Wilkes, 

Hart; (SC) – Anderson 

Terminal (GA) – Chatham and 

Vessel Transit Route (GA) 

Pipeline - No individuals or nests 

observed. Suitable habitat occurs 

within 0.5 miles of waterbodies 

throughout pipeline route. 

Terminal – No suitable habitat 

present, but is present along the 

transit route. 

Peregrine Falcon 

Falco peregrinus

-- SE SE Not listed in any counties 

crossed by the Pipeline or 

Terminal and Vessel Transit 

Route

No individuals or nests observed; 

however, suitable foraging habitat 

occurs throughout pipeline route. 

. 

Swallow-tailed Kite 

Elanoides forficatus 

-- SR SE Pipeline (GA) – All counties Suitable habitat present

Wood Stork 

Myctera americana

FE SE SE Pipeline (GA) - Chatham, 

Effingham, Screven, Jenkins, 

Burke, Jefferson, Glascock, 

Warren, McDuffie, Wilkes, 

Elbert, Hart; (SC) – Anderson 

Terminal (GA) – Chatham and 

Vessel Transit Route (GA) 

Pipeline - Individuals were 

identified within the Project area. 

Terminal – No Suitable habitat 

present, but is present along the 

transit route. 
 4-71 4.0 –Environmental Impact Analysis 

TABLE 4.7-2 (continued) 

Federal and State Listed Species Potentially Occurring in the Vicinity of the 

Proposed Terminal Expansion and Elba Express Pipeline a/

Status 

Common Name 

Federal b/ Georgia b/ South 

Carolina b/

Project Component 

(State) County 

Where Species May 

Occur in Project Area 

Comments 

 Gull-billed Tern 

 Sterna nilotica -- ST -- 

Pipeline, Terminal (GA) – 

Chatham 

Vessel Transit Route (GA) 

Suitable habitat is not present 

within the terminal or pipeline area 

but is present along the transit 

route. 

 Wilson’s plover 

Charadrius wilsonia -- SR ST 

Pipeline, Terminal (GA) – 

Chatham 

Vessel Transit Route (GA) 

Suitable habitat is not present 

within the terminal or pipeline area 

but is present along the transit 

route. 

Amphibians 

Flatwoods Salamander 

Ambystoma cingulatum

FT SR SE Pipeline (GA) - Chatham, 

Effingham, Screven 

Terminal (GA) – Chatham

Pipeline - Suitable habitat present

Terminal – No suitable habitat 

present 

Invertebrates 

Atlantic Pigtoe Mussel 

Fusconaia masoni 

-- SE -- Pipeline (GA) - Jenkins, 

Jefferson

Suitable habitat present 

Crustacean 

Broad River Burrowing 

Crayfish 

Distocambarus devexus 

-- ST -- Pipeline (GA) - Wilkes, Elbert Suitable habitat within the Broad 

River watershed 

Lean Crayfish 

Cambarus strigosus 

-- ST -- Pipeline (GA) - Wilkes, Elbert Suitable habitat within the Broad 

River watershed 

Plants 

Canby’s Dropwort 

Oxypolis canbyi 

FE SE SE Pipeline (GA) - Screven, Burke, 

Jenkins

Suitable habitat present

Granite Stonecrop 

Sedum pusillum 

-- ST -- Pipeline (GA) – Elbert, Wilkes Suitable habitat present

Granite Whitlow-grass 

Draba aprica 

-- SE -- Pipeline (GA) - Wilkes, Warren, 

McDuffie

Suitable habitat present

Indian Olive 

Nestronia umbellula

-- ST -- Pipeline (GA) - Burke, Jenkins, 

Glascock, Warren, McDuffie, 

Wilkes, Elbert, and Hart; (SC) – 

Anderson 

Suitable habitat present

Ocmulgee Skullcap 

Scutellaria ocmulgee 

-- ST -- Pipeline (GA) - Burke and 

McDuffie

Suitable habitat present

Oglethorpe Oak 

Quercus oglethorpensis 

-- ST -- Pipeline (GA) - Hart, Elbert, 

Wilkes

Individuals were identified within 

the project area.

Parrot Pitcher Plant 

Sarracenia psittacina 

-- ST -- Pipeline (GA) – All counties Suitable habitat present

Pondberry 

Lindera melissifolia

FE SE SE Pipeline (GA) – Effingham, 

Screven 

Terminal (GA) – Chatham 

Pipeline - Suitable habitat present

Terminal – No suitable habitat 

present 

Pondspice 

Litsea aestivalis 

-- ST -- Pipeline (GA) – Effingham, 

Chatham

Suitable habitat present 
 4-72 4.0 –Environmental Impact Analysis 

TABLE 4.7-2 (continued) 

Federal and State Listed Species Potentially Occurring in the Vicinity of the 

Proposed Terminal Expansion and Elba Express Pipeline a/

Status 

Common Name 

Federal b/ Georgia b/ South 

Carolina b/

Project Component 

(State) County 

Where Species May 

Occur in Project Area 

Comments 

Pool Sprite 

Amphianthus pusillus 

FT ST ST Pipeline (GA) - Wilkes, Warren, 

McDuffie

Suitable habitat present 

Sweet Pitcherplant 

Sarracenia rubra

-- SE -- Pipeline (GA) - Effingham, 

Screven, Burke, Jefferson

Suitable habitat present 

________________________________________________________________ 

a/ Source: Georgia’s and South Carolina’s List of Federally Listed Species, the South Carolina Rare, Threatened, and Endangered 

Species Inventory and the List of Georgia “State Protected” Species. 

b/ Legal Statuses: 

Federal: Species with the Statuses of FE (Federal Endangered), FT (Federal Threatened), FC (Federal Candidate) T(S/A) 

(Threatened because of Similarity of Appearance) Are Legally Protected under the U.S. Endangered Species Act of 1973. 

Georgia: Species with the Statuses of SE (State Endangered), ST (State Threatened), SR (Rare Species), SSC (State Special 

Concern) are Legally Protected under the Georgia Endangered Wildlife (1973) and the Georgia Wildflower Preservation Act 

(1973). 

South Carolina: Species with the Statuses of SE (State Endangered), ST (State Threatened), and LS (Species of Special 

Concern) Are Legally Protected under the South Carolina Code of Laws Section 50. 

TABLE 4.7-3

Recorded Occurrences of Federal and State Listed Threatened and Endangered Species 

within 1,500 Feet of the Elba Express Pipeline 

County / 

State Milepost Genus and 

Species 

Common 

Name 

Distance from 

Centerline (ft) 

Direction from 

Centerline Comment 

Elbert / GA 161.1 Quercus 

oglethorpensis 

Oglethorpe 

oak 1190 West Approximately 30 trees and seedlings 

Elbert / GA 162.1 Quercus 

oglethorpensis 

Oglethorpe 

oak 132 West 

Coordinates are 

approximately 107 ft 

outside planned 

workspace. Not 

identified during field 

surveys. 

Hart / GA 187.7 Notropis 

scepticus 

Sandbar 

shiner 838 West None 

________________________________________________________________ 

Source: GNHP 2006a. 

Based on review of available literature and the results of field surveys conducted by Southern 

LNG and EEC, we believe that the projects would have no affect on 20 of these species because 

the Elba III Project would not be within the known range of the species or because the Elba III 

Project would not impact habitat for the species (table 4.7-1). These 20 species are not addressed 

further in this EIS. The remaining 41 species are listed in table 4.7-2 and discussed below. 

The Natural Heritage Programs of Georgia and South Carolina maintain databases of known 

occurrences of federal and state threatened and endangered species. Table 4.7-3 identifies all 

occurrences of federal and state threatened and endangered species within 1,500 feet of the Elba 

Express Pipeline. 
 4-73 4.0 –Environmental Impact Analysis 

EEC submitted the results of its surveys to the FWS, GDNR, and SCDNR to request concurrence 

of its determination of no impact for species without potential habitat or individuals identified in 

the project area. Additionally, EEC asked the FWS, GDNR, and SCDNR to examine its speciesspecific surveys, monitoring, and/or mitigation, as necessary, for species with potential habitat in 

the project area. To further protect listed species that potentially occur within the project area, 

we recommend where protected species or their habitat exists, and surveys were conducted 

over one year prior to the start of construction, EEC should consult with the FWS to assess 

the need for additional surveys prior to construction. 

4.7.1 Federally Listed Threatened and Endangered Species 

Terminal Expansion and LNG Marine Traffic 

Six federally protected species of whales (Blue, Fin, Humpback, North Atlantic right, Sei, and 

Sperm), West Indian manatee, and five sea turtle species (Green sea, Hawksbill, Kemp’s Ridley, 

Leatherback, and Loggerhead) could potentially occur along the LNG vessel transit corridor. 

Blue, Fin, Humpback, Sei, and Sperm Whales 

Blue and Sei Whale 

The distribution of the sei whale (Balaenoptera borealis) and blue whale (Balaenoptera 

musculus) are uncommon off the mid-Atlantic in the Project area. The sei whale’s range is in 

northern waters. The southern limits of its spring and summer range include the Gulf of Maine 

and Georges Bank. It is often found in the deeper waters of the continental shelf edge. The blue 

whale’s range extends from the Arctic Ocean to mid-latitude waters and is often sighted off of 

eastern Canada (NOAA Fisheries, 2007).

Fin Whale 

The fin whale (Balaenoptera physalus) is common from Cape Hatteras north to the Gulf of 

Maine. In this area, fin whales may be the dominant large cetacean species year round, with the 

largest standing stock, food requirements, and impact on the marine ecosystem. It is likely that 

fin whales occurring in the eastern Atlantic undergo migrations into Canadian waters, open 

ocean areas, and subtropical or tropical regions (NOAA Fisheries, 2007). 

Humpback Whale 

The federally -endangered humpback whale is medium in size, attaining lengths of up to 50 feet 

and weights of up to 30 tons. Humpback whales are charcoal gray with lighter colored pectoral 

flippers. These whales are found in all the world’s oceans but are less common in arctic areas. In 

winter, these whales seek out waters near coastal areas and islands in temperate and tropical 

areas where they probably mate and give birth. 

The western north Atlantic stock of humpback whales includes whales using feeding areas in the 

Gulf of Maine, Gulf of St. Lawrence, Newfoundland, Labrador, western Greenland, and the 
 4-74 4.0 –Environmental Impact Analysis 

Iceland-Denmark strait. Humpback whales have been observed off Georgia and Florida during 

the winter. The NMFS has produced a recovery plan for the humpback whale. The major 

recommendations of the plan are to protect habitats that are important to humpback whales, 

continue prohibition on commercial harvesting of humpbacks, and reduce fishing gear 

entanglements. 

Sperm Whale 

Sperm whales (Physeter macrocephalus) are found throughout the world's oceans in deep waters 

to the edge of the ice at both poles. Sperm whales generally occur in waters greater than 984 feet 

and prefer continental margins, sea mounts, and areas of upwelling where food is abundant 

(NOAA Fisheries, 2007). 

Blue, Fin, Humpback, Sei, and Sperm Whale Impacts 

The Blue, Fin, Humpback, Sei, and Sperm whales usually do not occur in relatively shallow 

waters such as those found near the Elba III Project, however, they could potentially be impacted 

by collisions with LNG vessels that are transiting to and from the terminal in the Atlantic Ocean. 

A system of shipping safety fairways26 and fairway anchorages has been established for the 

Atlantic Ocean and is shown on some, but not all, navigation charts. These fairways are near 

port entrances and along coastal trade routes, but do not extend across or into the deep waters of 

the Atlantic Ocean. The likelihood of these whales encountering LNG vessels in the open ocean 

would be inherently low given their ability to avoid oncoming vessels coupled with their overall 

rarity. 

To reduce the risk associated with vessel strikes or disturbance of protected species, Southern 

LNG would include the NMFS Vessel Strike Avoidance Policy (see appendix K) as part of its 

Terminal Use Agreement with LNG Vessel operators. NMFS recently issued this policy to 

address vessels involved in the transport of LNG. This policy includes recommendations for 

vessel strike avoidance such as using a reference guide that includes and helps identify the 

whales and sea turtles that may be encountered; maintaining a vigilant watch for marine 

mammals and slowing down or stopping vessels to avoid striking protected species; maintaining 

a distance of 150 feet for sea turtles or small cetaceans and 300 feet for whales; maintaining a 

parallel direction to the animal’s course and avoiding excessive speed or abrupt changes in 

direction when protected species are in the area; reducing vessel speeds to 10 knots or less when 

pods or large assemblages of cetaceans are observed near an underway vessel; and reducing 

speed and shifting engines to neutral when protected species are sighted in the vessel’s path or 

near a moving vessel. In addition, the policy requires that crews report sightings of any injured 

or dead protected species immediately to the Mammal and Sea Turtle Stranding Hotline or the 

Marine Mammal Stranding Network. 

Hull-transmitted noise and propeller cavitation could interfere with whale communication by 

increasing ambient noise levels and masking important signals in the environment. Southern 

 

26 33 CFR 166.105 defines a shipping safety fairway as “a lane or corridor in which no artificial island or fixed 

structure, whether temporary or permanent, will be permitted.” 
 4-75 4.0 –Environmental Impact Analysis 

LNG’s implementation of the NMFS Vessel Strike Avoidance Policy would reduce speed to 10 

knots when cetaceans are observed near an underway vessel. This reduction in speed would 

reduce hull-transmitted noise and propeller cavitation. 

Construction of the Terminal Expansion facilities or Elba Express Pipeline Project would have 

no impact on Blue, Fin, Humpback, Sei, and Sperm whales. However, an increase in LNG 

vessel traffic could impact these whale species. Due to their rarity in the project area, these 

whales are not likely to be encountered by LNG vessels calling on the terminal in the Savannah 

River. Although the source of LNG supplies for the proposed Terminal Expansion facilities 

have not yet been identified, LNG vessels calling on the terminal could be expected to arrive 

from production countries in North Africa, the Middle East, or the southern Caribbean. 

In waters of the United States, the major shipping routes into the Savannah River would not 

cross key habitat areas of any of these whale species. In addition, implementation of the 

measures included in the Vessel Strike Avoidance Policy as discussed above would minimize 

potential impacts on these whale species. As such, we have determined that Southern LNG’s 

Terminal Expansion project is not likely to adversely affect or significantly impact the Blue, Fin, 

Humpback, Sei, and Sperm whales. 

North Atlantic Right Whale 

The federally -endangered North Atlantic right whale (right whale) possibly occurs in the waters 

near Elba Island in Chatham County, Georgia as well as along the LNG marine traffic corridor 

(FWS, 2000). The right whale is the world’s most endangered large whale and was considered 

to be extinct until rediscovered in the early 1980’s. Right whales calve in shallow coastal waters 

between Savannah and Cape Canaveral, Florida. Their winter range is largely unknown. Their 

spring and summer range encompasses areas of the Cape Cod/Massachusetts Bay and waters 

north to the Bay of Fundy. The current population is estimated at 300 whales. Historical 

population decline has been linked to unregulated hunting. Current threats include entanglement 

with fixed fishing gear, vessel collisions, and pollution. 

Because right whales are slow moving (estimated at less than a quarter of a mile per hour with a 

calf, slightly faster without) vessel strikes are a significant human caused threat to this species. 

Right whales are more likely to be found in shallow, coastal waters than other large whales 

(GDNR, 1999). Calving off of the coasts of Georgia and Florida is observed between December 

and March. Usually one calf per female is born every 2-5 years. Right whales feed by skimming 

at the waters surface through swarms of copepods, with mouths agape and their upper jaw 

protruding out of the water (GDNR, 1999). On February 17, 2006, a single adult right whale 

was observed about 20 miles southeast of the mouth of the Savannah River and was traveling in 

a southerly direction at a moderate rate of speed. This individual was observed in the vicinity of 

an LNG vessel that was traveling in an easterly direction away from the terminal (Bernhart, 

2006). Additionally, a north Atlantic right whale was found dead at the inlet to the Savannah 

River in December of 2006. It is believed at this time that a vessel strike was the reason for its 

death. 
 4-76 4.0 –Environmental Impact Analysis 

Because right whales are known to occur in or adjacent to many major shipping corridors along 

the eastern United States and collisions are known to account for over 50 percent of humaninduced mortality in right whales, NOAA Fisheries established a right whale vessel strike 

reduction program. Despite the measures implemented as part of that program (e.g., aerial 

surveys to notify mariners of whale locations, supporting shipping industry liaisons, mandatory 

reporting programs, etc.), right whales continue to be killed by vessel strikes. In response to this 

continuing problem, NOAA Fisheries developed a Strategy to Reduce Vessel Strikes of right 

whales, which is intended to minimize the overlap between vessels and whales and reduce the 

likelihood of vessel strikes to the extent practicable. 

Assuming that potential increase of 95 LNG vessels per year could unload cargo at the proposed 

terminal each year, about 47 would be expected to unload at the terminal during the 6 months, 

from November 1 to April 30, in which mothers and calves could be present within the transit 

corridor. These additional 95 vessels approaching and entering the Exclusive Economic Zone 

(EEZ) and then the Savannah river would be in addition to the existing vessel traffic entering the 

Savannah River and visiting various ports along the River. The additional vessel traffic likely 

increases the potential risk of a right whale vessel strike. However, Southern LNG’s adherence 

to NMFS applicable speed restrictions for incoming and outgoing vessels as indicated in 

appendix K (Vessel Strike Avoidance and Injured/Dead Protected Species Reporting Policy 

[Vessel Strike Avoidance Policy]) ) would reduce the likelihood of the potential for strikes to 

right whales. 

In addition to the measures that Southern LNG has agreed to, the NMFS further recommends: 

• The vessels maintain a distance of 500 yards from right whales (and 100 yards from other 

listed whales); 

• a seasonal speed restriction of 10 knots or less extending 30 nautical miles from shore 

during the calving season (November 1 to April 30);

• an Automated Identification System (AIS) contacting the inbound or outbound vessel and 

stating they are within a speed-restricted zone for right whales and requesting 

acknowledgement of the AIS message;

• the vessels take the most direct course through right whale habitat to reduce encounter 

rates with animals, while avoiding areas of recent whale sightings;

• distribution of educational materials to LNG vessel operators regarding right whales, 

information on how to report right whale sightings, and requirements to check maritime 

advisory information systems for right whale sightings within 30 nautical miles; and 

• Southern LNG submit an annual report to NMFS Southeast Regional Office detailing 

compliance with seasonal speed restrictions within the 30 nautical mile boundary. The 

annual report would include AIS information recorded from all LNG vessels calling on 

the terminal in the last calendar year. For each LNG vessel calling on the terminal 

information submitted for inbound and outbound trips must include: 

o the types of information materials provided to LNG vessel operators regarding 

right whale identification, reporting, and compliance with protection for this 

species, 

o a map showing the geo-boundary and course of vessels calling on the LNG 

terminal, 
 4-77 4.0 –Environmental Impact Analysis 

o the time and date of each arrival and departure, including the name of each LNG 

vessel, 

o the method, time and date the LNG vessel was informed of the speed restriction 

(by voice or by AID) and if acknowledgement was received from the LNG vessel. 

o the speed of the vessel before and after entering the geo-boundary, 

o any additional actions taken to inform non-compliant vessels of the speed 

requirement within the geo-boundary, 

o the number of vessels not in compliance with the speed requirement within the 

geo-boundary, 

o detailed reasons related to safe navigation why a vessel did not follow the speed 

requirements, 

o the date and number of right whale sightings provided to LNG vessels, and 

o any change of course by an LNG vessel or other measures taken to avoid right 

whales within the geo-boundary. 

In its comments on the draft EIS, Southern LNG stated that it is continuing to consult with the 

NMFS to determine mitigation measures to further protect the right whale. These measures 

would include vessel strike avoidance procedures, right whale identification, and notification 

protocols. Southern LNG has agreed to file its final right whale protection measures with the 

Director of OEP. Southern LNG would not be authorized to construct the terminal expansion 

until staff completes Section 7 of the ESA consultation for this species. 

Additionally, hull-transmitted noise and propeller cavitation could interfere with whale 

communication by increasing ambient noise levels and masking important signals in the 

environment. By Southern LNG’s proposed use of the NMFS Vessel Strike Avoidance Policy 

(see appendix K), it would reduce speed to 10 knots when cetaceans are observed near an 

underway vessel. This reduction in speed would reduce hull-transmitted noise and propeller 

cavitation. 

The potential for harassment is not expected to result in any significant response on migration, 

breathing, nursing, breeding, feeding, or sheltering to individuals, or have any consequences at 

the level of the population. With implementation of agreed upon mitigation measures, by 

maintaining a lookout for listed species, and taking prudent actions to avoid collisions with them, 

we believe that the likelihood of collisions between the vessel and listed species would be 

reduced to discountable levels. 

Construction of the Terminal Expansion facilities or Elba Express Pipeline Project would have 

no impact on north Atlantic right whales. Although LNG vessels servicing the proposed 

terminal have the potential to strike right whales in the vicinity of the EEZ and subsequently the 

Savannah River, adherence to agreed upon mitigation measures, speed restrictions, and other 

preventative measures proposed by Southern LNG would minimize the potential for strikes such 

that the proposed project is not likely to adversely affect or significantly impact the North 

Atlantic right whales. 
 4-78 4.0 –Environmental Impact Analysis 

West Indian Manatee 

The federally-listed endangered West Indian manatee possibly occurs in the waters of the 

Savannah River near Elba Island. Winter ranges for manatees include natural and artificial warm 

water sites in Florida (GDNR, 1999). During summer they expand their range and have been 

seen as far west as Louisiana on the gulf coast. Manatees often return to the same wintering and 

summering habitats year after year. Breeding usually takes place in mating herds formed when 

several males are attracted to a female in estrus. Mating herds can remain together for a few 

days to over a month, during which time as many as 20 males may compete intensely for access 

to the focal female (GDNR, 1999). Habitat preferences include sluggish rivers, sheltered marine 

bays, and shallow estuaries. In Georgia, manatees forage for submerged vegetation such as 

marsh grass, pickerel weed, green algae, and red algae. Calves usually stay with the mother 1-2 

years after conception. 

Manatees have been observed infrequently in the Savannah River as far upstream as the King’s 

Island Turning Basin about 11.0 miles upstream of the proposed Terminal Expansion site. 

However, the occurrence is very rare. Population decline has been mostly due to habitat 

destruction and vessel collisions, cold stress, and red tides. Population size is difficult to 

quantify (surveys conducted in Florida in 2001 counted approximately 3,300 individuals based 

on a single statewide count at warmwater refuges and adjacent areas). 

Southern LNG reported that no manatees have been observed in or near its existing slip berth 

since it has been in operation. Existing mitigation measures would be implemented to prevent 

injury to manatees should they occur during docking at the terminal. Southern LNG would 

adhere to the measures contained in the “Standard Manatee Conditions” set forth in its existing 

COE permit authorizations. These measures include: 

• advise all personnel associated with the project that there are civil and criminal penalties 

for harming, harassing or killing manatees; 

• all vessels associated with dredging activities would operate at “no wake/idle” speeds at 

all times while in water where the draft of the vessel provides less than four feet 

clearance from the bottom and that vessels would follow routes of deep water whenever 

possible; 

• ensure that all dredging activities in open water would cease upon the sighting of a 

manatee within 100 yards of the project area. Dredging activities would not resume until 

the manatees have not been seen in the project area for at least 30 minutes; 

• report any collision with a manatee immediately to the COE, FWS, and GDNR; 

• maintain a log detailing sightings, collisions, or injury to manatees, which have occurred 

during the contract period; 

• prepare a report summarizing any incidents and sightings and submit the report to the 

FWS; and 

• avoid performing authorized dredging work during the months of May, June and July, if 

practicable. 

Manatees typically inhabit shallow coastal areas, and as such LNG vessels would only be 

expected to encounter manatees in the near shore areas of the Savannah River. LNG marine 
 4-79 4.0 –Environmental Impact Analysis 

vessels would be within deeper water than manatees would be expected to inhabit. Additionally, 

the slow speeds that LNG marine vessels travel in near shore areas and the deep propellers would 

further reduce the likelihood of vessel strikes. Noise associated with the incremental increase in 

vessel traffic would be minimal, due to the number of vessels currently transiting the Savannah 

River Channel. 

Because of Southern LNG’s proposed mitigation measures, we have determined that the 

proposed Terminal Expansion and vessel transit are not likely to adversely affect or significantly 

impact the West Indian manatee. The proposed Elba Express Pipeline Project does not cross any 

West Indian manatee suitable habitat. Therefore, we conclude the Elba Express Pipeline Project 

would have no effect on the West Indian manatee. 

Sea Turtles 

Five species of federally-listed endangered and threatened sea turtles possibly occur in the waters 

near Elba Island in Chatham County, Georgia (FWS, 2000) and are described below. 

Green Sea Turtle

The green sea turtle is federally-listed as threatened. Green sea turtles inhabit shallow habitats 

with an abundance of marine algae and seagrass such as lagoons, bays, inlets, shoals, and 

estuaries. They use coral reefs and rocky outcrops near feeding areas to rest, and they feed on 

marine plants, mollusks, sponges, crustaceans, and jellyfish. They tend to nest on their natal 

beach (NOAA, 2006). Suitable nesting habitat for this species is not available within the project 

area. 

Hawksbill Sea Turtle

The hawksbill sea turtle is federally-listed as endangered. This species inhabits coastal reefs, 

bays, rocky areas, estuaries, and lagoons at depths of 70 feet or less. Hawksbill sea turtle 

hatchlings may be found in the open sea floating on masses of marine plants while juveniles, 

subadults, and adults may be found near their primary foraging area along coral reefs. Hawksbill 

sea turtles are omnivorous; however, they prefer to feed on invertebrates such as sponges, 

mollusks, and sea urchins. Nesting occurs on undisturbed deep-sand beaches, from high-energy 

beaches to small pocket beaches bounded by crevices of cliff walls with woody vegetation near 

the waterline (NOAA, 2006). 

Hawksbill sea turtles may occasionally pass through Georgia waters as transients. Of the 4,437 

turtles in the GDNR stranding database, only two are confirmed for hawksbill sea turtle in 

Georgia. These records were for deceased turtles found on Cumberland and Jekyll islands 

(located about 75 and 100 miles south of the Savannah River) during 1998. Suitable nesting 

habitat for this species is not available within the project area. 

Kemp’s Ridley Sea Turtle 
 4-80 4.0 –Environmental Impact Analysis 

The Kemp’s ridley sea turtle is federally-listed as endangered. Kemp’s ridley sea turtle inhabit 

shallow coastal and estuarine waters over sand or mud bottoms. Juveniles feed on sargassum 

while adults are largely shallow-water benthic feeders. Food items include shrimp, snails, 

bivalves, jellyfish, and marine plants. Juvenile Kemp’s ridley sea turtle may range throughout 

the Atlantic Ocean, while adults are restricted to the Gulf of Mexico. The majority of this 

species nests along an 11-mile-long stretch of coastline near Rancho Nuevo, Tamaulipas, Mexico 

(NOAA, 2006). Suitable nesting habitat for this species is not available within the project area. 

Leatherback Sea Turtle 

The leatherback sea turtle is federally-listed as endangered. Leatherback sea turtles spend most 

of their time in the open sea and come to land to nest. They may be found in coastal waters only 

when nesting or following jellyfish concentrations. They feed mainly on jellyfish and sea squirts 

as well as sea urchins, crustaceans, fish, and floating seaweed and prefer sandy beaches with a 

deepwater approach for nesting (NOAA, 2006). Suitable nesting habitat for this species is not 

available within the project area. 

Loggerhead Sea Turtle

The loggerhead sea turtle is federally-listed as threatened. The greatest threats to this sea turtle 

are coastal development, commercial fisheries, and pollution. Loggerhead sea turtles inhabit 

continental shelves, bays, estuaries, and lagoons in temperate, subtropical, and tropical waters. 

Along the Atlantic Coast, their range extends from Newfoundland to as far south as Argentina. 

Their primary nesting sites are along the east coast of Florida with other sites located on the Gulf 

Coast of Florida, in Georgia, and along the Carolinas. After hatching, loggerhead hatchlings 

move to the sea and commonly float on sargassum masses for three to five years. Subadults 

occupy near-shore and estuarine habitats, whereas adults occupy a variety of habitats that range 

from turbid bays to clear water. Loggerhead sea turtles feed on a variety of benthic and pelagic 

food. Loggerhead sea turtles nest on open, sandy beaches above the high tide mark and seaward 

of well-developed dunes. They prefer steeply sloped beaches with gradually sloped offshore 

approaches (NOAA, 2006). The loggerhead turtle is known to nest on Tybee Island located at 

the mouth of the Savannah River, about 8.5 miles downstream from the Terminal Expansion site; 

however, suitable nesting habitat for this species is not available at the terminal site. 

Sea Turtle Impacts 

Due to specific nesting habitat requirements, sea turtles would not likely be present onshore at 

the terminal. In general, sea turtles would be a rare visitor to the terminal area. However, if sea 

turtles were transient to the terminal area, they would be able to avoid the pile driving activities, 

sedimentation from dredging activities, and ballast water withdrawals. Effects from pile driving 

activities during the construction phase would be minimal due to the use of concrete piles. Noise 

associated with the pile driving activities would be expected to be a maximum of 210 db re 1μPa 

which is greater than the 195 db re 1μPa that elicit avoidance behaviors. However, a 

conservative impact zone of 328 feet and 170 db re 1μPa would not be expected to result in any 

pinch points on the Savannah River and migration would still be able to occur. In its comments 

on the draft EIS, NMFS indicated it is consulting with Southern LNG regarding these pile 
 4-81 4.0 –Environmental Impact Analysis 

driving concerns and Southern LNG would implement construction guidelines for protected 

species (see section 4.6.2.2 of this EIS). Due to the level of noise impacts associated with this 

project, we feel that our recommendation for Southern LNG to continue consultation with NMFS 

and file the results of those consultations would minimize noise impacts to a less than significant 

level. 

Sedimentation would mostly be contained within the berthing slip. The sediment that would 

enter the Savannah River Channel would likely be minimal and below levels associated with a 

storm event. Dredging associated with enlarging the berth would be done with the use of a 

cutterhead dredge. There have been two reported incidents of “takings” related to sea turtles due 

to cutterhead dredging. However, given the slow speeds of cutterhead dredges, noise associated 

with the dredge, and the location of dredging being within the vessel berth, impacts to sea turtles 

from cutterhead dredges would not be expected. Impacts associated with the use of hydrolic 

cutterhead dredges are generally considered less than the alternative hopper style dredge that 

could entrain sea turtles and sturgeon. Withdrawals from ballast water would be similar to those 

currently underway at the existing terminal site. Ballast water would be taken on through 0.5 

inch screens that would reduce the possibility of entrainment. 

Many of the sea turtles discussed have feeding, swimming, or resting behaviors that keep them 

near the surface, where they may be vulnerable to boat strikes. In the open waters of the Atlantic 

Ocean, the LNG vessels would represent an incrementally small increase in boat traffic over 

current conditions, relative to the area traversed by sea turtles. The Elba III Project would 

include a potential increase of 95 LNG vessels per year transiting to the terminal, which would 

result in a miniscule increase in potential boat strike risk for sea turtles. On approach to the 

Savannah River Ship Channel, vessel speeds are minimal and boat strike hazards would be 

further reduced, even when considering the additional vessel traffic posed by the LNG vessels. 

Slower speeds would also reduce noise impacts that could occur with increased vessel traffic. 

The Tybee National Wildlife Refuge provides nesting habitat for sea turtles. No reported 

increases in sedimentation have been documented due to the previous expansion of LNG 

shipping traffic due to increased wave action, and none would be expected with this increase in 

vessel traffic either. 

As described above, to help reduce the risk associated with vessel strikes or disturbance of 

protected species, Southern LNG has agreed to include the NOAA Fisheries Vessel Strike 

Avoidance Policy as part of its Terminal Use Agreement with LNG Vessel operators (see 

appendix K). In section 4.6.2.2 of this EIS we further discuss the potential impacts on marine 

organisms, including sea turtles, which could result from dredging activities, pile driving, and 

discharge of hydrostatic test water. 

With Southern LNG’s adherence to NOAA Fisheries Vessel Strike Avoidance Policy and given 

the rare occurrences of sea turtles in the project area, we believe that the Terminal Expansion 

facilities are not likely to adversely affect or significantly impact sea turtles, and the Elba Express 

Pipeline Project would have no effect on sea turtles. 
 4-82 4.0 –Environmental Impact Analysis 

Atlantic and Shortnose sturgeon 

Terminal Expansion and Elba Express Pipeline

The historic range of the federally-listed candidate and South Carolina-listed special concern 

Atlantic sturgeon extended from the Penobscot River, Maine to the St. Johns River, Florida. The 

current range has contracted somewhat and extends from the Kennebec River, Maine to the 

Satilla River, Georgia (NOAA Fisheries and FWS, 2007). The Satilla River is about 88 miles 

south of the Savannah River. Currently, Atlantic sturgeon are present in 32 rivers and spawning 

populations have been documented in 14 rivers, and possibly, in an additional five rivers. The 

NMFS, FWS, and USGS are currently in the process of updating the NOAA Fisheries and FWS 

1998 status review report for Atlantic sturgeon due to concerns over the current status of this 

species throughout its range (NOAA Fisheries, 2007a). In its 1998 status review report, NOAA 

Fisheries and FWS indicted that the Savannah River supports a reproducing population of 

Atlantic sturgeon (NOAA Fisheries and FWS, 2007). Threats to the Atlantic sturgeon 

populations include over-harvest and habitat degradation (NOAA Fisheries, 2007b). 

Because of the highly migratory nature of the Atlantic sturgeon, it requires access to an 

expansive variety of high quality freshwater and marine habitats. Adult Atlantic sturgeon 

migrate through nearshore Atlantic shelf waters and enter coastal sounds, bays and inlets to 

access the river basins in which they spawn. Atlantic sturgeon spawns in freshwater channel 

habitats from tidal river reaches to at least as far inland as the fall line in large, unobstructed river 

basins. Both spawning and egg survival to hatching are dependent upon habitats with low to 

moderate flows and limited sedimentation. During the fall and winter, Atlantic sturgeon move 

seaward into brackish and estuarine channels and it over winters in deep channels and holes 

within coastal sounds and bays (SCDNR 2007). 

The federally-listed endangered and state-listed endangered shortnose sturgeon possibly occurs 

near Elba Island in Chatham County, Georgia (FWS, 2000) and in major waterbodies (greater 

than 100 feet wide) along the proposed pipeline route. Shortnose sturgeon are known to spawn 

within the Savannah River at spawning sites about 10 miles north of Elba Island. The shortnose 

sturgeon’s range extends from the St. John’s River in Florida to the St. John River in New 

Brunswick, Canada (GDNR, 1999). Threats to the shortnose sturgeon populations include overharvest, incidental killing by drifting gill nets, and spawning habitat alteration due to dredging 

and alteration of the flows in rivers. 

Shortnose sturgeon inhabit large coastal rivers and are considered anadromous, meaning they 

travel up large coastal rivers to spawn but reside in the lower river estuaries the rest of the year 

(GDNR, 1999). Their breeding preferences include swift waters over gravel or course substrate 

usually associated with submerged timber. Upstream migration begins in February when water 

temperatures exceed 9° C (48° F), and migration downstream to the estuaries begins in March 

(GDNR, 1999). Spawning in males begins at age 2-3, whereas females mature at age 6 in 

Georgia (GDNR, 1999). Females lay as many as 200,000 eggs on course substrates. 

After hatching, larvae drift down river from the spawning site prior to becoming demersal. 

Young, juvenile, and adult stages of the shortnose sturgeon are known to be demersal and rely 
 4-83 4.0 –Environmental Impact Analysis 

upon benthic food resources. Young shortnose sturgeon reach a size of 5.5 to 11.8 inches in 

length and are capable of readily avoiding velocities of 1.0 foot per second. 

As discussed in section 4.3.3, pump intakes would be appropriately screened with a 1/2-inch 

wire-mesh to prevent the entrainment of large particles during hydrostatic test water withdrawal. 

To prevent the impingement/entrainment of fish species on the screens, screen boxes would be 

sized such that the velocity of the inflowing water at the screen surface would be significantly 

less than the typical maximum swimming velocities of adult fish species of concern in the 

Savannah River (less than 0.5 foot per second). The LNG vessels calling on the Elba Island 

Terminal would take on ballast while discharging LNG. Ballast water intake by additional 

vessels at the terminal would be similar to ballast water intake by vessels that currently call on 

the terminal, as well as others that unload cargo at other points of call along the Savannah River 

transit corridor and this impact would not add appreciably to current impacts. 

Noise associated with the installation of the sheet pile bulkhead would be minimal because of the 

use of a vibratory hammer. Conversely, noise associated with the pile driving activities would 

be expected to be a maximum of 210 db re 1μPa which is greater than the 195 db re 1μPa that 

elicit avoidance behaviors. However, a conservative impact zone of 328 feet at 170 db re 1μPa 

would not be expected to result in any pinch points on the Savannah River and migration would 

be able to occur. In its comments on the draft EIS, NMFS indicated that Southern LNG is 

consulting with the NMFS regarding these pile driving concerns and would implement 

construction guidelines for protected species (see section 4.6.2.2 of this EIS). We have also 

recommended that Southern LNG continue its consultation to further reduce noise impacts 

associated with pile driving activities. 

Sedimentation would mostly be contained within the berthing slip. The sediment that would 

enter the Savannah River Channel would likely be minimal and below levels associated with a 

storm event. Dredging associated with enlarging the berth would be done with the use of a 

cutterhead dredge. Given the slow speeds of cutterhead dredges, noise associated with the 

dredge, and the location of dredging being within the vessel berth, impacts to shortnose sturgeon 

from cutterhead dredges would not be expected. Withdrawals from ballast water would be 

similar to those currently underway at the existing terminal site. Ballast water would be taken on 

through 0.5 inch screens that would reduce the possibility of entrainment. 

Water quality impacts associated with dredging at the berth are discussed in section 4.3.3. 

Both the Ogeechee River and Savannah River have historic (Atlantic) and known (shortnose) 

populations of sturgeon. The Elba Express Pipeline would cross Ogeechee Creek at MP 33.9 

which is about 3.5 miles northeast of the Ogeechee River. Although a population of Atlantic 

sturgeon apparently persisted in the Ogeechee River, results of sampling efforts during 1991 to 

1994, 1997, and 1998 suggest that juveniles were scarce and apparently absent in some years, 

indicating spawning or recruitment failure (NOAA Fisheries and FWS, 2007). EEC would not 

cross the Ogeechee River. The Elba Express Pipeline would cross the Savannah River at MP 

187.5, below the New Savannah Bluff Lock and Dam and two dams above the Augusta 

Diversion Dam. Although potential sturgeon habitat occurs in this area, currently there is no 

passage at the Augusta Diversion Dam through which the shortnose or Atlantic sturgeon can 
 4-84 4.0 –Environmental Impact Analysis 

migrate into the northern reaches of the Savannah River. Since EEC would employ the HDD 

method for crossing the Savannah River no impacts are anticipated to the Atlantic or shortnose 

sturgeon (see section 4.6.2). 

The currently proposed Elba III Project includes construction and operation of the Terminal 

Expansion and Elba Express Pipeline facilities as well as additional LNG vessels calling on the 

Elba Island Terminal. As discussed in section 4.6.2, Southern LNG and EEC would implement 

measures to avoid, minimize, or mitigate impacts on aquatic species, including the shortnose 

sturgeon. We believe that the proposed Elba III Project (i.e., expansion of the LNG Terminal, 

construction and operation of the Elba Express Pipeline, and additional LNG vessels calling on 

the Terminal) is not likely to adversely affect or significantly impact the Atlantic or shortnose 

sturgeon. 

Elba Express Pipeline

American Alligator 

Numbers and distribution of the American alligator do not support federal listing of the alligator 

as threatened, but rather it is listed due to similarity in appearance with the American crocodile. 

The alligator inhabits freshwater swamps and marshes, but is also found in rivers, lakes, and 

smaller bodies of water. Nesting times vary, but can be expected to occur in late spring to early 

summer (FWS, 2000). This species may potentially occur in South Carolina and Georgia near the 

Elba Express Pipeline Project. 

Impacts on this species resulting from construction of the Elba Express Pipeline Project would be 

temporary as individuals may be disturbed and displaced to adjacent wet habitat. It is likely that 

individuals would return to the wet habitats traversed by the pipeline ROW after the completion 

of construction. Additionally, although there would be the conversion of swamp forests to marsh 

and shrub swamps, long-term adverse effects on the species are not expected because American 

alligators use all of the above habitats. Thus, we conclude the Elba Express Pipeline Project is 

not likely to adversely affect the American alligator. 

Eastern Indigo Snake 

The federally-listed and Georgia state threatened eastern indigo snake possibly occurs in or near 

Elba Island in Chatham County, Georgia (FWS, 2000), and along the proposed pipeline route in 

Chatham, Effingham, and Screven counties, Georgia. Historically the eastern indigo snake 

ranged from southern South Carolina south and west to southeastern Mississippi. Current data 

show only small, fragmented populations in southern Georgia and Florida. Eastern indigo 

snakes are thought to rely heavily on burrows of the gopher tortoise for wintering, and the 

documented reduction in gopher tortoise populations is thought to have had a cause and effect 

relationship on the indigo snake. Another contributing factor to the decline of the eastern indigo 

snake is thought to be the lack of natural communities within the coastal plain, which is a result 

of agricultural and silvicultural development. 
 4-85 4.0 –Environmental Impact Analysis 

In warmer months, the eastern indigo snake prefers foraging habitat on the edge of wetland areas 

where frogs and snakes are present. Flood plains or the periphery of cypress ponds, either 

adjacent or interspersed with sandy uplands, are used during the summer months. Eastern indigo 

snakes are closely associated with longleaf pine habitats, such as sand hills and turkey oak. Prey 

consists of a variety of birds, small mammals, fishes, frogs, turtles, lizards, and snakes. Home 

range size is large during warmer months, sometimes greater than 250 acres. Upland sand ridges 

are preferred during the winter months. Breeding occurs from November until April, and 

females usually lay 5-10 eggs in May or June (GDNR, 1999). Nests are usually placed in 

tortoise burrows. 

During field surveys, EEC initially identified gopher tortoise burrows in three locations along the 

proposed pipeline route in Screven County, Georgia (MPs 33.2, 33.3, and 34.5). There were a 

total of 26 gopher tortoise burrows identified during the initial field surveys conducted during 

April 2006. Of this amount, 18 were active burrows, 2 were inactive, and 6 were abandoned. 

Given the preference of indigo snakes to utilize gopher tortoise burrows during the winter 

season, the potential exists for snakes to be affected during construction through areas of gopher 

tortoise burrows. In order to avoid impacts on eastern indigo snakes occupying gopher tortoise 

burrows, EEC has proposed to implement the following measures along the Elba Express 

Pipeline Project: 

• conduct pre-construction surveys of the proposed construction corridor, all proposed 

facilities sites, all pipe storage/contractor work yards, and all adjacent areas that have 

been previously identified as suitable habitat for gopher tortoises and commensal species 

(species that may also use gopher tortoise burrows), and that may be potentially disturbed 

during construction. Each burrow would be inspected with a remote video system to 

determine occupancy by tortoises and/or protected commensal species; 

• scope and check gopher tortoise burrows for eastern indigo snake sign (tracks, shed skins, 

eggs, etc.) before they are excavated and collapsed. Any vertebrate species utilizing the 

burrows during this period would be allowed to vacate the burrow or would be relocated 

(excluding indigo snakes, which would be allowed to leave the burrows of their own 

accord and not relocated) to an unused burrow in adjacent habitat off of the ROW; and 

• monitor any eastern indigo snake eggs found within a gopher tortoise burrow until the 

eggs hatch and the snakes leave the burrow. Once gopher tortoise burrows are vacated by 

eastern indigo snakes the burrows would be excavated and collapsed and the work area 

would be fenced to prevent the immigration of eastern indigo snakes and laying of eggs. 

In its comments on the draft EIS, EEC stated that all construction activities within the vicinity of 

occupied gopher tortoise burrows would be monitored by biologists with previous gopher 

tortoise and indigo snake experience. All construction areas, open trenches, and spoil piles in the 

vicinity of the occupied gopher tortoise burrows would be inspected daily prior to the initiation 

of construction activities. If new burrows are found the measures described above would be 

implemented. 

In the event that a new burrow is discovered during construction and it is determined it is being 

used by an eastern indigo snake, EEC would allow the snake to vacate the burrow prior to 
 4-86 4.0 –Environmental Impact Analysis 

resuming construction in that area. If an indigo snake is seen on the construction ROW, EEC 

would cease all activities until the snake has left the area. 

Although capture and relocation of indigo snakes would likely avoid adverse direct impacts on 

the individuals, handling of snakes would be considered harm under the definition of the ESA 

and would require formal consultation between the FERC staff and the FWS. However, if EEC 

could allow individual snakes to leave burrows on their own accord or avoid those burrows 

occupied by snakes during construction and therefore avoid handling, adverse impacts on snakes 

could be also avoided. Given the low likelihood of encountering eastern indigo snakes along the 

Elba Express Pipeline project due to the relatively low number of burrows identified along the 

project corridor, we believe that EEC should be able to allow this to occur. Because we believe 

the likelihood of encountering eastern indigo snakes in gopher tortoise burrows occurring along 

the Elba Express Pipeline project is low and that EEC should be able to allow individual snakes 

to leave burrows on their own accord or avoid those burrows occupied by snakes during 

construction and avoid handling of individual snakes if identified during surveys, the Elba 

Express Pipeline Project is not likely to adversely affect the eastern indigo snake. 

Wood Stork 

The federally-listed endangered wood stork possibly occurs in or near Elba Island in Chatham 

County, Georgia (FWS, 2000), and along the proposed pipeline route in Anderson County, South 

Carolina and in Chatham, Effingham, Screven, Jenkins, Burke, Jefferson, Glascock, Warren, 

McDuffie, Wilkes, Elbert, and Hart counties, Georgia. 

The wood stork’s breeding range includes the southeastern United States including Florida, 

Georgia and South Carolina, both coasts of Mexico and Central America, Cuba, and South 

America from Columbia to Argentina. After the breeding season, wood storks are thought to 

disperse north to North Carolina, Tennessee, and Arkansas. The main cause of population 

decline is loss of habitat. The direct loss of feeding habitat through draining and filling of 

wetlands has caused much of the breeding habitat of Florida to become unsuitable (GDNR, 

1999). The breeding population estimates from 1995 indicate around 7,853 breeding pairs in 

Florida, Georgia, and South Carolina (GDNR, 1999). 

Wood storks use a variety of estuarine and freshwater wetlands for breeding, feeding, and 

roosting. Wood stork breeding generally begins in summer when the birds gather in large 

communal roosts along coastal areas. They are colonial nesters, and several nests are often 

located in the same tree. Colony sizes range from 12 to 500 nests. Nests are located in trees over 

standing water or in trees next to water. Storks sometimes forage considerable distances from 

nesting sites. Forage mainly consists of fish, crayfish, amphibians, and small aquatic animals. In 

Georgia and South Carolina breeding begins in March, with clutch sizes from 2 to 5 eggs 

(GDNR, 1999). Incubation takes from 27 to 32 days, and the young fledge around 12 weeks 

after hatching. 

A known wood stork rookery is located approximately 5 miles west of the proposed pipeline 

route near MP 70.0 at the Big Dukes Natural Area in Jenkins County, Georgia, and is the largest 
 4-87 4.0 –Environmental Impact Analysis 

known wood stork breeding colony in Georgia. The proposed pipeline would occur within 

foraging habitat for the adult wood storks. 

The FWS has developed Habitat Management Guidelines for the Wood Stork in the Southeast 

Region which include mitigation measures such as: establishment of a buffer zone (i.e., no 

human intrusion) of 300 feet around feeding sites where a solid vegetation screen exists; 

establishment of a buffer zone 750 feet in areas with no vegetation screen; establishment of a 

1,000- to 1,500-foot primary zone buffer in all directions from the actual colony boundary when 

there are no visual or broad aquatic barriers (never less than 500 feet when there are strong visual 

or aquatic barriers); establishment of a secondary zone buffer that extends to a radius of 2,500 

feet from the outer edge of the colony; avoidance of human activities within 500 to 1,000 feet of 

roost sites during the seasons of the year and times of day when storks may be present, especially 

avoidance of nocturnal activities; and protection of vegetative and hydrological characteristics of 

the more important roosting sites, which are those that are used annually and/or used by flocks of 

25 or more storks. 

EEC indicated that foraging habitat is located within the project area. Any disruption to this 

habitat would be temporary. Further, EEC has agreed to stop construction in the event any wood 

storks are present during construction.

EEC indicated that it would address potential impacts and mitigation requirements for the wood 

stork in its Sensitive Species Mitigation Plan (SSMP), which would be prepared in consultation 

with the FWS, GDNR, SCDNR, and NOAA Fisheries. Implementation of mitigation measures 

agreed to by EEC and consultations with the appropriate federal and state agencies would 

minimize impacts on wood storks such that we believe that the Elba Express Pipeline project is 

not likely to adversely affect the wood stork. 

Flatwoods Salamander 

The federally-listed threatened and South Carolina endangered flatwoods salamander possibly 

occurs in or near Elba Island in Chatham County, Georgia (FWS, 2000). Initial field surveys 

conducted by EEC revealed that potentially suitable flatwoods salamander habitat occurs along 

the proposed pipeline route in Effingham, Chatham, and Screven counties, Georgia. The 

flatwoods salamander is restricted to the Coastal Plain of South Carolina, Georgia, Florida, and 

Alabama. This salamander is endemic to mesic flatwoods habitats within the vanishing longleaf 

pine, wiregrass community type (GDNR, 1999). Habitat loss has been the primary reason for the 

salamander’s decline throughout its native range. Agricultural and silvicultural practices have 

diminished the once abundant longleaf pine flatwoods community. Ditching and draining often 

accompany these practices, altering the hydrology of the soils. This has an effect on the fossorial 

and aquatic existence of the salamander, as well as interfering with the successful migration of 

the species. Ditching and draining isolated wetlands used by breeding flatwoods salamanders 

significantly shortens their hydroperiod, halting larval development prior to metamorphosis 

(GDNR, 1999). Fire suppression has also reduced the amount of suitable habitat. 

Flatwoods salamander habitat includes pine flatwoods, which are fire-dependent communities 

requiring periodic burns to promote grasses and forbs, while limiting shrubs and hardwoods. As 
 4-88 4.0 –Environmental Impact Analysis 

adults, flatwoods salamanders are fossorial, living in burrows below the soil surface. Breeding 

sites are typically shallow, ephemeral cypress and/or swamp tupelo ponds or “domes,” though 

flooded roadside ditches and fire lines are occasionally used. Breeding areas also depend on 

frequent dry season fires to keep emergent and subemergent vegetation the dominant species 

composition. Breeding begins with the onset of cold rains in the fall to early winter (GDNR, 

1999). Mature salamanders nocturnally migrate in large groups to isolated wetlands. Movements 

of up to a mile or more have been reported from the breeding site to a terrestrial retreat. After 

breeding, the female deposits up to 225 eggs singly or in groups in the dry portion of a pond 

basin or in grassy areas on pond margins, usually under leaf litter or logs, at the base of grassy 

clumps, or at the entrance of crayfish burrows. After hatching, an 11-18 week developmental 

period follows and larvae metamorphose in March or April. Since EEC would construct its 

pipeline during the summer and winter months, construction related activities could interfere 

with the breeding season. In its comments on the draft EIS, EEC indicated that biological 

surveys for flatwoods salamander, and other protected species, would be conducted in the spring 

of 2008, within one year of the start of construction. If flatwoods salamander are found in the 

construction work area, EEC would consult with the FWS to develop specific mitigation 

measures to avoid or minimize impacts to this species and incorporate those measures into its 

SSMP. 

We recommend that EEC file with the Secretary completed surveys for flatwoods 

salamander habitat along the pipeline route (i.e., MP location of suitable habitat), and 

provide copies of any correspondence with the FWS including recommended mitigation 

measures. 

By conducting surveys prior to construction to identify areas of suitable flatwoods salamander 

habitat and implementing measures to avoid impacts on habitat and/or individual salamanders, 

we conclude the Elba Express Pipeline project is not likely to adversely affect flatwoods 

salamanders. 

Canby’s Dropwort 

Initial field surveys conducted by EEC revealed that potentially suitable habitat for the federallylisted endangered Canby’s dropwort possibly occurs in or near the project area in Screven, 

Burke, and Jenkins counties, Georgia. Historical range includes the Coastal Plain from 

southwestern Georgia to southeastern North Carolina, disjunct in Maryland, and possibly 

extirpated in Delaware (GDNR, 1995). Canby’s dropwort is rare throughout its range and has 

experienced significant habitat loss due primarily to draining of its habitat for agricultural land. 

Canby’s dropwort can be found in peaty muck of shallow cypress ponds, wet pine savannas, and 

adjacent sloughs and drainage ditches (GDNR, 1995). The white flower of this species is noted 

as occurring from May through August, although past surveys indicate blooming in the project 

area occurs between late July and October. 
 4-89 4.0 –Environmental Impact Analysis 

Pondberry 

The federally-listed endangered pondberry possibly occurs in or near the proposed Elba Express 

Pipeline Project in Chatham County, Georgia (FWS, 2000) and initial field surveys conducted by 

EEC revealed that potentially suitable pondberry habitat occurs along the proposed pipeline route 

in Effingham and Screven counties, Georgia. The historical range of pondberry is the 

Southeastern Coastal Plain from North Carolina to Louisiana and north to southeastern Missouri 

in the Mississippi Embayment (apparently extirpated in the Florida Panhandle). Pondberry is 

rare throughout its range, and has experienced significant habitat loss due to draining of its 

habitat for conversion to agriculture or pine plantation. The species is dioecious (with separate 

male and female plants), which makes it much more susceptible to habitat fragmentation. Due to 

habitat loss, plants become highly isolated, further reducing the chance that pollination would 

occur. Many remaining populations consist of male plants, usually sprouts from a single 

individual (GDNR, 1995). 

Habitat preference for pondberry is shallow, depressional wetlands and ponds of sandhills, along 

margins of cypress ponds, and in seasonally wet, low areas among bottomland hardwoods 

(GDNR, 1995). 

Pool Sprite 

Initial field surveys conducted by EEC revealed that potentially suitable habitat for the federallythreatened pool sprite potentially occurs along the proposed pipeline route in Wilkes, Warren, 

and McDuffie counties, Georgia. The pool sprite occurs in shallow flat-bottomed depressions on 

granite outcrops in the Piedmont of Georgia. Flowering occurs in March and April (Patrick et al. 

1995) and the plants disintegrate soon after fruiting. Pool sprite is threatened by disturbances 

such as cattle grazing, off-road vehicle traffic, and outcrop mining. 

EEC has indicated that potentially suitable habitat for Canby’s dropwort, pondberry, and 

poolsprite was present along the pipeline. EEC proposes to re-survey areas of potentially 

suitable habitat in 2007. We recommend that if Canby’s dropwort, pondberry, and/or 

poolsprite are identified during surveys, EEC should contact the FWS to obtain guidance 

regarding a course of action to be taken to avoid or minimize impacts on these species 

during construction. Prior to construction, EEC should file the completed survey report 

with the Secretary that contains the following information: 

a. name(s) and qualifications of the person(s) conducting the survey; 

b. method(s) used to conduct the survey; 

c. date(s) of the survey; 

d. area surveyed (include the MP surveyed); and 

e. proposed mitigation that would substantially minimize or avoid the potential 

impacts. 

Copies of all coordination, including any recommended mitigation measures, should be 

filed for review and approval by the Director of OEP. 
 4-90 4.0 –Environmental Impact Analysis 

By developing construction methods for the project and implementing our recommendations, we 

believe that the Elba Express Pipeline project is not likely to adversely affect Canby’s dropwort, 

pondberry, and poolsprite. 

Effects of a Spill on Federally Listed or Special Status Species 

Impacts on federally listed species resulting from the proposed increase of LNG vessel traffic in 

the Savannah River Channel are discussed above; the following discussion addresses potential 

impact on federally listed species resulting from an LNG hazardous incident. If an unignited 

LNG spill were to occur along the transit corridor within the Zones of Concern, any listed 

species within Zone 1 (as defined in section 4.12.4.3 of this EIS) could be impacted. Figures 

4.7-1 to 4.7-3 show the locations of threatened and endangered species along the LNG transit 

route. Because LNG is lighter than water, the LNG would float on the water until it had 

vaporized. 

If any listed species were to come into contact with the LNG, it would experience an extreme 

temperature change, and could be injured or expired. The LNG from any release along the 

transit would rapidly cool water within the LNG pool. Because the more dense cold water would 

settle to the bottom of the channel, it could temporarily impact the benthos and species beneath 

the pool of LNG. However, the temperature change would be greatest at the surface, with 

decreasing affects as depth is increased within the water column. Whales and sturgeon within 

the LNG marine traffic area would not be affected by the cold water or boil effect because they 

would to be in deep water or avoid the impacted area. Additionally, whales within the project 

area are less sensitive to colder temperatures than many other species. However, manatees and 

sea turtles would be expected to avoid, if possible, the colder water due to their sensitivity (as 

described in section 4.6.2.3 of this EIS). Formation of a cold, heavier-than-air vapor cloud could 

cause significant impacts on some terrestrial listed species within Zone 1 from asphyxiation. 

Transient wood storks flying over the spill could experience inhalation problems, and possibly 

asphyxiate. The marine transit safety and security measures (as described in sections 4.12.4 and 

4.12.6 of this EIS) make the likelihood of an LNG vessel spill from collisions, allisions, and 

terrorist attacks extremely remote. As a result, no significant impact on whales, manatees, sea 

turtles, wood storks, or sturgeon would be anticipated from an unignited marine LNG spill within 

Zone 1. No impacts would be expected outside of Zone 1 from a release of LNG. 

If a pool fire were to occur in association with a release of LNG, species on or near the surface of 

the water within Zone 1 could be experience injury or mortality either by the fire or radiant heat. 

Species within Zone 2 may be impacted by radiant heat, while others may be impacted by 

displacement from its native habitat. However, given the resilience of vegetation in wet warm 

climates, and that root systems would likely remain in tact, these impacts would not be expected 

to be permanent. No impacts would be expected to species within Zone 3 from a pool fire. The 

maximum flammable range for a vapor cloud could extend to the outer limits of Zone 3. If the 

vapor cloud were to come in contact with an ignition source, the resulting fire could burn back to 

the spill and impact any listed species it came in contact with. 
Non-Internet Public 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED ELBA III PROJECT 

Docket Nos. CP06-470-000, CP06-471-000, CP06-472-000, 

CP06-473-000, and CP06-474-000 

Page 4-91 

Figure 4.7-1 

Invertebrate, Bottlenose Dolphin, and Loggerhead Sea Turtle 

Areas within Zones of Concern 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 
Non-Internet Public 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED ELBA III PROJECT 

Docket Nos. CP06-470-000, CP06-471-000, CP06-472-000, 

CP06-473-000, and CP06-474-000 

Page 4-92 

Figure 4.7-2 

Threatened and Endangered Birds within Zones of Concern 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 
Non-Internet Public 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED ELBA III PROJECT 

Docket Nos. CP06-470-000, CP06-471-000, CP06-472-000, 

CP06-473-000, and CP06-474-000 

Page 4-93 

Figure 4.7-3 

Fish Species of Concern within Zones of Concern 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 
 4-94 4.0 –Environmental Impact Analysis 

Federally Listed or Special Status Species Conclusion 

Section 7 of the ESA requires a federal agency to consult on a permitted “proposed action” and 

reasonably foreseeable events associated with that action. A spill event or other emergency type 

action is not a part of the defined proposed action. The marine transit safety and security 

measures make the likelihood of an LNG vessel spill from collisions, allisions and terrorist 

attacks extremely remote. Due to the extremely unlikely nature of a spill from an LNG vessel, 

we would not modify our affects determinations, as discussed above. If a release of LNG were 

to occur, and listed species were impacted, we would consult with the FWS and/or NMFS 

regarding impacts on those species under an emergency consultation (50 CFR §402.05). 

Except for areas underlying permanent aboveground facilities, all areas disturbed by construction 

would be returned to pre-construction conditions, which would restore habitat value of these 

temporarily disturbed areas. Habitat at sites of permanent aboveground facilities would be 

converted to industrial use. We believe that implementation of the mitigation measures proposed 

to protect wildlife, aquatic resources, and habitat as described in section 4.6 of this EIS, as well 

as species-specific recommendations, would be sufficient to prevent significant adverse effects 

on threatened and endangered species. Therefore, we believe that the project would have no 

effect or would not be likely to adversely affect any federally or state-listed threatened or 

endangered species. However, because we have requested that the FWS and the NMFS consider 

this EIS as our Biological Assessment for the Terminal Expansion and Elba Express Pipeline 

Projects with respect to construction, maintenance, and associated operational activities, in order 

to comply with our responsibilities under Section 7 of the ESA, we recommend that Southern 

LNG and EEC not begin construction of facilities for the respective projects until: 

1. all outstanding biological surveys have been completed; 

2. the staff completes any necessary consultations with FWS and NMFS; and 

3. Southern LNG and EEC have received written notification from the Director 

of OEP that construction and/or use of mitigation (including implementation 

of conservation measures) may begin. 

4.7.2 State-Listed Threatened, Endangered or Species of Concern 

Reptiles

Gopher Tortoise 

Gopher tortoise is listed as threatened in the state of Georgia. The gopher tortoise potentially 

may occur in Chatham, Effingham, Screven, Jenkins, Burke, and Jefferson (MP 0.0 to 107.7) 

counties of Georgia. This species inhabits sandy coastal plain areas from extreme southern 

South Carolina to the southeastern corner of Louisiana, and throughout most of Florida. 

Individuals may occur on well-drained, sandy soils in transitional areas. Gopher tortoises also 
 4-95 4.0 –Environmental Impact Analysis 

are associated with a pine overstory and an open understory with a grass and forb groundcover 

and sunny areas for nesting. They are commonly found in self-made, unusually long burrows 

which often are used by other animals. Females lay eggs between late April and mid-July. 

These eggs hatch between August and September. 

During field surveys, EEC initially identified gopher tortoise burrows at three locations along the 

proposed pipeline route in Screven County, Georgia (MPs 33.2, 33.3, and 34.5). There were a 

total of 26 gopher tortoise burrows identified during the initial field surveys conducted during 

April 2006. Of this amount, 18 were active burrows, 2 were inactive, and 6 were abandoned. 

If occupied during construction, mechanical crushing of active burrows could result in injury or 

death of gopher tortoises. Additionally, if gopher tortoises occupying adjacent habitats were 

present on the ROW during construction, injury or mortality could also occur if the individuals 

were not avoided. To minimize impacts on this species, EEC has proposed mitigation plans for 

the gopher tortoise that would be implemented prior to and during construction, and during 

maintenance of the proposed facilities. Major points from the mitigation plans are summarized 

below. Any discussion pertaining to “protected commensals” is secondary to measures 

described for individual species elsewhere in this document, especially for the eastern indigo 

snake. 

Preconstruction Measures

Prior to initiation of construction activities, EEC would survey for gopher tortoise burrows and 

the presence/absence of indigo snakes. At each identified location EEC would implement the 

following methodology: 

1. Surveyors would walk transects and visually search the area for previously identified, as 

well as any unidentified, gopher tortoise burrows. The apron and entrance to any gopher 

tortoise burrow would be examined for snake activity and global positioning system 

(GPS) locations would be confirmed and/or recorded. 

2. After visual observation of the habitat for the presence/absence of gopher tortoise 

burrows, and indigo snakes, efforts would be made to further analyze the habitat. All 

active, inactive and abandoned gopher tortoise burrows would be inspected with a remote 

video system to determine occupancy by indigo snakes, gopher tortoises and/or protected 

commensal species. Consultations with FWS would be conducted to determine the best 

alternatives to proceed with construction if indigo snakes are verified by surveyors. After 

the absence of indigo snakes at an area has been established, all protected commensal 

species would be given opportunity to leave burrows on their own, or trapped if 

necessary. 

3. All burrows (active, inactive, and abandoned) would be excavated to conclusively 

determine that they are unoccupied by indigo snakes, gopher tortoises or vertebrate 

commensals. These activities would be directly supervised by a biologist with previous 

experience excavating gopher tortoise burrows. Throughout the excavation process, the 

burrow would be frequently inspected to insure that the tortoise/commensal has not 
 4-96 4.0 –Environmental Impact Analysis 

moved to a position where it might be injured by the backhoe or shovel. Following 

removal of any tortoise and/or commensal, all excavated burrows would be filled. 

4. Gopher tortoise burrows adjacent to the construction corridor would be clearly identified 

and protected to prevent inadvertent impacts from heavy equipment and related 

construction activities. Barricade fencing would be erected along the edge of the ROW 

and would be monitored and repaired/replaced, as necessary, throughout construction. 

After construction, re-vegetation, and final cleanup of the ROW are complete the fencing 

would be removed. 

5. A survey report documenting the results of the preconstruction survey, capture and 

displacement of gopher tortoises would include the name(s) and qualifications of the 

investigator(s); survey date(s); area surveyed (including mileposts); specific burrow 

location(s) (milepost, distance from pipeline center), and direction; survey method(s); 

burrow size, condition, and activity level (active, inactive, or old); the individual marking 

used to identify each relocated tortoise and their associated original and relocated burrow 

sites; mitigation measures to be implemented and, if applicable, relocation site and date 

of relocation; and conclusions. 

Construction

1. A biologist with previous gopher tortoise and protected commensal experience would be 

on-site to monitor all construction activities within the vicinity of occupied tortoise 

burrows. 

2. All construction areas, trenches, and spoil piles in the vicinity of occupied gopher tortoise 

burrows would be inspected daily prior to the start of any construction activities. 

3. Any new burrows that are identified during daily surveys would be inspected for 

occupancy using a remote video system. Occupied burrows would be excavated and the 

tortoises and/or protected commensals handled for data collection and released into 

nearby unoccupied/starter burrows following preconstruction procedures. 

4. Except in emergency situations, only project biologists and specifically trained EIs would 

be allowed to handle tortoises and protected commensal species. These individuals 

would wear pagers and have access to radios and/or cellular phones while in the field. 

5. If a gopher tortoise or commensal species is encountered by construction personnel 

within the construction corridor, all activities that might harm the species would be 

stopped and a project biologist or EI would be summoned. 

6. At no time would construction equipment or fuel be stored (overnight or long-term) 

within 100 feet of any occupied gopher tortoise burrows. No fueling of equipment would 

take place within 100 feet of any occupied gopher tortoise burrows. 
 4-97 4.0 –Environmental Impact Analysis 

7. If a gopher tortoise or protected commensal species is found dead during construction 

activities, the specimen would be frozen and the FWS or GDNR, would be notified 

within 24 hours of the incident. 

Post-Construction ROW Maintenance and Operation

1. Mowing activities would be conducted during the gopher tortoise’s inactive season, 

between November 1 and March 1. 

2. EEC would train mowing personnel in gopher tortoise awareness and would provide 

maps showing the locations of known active/inactive burrows on or near the ROW. 

3. Mowers would reduce the speed of power equipment within 50 feet of burrows. 

4. Hand pushed mowers and hand-held equipment would be used within 15 feet of tortoise 

burrows, and maintenance personnel would avoid mowing across the burrow apron, 

burrow entrance, and the area immediately behind the entrance. 

5. Except for travel on existing roads and paths, routine maintenance activities unrelated to 

vegetation maintenance would be restricted to areas at least 15 feet from tortoise burrows. 

Where these activities may be required to be closer than 15 feet from burrows, only 

handheld equipment would be used and the maintenance personnel would avoid the 

burrow apron, entrance, and area immediately behind the entrance. 

6. Gopher tortoise burrows within 50 feet of maintenance activities requiring excavation 

would be clearly marked for avoidance, and all excavation areas within the vicinity of 

gopher tortoise burrows would be surrounded by a fence with a minimum two-inch mesh 

to exclude tortoises. 

7. If maintenance activities require capture and displacement of gopher tortoises or 

protected commensal species, a qualified biologist would be called to trap/excavate the 

individual, collect data, and release the individual into a nearby unoccupied/starter 

burrow using preconstruction relocation procedures. 

8. In the event of emergency repair, all efforts would be made to protect any tortoises and 

commensals that may be located in the area, and a biologist would be called to the site as 

soon as possible to assess the potential impacts of the emergency situation and repair 

work on nearby tortoises or protected commensal species. The nearest FWS or GDNR 

office would be immediately contacted concerning any adverse effects on these species. 

9. If a gopher tortoise or protected commensal species is found dead during maintenance 

activities, the FWS or GDNR, would be notified within 24 hours of the incident. 

No gopher tortoise burros were found during surveys of the terminal; therefore, no impacts to 

this species are expected from construction of the Terminal Expansion facilities. Impacts on the 

gopher tortoise from the proposed Elba Express Pipeline Project would be temporary due to 
 4-98 4.0 –Environmental Impact Analysis 

displacement of individuals during construction. The temporary loss of habitat during 

construction could also affect gopher tortoises. However, maintenance of the ROW during 

operation of the proposed pipeline facilities would create better foraging and refuge sites in areas 

of marginal habitat. With implementation of EEC’s proposed mitigation measures, the impact of 

the proposed facilities on gopher tortoises would be minimized and the proposed project would 

not likely result in adverse impacts on this species. 

Fish 

Bluebarred Pygmy Sunfish 

Bluebarred pygmy sunfish is listed as endangered in Georgia and is found in all crossings of 

Brier Creek system and its tributaries. EEC would cross Big Brier Creek at MP 119.2. 

Bluebarred pygmy sunfish are restricted to the lower Savannah River drainage in Georgia and 

South Carolina. It inhabits drainage ditches, stagnant ditches and the backwaters of creeks and 

rivers and is found in shallow water with abundant submerged and/or emergent vegetation that is 

rooted in soft detritus-rich substrate. It often inhabits disturbed areas such as roadside ditches 

and backwaters near boat ramps (SCDNR, 2007b). 

The GDNR stated in a letter dated December 12, 2006, that all stream crossings within the Brier 

Creek system between the confluence of Brushy Creek and the upstream watershed boundary 

should be surveyed by a qualified biologist for the presence of this species. If the species, or 

suitable habitat, is found within a waterbody crossing, then the GDNR suggested that the HDD 

method be used at that crossing. However, if EEC decides to use the HDD method for all 

waterbody crossings within the Brier Creek system then the GDNR indicated that surveys would 

not be required. If bluebarred pygmy sunfish or suitable habitats for this species are identified 

during field surveys, we recommend that EEC file, for the review and written approval of 

the Director of OEP, the results of consultation with the GDNR regarding avoidance or 

minimization of impacts on the bluebarred pygmy sunfish prior to construction.

This recommendation would reduce the likelihood of construction related sedimentation 

impacting the bluebarred pygmy sunfish and therefore minimize the level of impacts to this 

species. 

Robust Redhorse 

Robust redhorse sucker is listed as endangered in Georgia and is found in the Ogeechee River 

and Broad River watersheds. This species is the focus of an intensive recovery effort by the 

interagency Robust Redhorse Conservation Committee (RRCC), designed to prevent federal 

listing under the ESA. 

The historic range of the robust redhorse is believed to include Atlantic slope drainages from the 

Pee Dee River in North Carolina to the Altamaha River in Georgia. The only recent verified 

records from natural populations are from the Pee Dee River in North Carolina and the 

Savannah, Oconee and Ocmulgee Rivers in Georgia. However, in addition to these rivers, robust 

redhorse have also been reintroduced into the Broad River (crossed at MP 161.0) and Ogeechee 
 4-99 4.0 –Environmental Impact Analysis 

Rivers (the Ogeechee River is about 3.5 miles northeast of at MP 33.9) to restore the species 

within its historic range. The FWS typically recommends ceasing construction activities from 

April 1 to July 1 to protect the robust redhorse during its spawning, egg, and larval development 

period. 

Robust redhorse spawn on gravel beds during April, May, and June. Clean gravel beds are 

necessary for recruitment because they provide the correct substrate, dissolved oxygen, flow, and 

protective requirements for the spawning and development of eggs and larvae. Great amounts of 

fine sediment are related to reduced survival, caused by increased egg or fry mortality within the 

substrate. Crossing the Broad River by the HDD method would reduce impacts to this species. 

Sandbar shiner 

Sandbar shiner is listed as rare in the state of Georgia. Sandbar shiners range from the Blue 

Ridge foothill and Piedmont streams in the Cape Fear River drainage of eastern North Carolina 

to the Savannah River drainage in eastern Georgia. Along the Elba Express Pipeline Project, the 

sandbar shiner may potentially occur in McDuffie, Wilkes, Elbert, and Hart (MP 116.2 to 187.7) 

counties of Georgia. The sandbar shiner is less common in mountain streams and uncommon 

within the Coastal Plain. Sandbar shiners occur in flowing, sand-bottomed pools, often near 

riffles, in creeks and small to medium sized rivers. Sandbar shiners spawn in late May to early 

July at water temperatures of 64-75oF and peak in June at about 71oF. Most are sexually mature 

in 2 years with some females mature in 1 year. 

The FWS typically recommends ceasing construction activities from April 1 to July 31 to protect 

the sandbar shiner during its spawning, egg, and larval development period in the Broad River 

watershed. However, in its comments on the draft EIS, EEC indicated that impacts to sandbar 

shiner would be avoided at the Savannah River and Broad River crossing locations because it 

would cross these waterbodies using the HDD method. Therefore, no additional surveys for 

sandbar shiner would be necessary. 

As currently proposed, EEC’s hydrostatic test water withdrawals could take place in the Broad 

River during sensitive periods for both the sandbar shiner and robust redhorse. In order to 

minimize impacts on these species, we recommend that EEC not withdraw water for 

hydrostatic testing from the Broad River or its tributaries during the period April 1 to July 

31. However, if EEC believes water withdrawal must occur during this period, EEC 

should develop a hydrostatic test water withdrawal plan (containing measures to minimize 

impacts on the sandbar shiner and robust redhorse) for the Broad River in consultation 

with the GDNR. Either a statement indicating EEC’s commitment to abide by the FWS 

time-of-year restrictions or copies of correspondence with the FWS and GDNR approving 

the hydrostatic test water withdrawal plan should be filed with the Secretary prior to 

construction.

Birds

Peregrine Falcon 
 4-100 4.0 –Environmental Impact Analysis 

Peregrine falcon is listed as endangered in the states of Georgia and South Carolina. This species 

breeds from non-arctic portions of Alaska and Canada south to Baja California, central Arizona 

and Mexico; western limits follow the eastern front of the Rocky Mountains in the U.S. The 

original population in the eastern United States had been decimated; however, a captive breeding 

program has successfully reestablished the population. The ideal nesting habitat for the falcon is 

on cliffs or a series of cliffs, but they may also nest in river cutbacks, trees, and manmade 

structures. Threats to the species include loss of wetland habitat, loss of primary prey, poachers 

robbing nests, hunting, and food chain contamination. Depending on its nesting location, the 

falcon arrives in its breeding area late April to early May and begins departure in late August 

through early September. Breeding begins when pairs establish nesting territories; eggs are laid 

during late March and April. 

No known occurrences of the peregrine falcon have been identified in any of the counties 

crossed by the proposed Elba Express Pipeline Project. If any transients are within the project 

area, they would likely avoid the construction ROW due to construction activities and use the 

abundant surrounding, undisturbed habitats to forage. Thus, construction of the Elba Express 

Pipeline project is unlikely to have any adverse impacts on this species. 

Swallow-tailed Kite 

Swallow-tailed kite is listed as a rare species in Georgia and an endangered species in South 

Carolina. This species potentially may occur in all Georgia counties along the proposed pipeline 

corridor. The swallow-tailed kite resides in river swamps and marshes. Breeding occurs in 

March with nesting in March through May. Swallow-tailed kites eat insects, snakes, frogs, 

lizards, birds, and small mammals. 

Although potential roost locations could be lost during tree clearing and other project activities, 

the amount of habitat actually removed would be minimal relative to available habitat in the area. 

Thus, adverse impacts on the swallow-tailed kite are not expected. 

Gull-billed Tern 

Gull-billed tern is listed as a threatened species in Georgia. This species potentially may occur 

along the LNG vessel tranist route. The gull-billed tern inhabits beaches, bays, and large rivers 

and breeds on sand, gravel, shell beaches, or grassy areas of coastal inlands. They are colonial 

nesters and breeding occurs in May and extends into August. Gull-billed terns eat insects, 

aquatic invertebrates, and fish. 

No known occurrences of the gull-billed tern have been identified along the LNG vessel tranist 

route, or near the terminal site. However, transients may occur within the project area or along 

the LNG vessel transit route but would not be expected to be impacted by the incremental 

increase in vessel traffic. 

Wilson’s Plover 

Wilson’s plover is listed as a threatened species in South Carolina. This species potentially may 

occur along the LNG vessel tranist route. The Wilson’s plover inhabits sandy or shell beaches or 
 4-101 4.0 –Environmental Impact Analysis 

tidal mudflats. They are colonial nesters and breeding occurs in early April and extends into 

August. Wilson’s plover eat mostly crustaceans and insects and feed both at night and during the 

day by moving on the ground in search of food at the water's edge. 

Wilson’s plover is known to occur along the LNG vessel tranist route in Jasper County, South 

Carolina. Transient or foraging plovers would not be expected to be impacted by the incremental 

increase in vessel traffic. 

Invertebrate

Atlantic Pigtoe Mussel 

Atlantic pigtoe mussel is listed as endangered in Georgia and is only found in Jenkins and 

Jefferson Counties (Georgia Museum of Natural History, 2006). This freshwater mussel has a 

medium, semi-triangular (rhomboidal) shaped shell (except in headwater areas where individuals 

are more elongate) that usually measures less than 2.4 inches. Fish hosts include the bluegill 

sunfish and shield darter. It is found in unpolluted, fast-flowing water in coarse sand/gravel 

substrate. Most Georgia populations have been coastal plain inhabitants in water underlain by 

limestone and dolomite. Primary threats are pollution, habitat degradation, impoundments, and 

sedimentation (see section 4.6.2.2). Like many of the endangered and threatened freshwater 

mussels, this species does not seem to be able to tolerate changes in its aquatic habitat. 

The Atlantic pigtoe mussel is found within the Ogeechee Creek watershed within the 

construction area. The reproductive period for this species is generally considered to be from 

late June through July with pigtoe mussels being sensitive to sedimentation through August. The 

FWS recommends not constructing from June 1 to August 30 to minimize impacts during its 

sensitive period. 

As currently proposed EEC’s, construction is scheduled to cross the Ogeechee Creek watershed 

during Atlantic pigtoe sensitive period. While GDNR did not comment specifically on this 

species, we believe the FWS time of year restrictions to be reasonable to reduce impacts to the 

Atlantic pigtoe mussel. Therfore, we recommend that EEC not construct its crossing of the 

Ogeechee Creek or its tributaries during the period June 1 to August 30 unless EEC 

receives written approval from the Director of OEP. Prior to construction, EEC should file 

with the Secretary either a statement indicating EEC’s commitment to abide by the FWS 

time-of-year restriction or copies of correspondence with the GDNR approving a summer 

crossing plan that contains measures to minimize impacts on the Atlantic pigtoe mussel. 

Alternatively, EEC shall file documentation that the GDNR has determined that the 

proposed project would not likely affect the Atlantic pigtoe mussels. 

EEC has agreed to submit a hydrostatic test water withdrawal plan to the GDNR prior to 

construction. 

These measures would reduce the likelihood of construction related sedimentation impacting the 

sandbar shiner, the robust redhorse, and the Atlantic pigtoe mussel, and therefore minimize the 

level of impacts to these species. 
 4-102 4.0 –Environmental Impact Analysis 

Crustacean

Broad River Burrowing Crayfish and Lean Crayfish 

In Georgia, both the Broad River burrowing crayfish and the lean crayfish are listed as 

threatened. Both are found within Broad River watershed in Wilkes and Elbert Counties. Adult 

crayfish are found in complex burrows in sandy-clay soils in floodplain areas with a high water 

table and are susceptible to the degradation of wetland and floodplain habitats fringing streams. 

The GDNR stated in a letter dated December 12, 2006, that stream crossings south of the Broad 

River (MP 161.0) should be surveyed by a qualified biologist for the presence of these species. 

In EEC’s comments on the draft EIS, it has agreed to this recommendation. If these species, or 

suitable habitat, are found within a waterbody crossing, then the GDNR suggested that the HDD 

method be used at that crossing. However, if EEC decides to use the HDD method for all 

waterbody crossings in this area, then the GDNR indicated that surveys would not be required. 

In order to protect the lean crayfish and the Broad River burrowing crayfish, or suitable habitat, 

we recommend that prior to construction, EEC file survey reports for Broad River 

burrowing crayfish and lean crayfish with the Secretary. If Broad River burrowing 

crayfish or lean crayfish are found during surveys, then EEC should not begin construction 

in the Broad River watershed until it files the results of GDNR consultation regarding 

avoidance or minimization of impacts on these species for review and written approval by 

the Director of OEP.

This recommendation would reduce the likelihood of construction related sedimentation 

impacting the Broad River burrowing crayfish and lean crayfish, and therefore minimize the 

level of impacts to these species. 

Plants

Granite Stonecrop 

Granite stonecrop is listed as threatened in Georgia. Along the Elba Express Pipeline Project it 

may potentially occur in Elbert (MP 161.0 to 182.4) and Wilkes (MP 135.0 to 161.0) Counties, 

Georgia. It is usually found growing among lichens in partial shade under large, open-grown 

eastern red cedar trees on granite outcrops. Normally it grows to 0.75 inch tall. The succulent 

leaves are up to 0.5 inches and are cylindrical and overlapping. This plant is often confused with 

“red moss” or Elf Orpine (Sedum smallii) which is abundant on most granite outcrops and has 

uniformly red leaves. The differences are only slight. Granite stonecrop is the larger of the two 

species and has bluish-green leaves, sometimes with tinges of red. It has small white flowers, 

consisting of four petals that are 0.1 inch long. The fruit is the most distinguishing feature. 

Granite Whitlow-grass 

Granite whitlow-grass is listed as endangered in Georgia and rare in South Carolina. It occurs in 

the Piedmont of Georgia and South Carolina. It may potentially occur in Wilkes (MP 135.0 to 

161.0), Warren (MP 112.6 to 121.3), and McDuffie (MP 116.2 to 135.0) Counties, Georgia. 
 4-103 4.0 –Environmental Impact Analysis 

This small plant occurs in the shallow soils in and around granite outcrops especially beneath 

eastern red cedar (Juniperus virginiana). Granite whitlow grass flowers in March and April but 

the best search time is during fruiting (May) when the branched hairs on the fruits are diagnostic. 

Exotic weeds such as honeysuckle are threats to this species. 

Indian Olive 

Indian olive is listed as threatened in Georgia and occurs on the Piedmont and Inner Coastal 

Plain from Alabama to Southern Virginia. Along the Elba Express Pipeline Project it may 

potentially occur in Jenkins, Burke, Glascock, Warren, McDuffie, Wilkes, Elbert, and Hart (MP 

57.5 to 187.7 excluding Jefferson County [MP 93.8 to 107.7]) Counties, Georgia, and in 

Anderson (MP187.7 to 187.9) County South Carolina. This species is found in dry, open, upland 

forest of mixed hardwood and pine. Indian Olive flowers from April to May and bears greenishyellow, olive shaped fruits in July. 

Ocmulgee Skullcap 

Ocmulgee skullcap is listed as threatened in Georgia. Along the Elba Express Pipeline Project it 

may potentially occur in Burke (MP 70.8 to 93.8) and McDuffie (MP 116.2 to 135.0) counties, 

Georgia. Ocmulgee skullcap is found on forested terraces, riverbanks, and nearby hardwood 

ravine slopes. Its flowers are dull-to violet-blue with white splotches, and it blooms late June 

through early October. The main threat to this species is development and exotic plants, 

especially Japanese honeysuckle. 

Oglethorpe Oak 

Oglethorpe oak is listed as threatened in Georgia. It occurs in the coastal plain of Georgia, South 

Carolina, Louisiana, and Mississippi. Along the Elba Express Pipeline Project it may potentially 

occur in Hart (MP 182.4 to 187.7), Elbert (MP 161.0 to 182.4), and Wilkes (MP 135.0 to 161.0) 

Counties, Georgia. Oglethorpe oaks are found in poorly drained soils of Piedmont seepage 

swamps and stream terraces. This deciduous tree is best found during the growing season when 

the characteristic leaves can be used for identification. Drainage and logging are major threats to 

this species. 

Parrot Pitcher Plant 

Parrot pitcher plant is state-listed as threatened in Georgia. It occurs from the Coastal Plain of 

northeastern Florida and southern Georgia, west to southeastern Louisiana. In Georgia, it has 

been recorded in 27 counties. Habitat for parrot pitcher plant includes acidic soils of open bogs, 

wet savannas, and low areas in pine flatwoods. It requires frequent, low-intensity fires to 

maintain open habitat and reduce competition. Draining, logging, and woody encroachment due 

to fire suppression are major threats to this species. 

Pondspice 

Pondspice is listed as threatened in Georgia and may potentially occur in Effingham (MP 4.7 to 

31.8) and Chatham (MP 0.0 to 4.7) counties, Georgia. This species is mostly an outer coastal 
 4-104 4.0 –Environmental Impact Analysis 

plain species ranging from the coastal plain of Maryland to Florida, but appears in low numbers 

when found elsewhere. Suitable habitat includes pond and swamp margins and low wet 

woodlands. It also can be found within basins of limesinks or other depressional ponds (10 to 

200m). Flowers appear in late winter through spring. Pondspice is threatened due to alterations 

in hydrology and by suppression of natural fire regimes. 

Sweet Pitcher Plant 

Sweet pitcher plant is state-listed as endangered in Georgia and South Carolina. Along the Elba 

Express Pipeline route it may occur in Effingham (MP 4.7 to 31.8), Screven (MP 31.8 to 57.5), 

Burke (MP 70.8 to 93.8) and Jefferson (MP 93.8 to 107.7) Counties, Georgia. Habitat for sweet 

pitcherplant includes open and sunny ecotones, bogs, and wet prairies and savannas, and gaps 

along streams and swamps with moist, acidic soil that is low in nutrients. It requires frequent, 

low-intensity fires to maintain open habitat and reduce competition. Draining, logging, and 

woody encroachment due to fire suppression are major threats to this species. 

Granite stonecrop, granite whitlow-grass, Indian olive, Ocmulgee skullcap, Oglethorpe oak, 

parrot pitcher plant, pondspice, and sweet pitcher plant potentially occur along the proposed 

pipeline route. EEC has not yet determined if impacts on these species could occur as a result of 

the Elba Express Pipeline Project; however, in its comments on the draft EIS, EEC indicated that 

it would resurvey potential habitat for these state listed plant species during the spring/summer of 

2008. EEC updated its SSMP to address measures that would be implemented to minimize 

impacts to granite stonecrop, granite whitlow-grass, Indian olive, Ocmulgee skullcap, Oglethorpe 

oak, parrot pitcher plant, pondspice, and sweet pitcher plant if they are found along the proposed 

pipeline route during the surveys. These measures include specialized construction techniques 

such as minimizing workspace requirements, preserving the seed bank through topsoil 

segregation, and ensuring germination by proper restoration of grade and avoidance of soil 

compaction. In addition, hydrologic conditions and soil profiles would be restored. EEC has 

submitted its revised SSMP to the GDNR and included revisions to further minimize impacts on 

these plant species. 

Effects of a Spill on State Listed or Special Status Species 

Impacts on state listed species resulting from the proposed increase of LNG vessel traffic in the 

Savannah River Channel are discussed above; the following discussion addresses potential 

impact on state listed species resulting from an LNG hazardous incident. State listed species that 

could occur within Zone 3 include the bald eagle, gull-billed tern, Wilson’s plover, dwarf siren, 

spotted turtle, and Atlantic sturgeon. If an unignited LNG spill were to occur along the transit 

corridor within the Zones of Concern, any state listed species within Zone 1 (as defined in 

section 4.12.4.3 of this EIS) could be impacted. Figures 4.7-1 to 4.7-3 show the locations of 

threatened and endangered species along the LNG transit route. Because LNG is lighter than 

water, the LNG would float on the water until it had vaporized. 

If any listed species were to come into contact with the LNG, it would experience an extreme 

temperature change, and could be injured or expired. The LNG from any release along the 

transit route would rapidly cool water within the LNG pool. Because the more dense cold water 
 4-105 4.0 –Environmental Impact Analysis 

would settle to the bottom of the channel, it could temporarily impact the benthos and species 

beneath the pool of LNG. However, the temperature change would be greatest at the surface, 

with decreasing affects as depth is increased within the water column. Transient bald eagles, 

gull-billed terns or Wilson’s plovers flying over the spill could experience inhalation problems, 

and possibly asphyxiate. No dwarf sirens, spotted turtles, or Atlantic sturgeon would be 

expected to be affected by an LNG release unless they came in direct contact with the LNG. The 

marine transit safety and security measures (as described in sections 4.12.4 and 4.12.6 of this 

EIS) make the likelihood of an LNG vessel spill from collisions, allisions, and terrorist attacks 

extremely remote. As a result, no significant impact on bald eagles, gull-billed terns or Wilson’s 

plovers would be anticipated from an unignited marine LNG spill within Zone 1. No impacts 

would be expected outside of Zone 1 from a release of LNG. 

If a pool fire were to occur in association with a release of LNG, species on or near the surface of 

the water within Zone 1 could experience injury or mortality either by the fire or radiant heat. 

Species within Zone 2 may be impacted by radiant heat, while others may be impacted by 

displacement from its native habitat. Dwarf sirens, spotted turtles, bald eagles, gull-billed turns, 

Wilson’s plover, and Atlantic sturgeon could be impacted by the radiant heat and possibly 

expire. No impacts would be expected to species within Zone 3 from a pool fire. The maximum 

flammable range for a vapor cloud could extend to the outer limits of Zone 3. If the vapor cloud 

were to come in contact with an ignition source, the resulting fire could burn back to the spill and 

impact any listed species within its path. 

The marine transit safety and security measures make the likelihood of an LNG vessel spill from 

collisions, allisions and terrorist attacks extremely remote and reduce the impacts to a less than 

significant level. If a release of LNG were to occur, and listed species were impacted, we would 

consult with the SCDNR and/or GDNR regarding impacts on those species. 

4.8 LAND USE, RECREATION, AND VISUAL RESOURCES 

The existing Terminal is located in Chatham County, Georgia, approximately 8.5 miles upstream 

from the mouth of the Savannah River. The 224.47 acre terminal is completely contained on the 

840 acre Elba Island and is the only facility located on the island, which is owned in its entirety 

by Southern LNG. Because Elba Island is zoned for industrial use and the terminal is the only 

facility on the island, the Terminal Expansion would not affect land use or recreation. There 

would be a minor impact on visual resources with the additional facilities. 

EEC proposes to construct two pipeline segments and associated support facilities through 

Georgia to South Carolina for a total of 187.9 miles. Construction and operation of the proposed 

pipeline would include temporary and permanent impacts to upland forest, planted pine, open 

space, open water, ROW, residential, commercial/industrial, agriculture and scrub-shrub, and 

emergent and forested wetlands. In addition, the Project would affect planned developments and 

special land use areas including: wildlife management areas, a state park, COE Project and 

Mitigation Lands, a protected river, and the Georgia Coastal Management area. Mitigation 

measures would minimize effects to the affected land use types as described below. 
 4-106 4.0 –Environmental Impact Analysis 

4.8.1 Land Use 

4.8.1.1 Land Use Requirements 

The total land area disturbed by construction of all proposed facilities (Terminal Expansion and 

Elba Express Pipeline) would be 3,296.51 acres. Operation of all proposed facilities would 

affect 1,028.43 acres. Table 4.8-1 summarizes the acreage of each land use type that would be 

affected by the construction and operation of the Project while table 4.8-2 details the acreages of 

each land use type that would be affected by EEC’s ancillary facilities. 

Terminal Expansion

The area to be affected by the Terminal Expansion is commercial/industrial land and open water. 

Southern LNG proposes to use approximately 213.08 acres of the existing terminal property. All 

parts of the existing terminal not currently utilized would be covered by the proposed structures, 

parking, storage of materials, laydown areas, or other temporary activities during construction. 

Permanent terminal facilities would include the proposed LNG tanks, vaporizers, pumps, 

buildings and other ancillary facilities. The 34.26 acres of permanent impacts from construction 

would be covered by structures, earthworks, road/pads and gravel. 

Elba Express Pipeline

Existing land uses along the pipeline route consist primarily of agricultural, forested, planted 

pine trees, and open space. The pipeline would consist of two segments as follows: 

• Southern Segment – (MP 0.0 to MP 104.8) would consist of a 42-inch-diameter pipeline 

• Northern Segment – (MP 104.8 to MP 187.9) would consist of 83.1 miles of mixeddiameter pipeline: 

o 10.0 miles of 42-inch-diameter pipeline (MP 104.8 to MP 114.8); and 

o 73.1 miles of 36-inch-diameter pipeline (MP 114.8 to MP 187.9).

Southern Segment – 42 inch 

EEC proposes to use a 125-foot-wide construction ROW for the 42-inch-diameter Southern 

Segment. This construction ROW would include an overlap of Southern’s existing ROW, which 

would vary based upon the existing ROW configuration (see table 4.8-3 and figure 2.2-1). 

Temporary construction and additional permanent ROW would be located on the 

western/southern side of the existing ROW. Additional site-specific areas would be required for 

extra workspace at various road, waterbody, wetland and waterbody crossings to provide extra 

space for spoil storage and associated construction activities. EEC would retain up to 20 feet of 

new permanent easement (in addition to the existing 90 feet of permanent easement currently 

held by Southern) along portions of this segment. The resulting permanent easement of up to 

110 feet would be sufficient to maintain all of the existing pipelines and the new Elba Express 

Pipeline.
TABLE 4.8-1

Acres of Land Affected by Construction and Operation of the Proposed Project 

Residential Industrial/ Commercial Agriculture Scrub-Shrub Wetland c/ Emergent Wetland c/ 

Cons 

a/

Oper 

b/

Cons 

a/

Oper

b/

Cons 

a/

Oper 

b/

Cons 

a/

Oper 

b/

Cons 

a/

Oper 

b/

Terminal ExpansionTerminal Facilities 0.00 0.00 179.77 34.26 0.00 0.00 0.00 0.00 0.00 0.00 PipelineMainline- Georgia 22.03 7.92 7.43 2.52 366.99 103.51 10.91 4.94 119.18 66.76 Mainline-South Carolina 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Aboveground FacilitiesGeorgia 0.01 0.00 0.55 0.28 0.05 0.00 0.00 0.00 0.09 0.07 South Carolina 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Warehouse/Storage YardsGeorgia 11.67 0.00 51.06 0.00 109.36 0.00 0.46 0.00 0.18 0.00 South Carolina 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Pig Launcher/Receiver d/ Georgia 0.00 0.00 1.61 1.61 N/A N/A N/A N/A N/A N/A South Carolina N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A TOTAL PROJECT 33.71 7.92 240.42 38.67 476.40 103.51 11.37 4.94 119.45 66.83 

4-107 4.0 – Environmental Impact Analysis
TABLE 4.8-1 (continued)

Acres of Land Affected by Construction and Operation of the Proposed Project 

Upland Forest Planted Pine Open Space Open Water ROW 

Cons 

a/

Oper 

b/

Cons 

a/

Oper 

b/

Cons 

a/

Oper 

b/

Cons

a/

Oper 

b/

Cons 

a/

Op

b

Terminal ExpansionTerminal Facilities 0.00 0.00 0.00 0.00 0.00 0.00 33.31 0.00 0.00 0.PipelineMainline- Georgia 917.35 335.43 534.78 161.26 625.45 215.78 5.21 2.35 28.08 9.Mainline-South Carolina 

3.95 1.85 0.00 0.00 0.00 0.00 0.54 0.54 0.00 0.

Aboveground FacilitiesGeorgia 1.34 0.59 26.97 24.58 1.05 1.05 0.00 0.00 1.15 1.South Carolina 6.51 4.05 0.00 0.00 0.00 0.00 0.00 0.00 0.01 0.Warehouse/Storage YardsGeorgia 11.89 0.00 0.03 0.00 109.03 0.00 1.07 0.00 1.17 0.South Carolina 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.Pig Launcher/Receiver d/ Georgia N/A N/A N/A N/A N/A N/A N/A N/A N/A NSouth Carolina N/A N/A N/A N/A N/A N/A N/A N/A N/A NTOTAL PROJECT 941.04 341.92 561.78 185.84 735.53 216.83 40.13 2.89 30.41 10_______________________________________________________________________ a/ Construction impacts include permanent ROW, temporary ROW and additional temporary work spaces associated with the construction corridor. 

b/ Operation impacts are permanent. 

c/ Numbers in the “Cons” column depict a 30-foot-wide permanent ROW in wetlands. 

d/ “N/A” indicates the pig launcher/receiver occurs within aboveground facility limits. 

4-108 4.0 – Environmental Impact Analysis 
 4-109 4.0 – Environmental Impact Analysis 

TABLE 4.8-2 

Land Requirements for the Ancillary Facilities associated with the 

Elba Express Pipeline 

Facility County/State Milepost 

Land Affected 

During 

Construction 

(acres) a/

Land Use 

Land Affected During 

Operation 

(acres) 

Warehouse/ Storage Yards 

8.75 AG 

CSC-001 (F1ACSC001) Screven/GA N/A 0.09 ROW 

0.08 UF 

0.00 N/A 

22.57 AG CSC-002 (F1ACSC002) Screven/GA N/A 0.25 UF 0.00 N/A 

15.19 OS 

PSC-001 (F1APSC001) Screven/GA N/A 0.05 ROW 

0.15 UF 

0.00 N/A 

PSC-002 (F1APCS002) Screven/GA N/A 15.15 AG 0.00 N/A 

RSC-001 (F1ARSC001) Screven/GA N/A 0.90 RE 0.00 N/A 

35.39 CI 

3.97 OS 

0.98 ROW 

0.46 PSS 

1.47 RE 

CBU-001 (F1ACBU001) Burke/GA N/A 

0.73 ROW 

0.00 N/A 

18.80 AG PBU-001 (F1APBU001) Burke/GA N/A 0.13 UF 0.00 N/A 

55.84 OS 

PFJ-001 (F1ACJF001) Jefferson/GA N/A 1.26 AG 

0.03 PP 

0.00 N/A 

10.37 OS RGL-001 (F1ARGL001) Glascock/GA N/A 0.94 RE 0.00 N/A 

2.53 OS CMC-001 (F1ACMC001) McDuffie/GA N/A 0.18 PEM 0.00 N/A 

CMC-002 (F1ACMC002) McDuffie/GA N/A 6.74 RE 0.00 N/A 

CEL-001 (F1ACEL001) Elbert/GA N/A 15.67 CI 0.00 N/A 

CEL-002 (F1CREL002) Elbert/GA N/A 3.40 UF 0.00 N/A 

17.97 OS PEL-001 (F2CPEL001) Elbert/GA N/A 0.02 ROW 0.00 N/A 

42.83 AG 

1.62 RE 

0.37 ROW REL-001 (F1APHA001) Elbert/GA N/A 

7.78 UF 

0.00 N/A 

3.16 OS REM-001 (F1AREM001) Emanuel/GA N/A 0.10 UF 0.00 N/A 

Total Warehouse/Storage Yard 295.92 0.00 

Aboveground Facilities 

23.21 PP 23.21 PP 

1.15 ROW 1.15 ROW Elba Express Compressor 

Station Jenkins/GA 58.3 

0.68 OS 0.68 OS 

0.23 PFO 0.23 PFO Port Wentworth Meter Station Chatham/GA 0.0 0.15 CI 0.07 CI 

0.88 PP 0.88 PP 

McIntosh Meter Station Effingham/GA 9.7 0.33 OS 0.33 OS 

0.07 PEM 0.07 PEM 

EEC/Cypress Meter Station Effingham, GA 9.7 

Included in 

McIntosh 

Station 

Included in 

McIntosh 

Station 

Included 

in 

McIntosh 

Station 

Included 

in 

McIntosh 

Station 
 4-110 4.0 – Environmental Impact Analysis 

TABLE 4.8-2 (continued) 

Land Requirements for the Ancillary Facilities associated with the 

Elba Express Pipeline

Facility County/State Milepost 

Land Affected 

During 

Construction 

(acres) a/

Land Use 

Land Affected During 

Operation 

(acres) 

2.88 PP 

0.09 CI 0.49 PP 

0.04 OS Effingham Meter Station Effingham/GA 10.3 

0.02 PEM 0.04 OS 

0.31 CI 

Wrens Meter Station Jefferson/GA 104.8 0.05 AG 

0.01 RE 

0.21 CI 

Transco Zone 4 Meter Station Hart/GA 187.1 1.34 UF 0.59 UF 

Transco Mixing Station Anderson/SC 187.9 2.75 UF 2.75 UF 

2.64 UF 

Plant Rainey Meter Station Anderson/SC 187.9 0.32 UF 

0.01 UF 

0.50 UF 

Transco Zone 5 Meter Station Anderson/SC 187.9 0.80 UF 0.80 UF 

Aboveground Facility Total 37.96 32.00

Main Line Valves b/ 

MLV-001 Effingham/GA 9.70 N/A N/A N/A N/A 

MLV-002 Effingham/GA 18.25 N/A N/A N/A N/A 

MLV-003 Screven/GA 36.46 N/A N/A N/A N/A 

MLV-004 Screven/GA 53.28 N/A N/A N/A N/A 

MLV-005 Burke/GA 71.95 N/A N/A N/A N/A 

MLV-006 Burke/GA 89.44 N/A N/A N/A N/A 

MLV-007 McDuffie/GA 124.55 N/A N/A N/A N/A 

MLV-008 Wilkes/GA 143.89 N/A N/A N/A N/A 

MLV-009 Elbert/GA 163.86 N/A N/A N/A N/A 

MLV-010 Hart/GA 183.42 N/A N/A N/A N/A 

Main Line Valves Total N/A N/A N/A N/A

Pig Launcher/Receiver 

Port Wentworth 42-inch Pig 

Launcher c/ Chatham/GA N/A N/A N/A N/A N/A 

Wrens 42-inch Pig Receiver Warren/GA N/A 

Wrens 36-inch Pig Launcher Warren/GA N/A 1.61 CI 1.61 CI 

Transco Zone 5 Pig Receiver c/ Anderson/SC N/A N/A N/A N/A N/A 

Pig Launcher/Receiver Total 1.61 1.61

Ancillary Facility Total 336.73 33.61 

____________________________________________________________ 

a/ Extra Workspace within the construction ROW is included in pipeline land requirements. 

b/ Occurs within ROW or existing/proposed aboveground facility limits. 

c/ Occurs within meter station limits. 

Land Use Classifications: 

AG: Agriculture; CI: Commercial/Industrial; OS: Open Space; OW: Open Water; PEM: Palustrine Emergent Wetland; PFO: 

Palustrine Forested Wetland; PSS: Palustrine Scrub-Shrub Wetland; RE: Residential; ROW: Right-of Way; UF: Upland Forest; 

PP: Planted Pines 

N/A: Not Applicable 
 4-111 4.0 – Environmental Impact Analysis 

TABLE 4.8-3

ROW Configurations for the Elba Express Pipeline 

County/State MP 

Total 

Miles 

Collated 

Type of ROW 

Width of 

Existing 

ROW 

(ft) 

Overlap of 

Temporary 

Construction 

ROW a/

Additional 

Permanent 

ROW 

(ft) 

Additional 

Temporary 

ROW 

(ft) b/

Chatham/GA 0.0 – 4.7 4.7 Southern 

Pipeline 90 35 20 70 

4.7 – 9.7 4.8 Southern 

Pipeline 90 35 20 70 

9.7 – 27.3 17.8 Southern 

Pipeline Effingham/GA 90 35 20 70 

27.3 – 31.8 4.5 Southern 

Pipeline 90 55 0 70 

Screven/GA 31.8 – 57.5 25.7 Southern 

Pipeline 90 55 0 70 

Jenkins/GA 57.5 – 70.8 13.3 Southern 

Pipeline 90 55 0 70 

70.8 – 89.4 18.6 Southern 

Pipeline 90 55 0 70 

Burke/GA 

89.4 – 93.8 4.4 Southern 

Pipeline 90 35 20 70 

93.8 – 104.8 11.0 Southern 

Pipeline 90 35 20 70 

104.8 – 106.1 1.3 Southern 

Pipeline 90 35 20 70 Jefferson/GA 

106.1 – 107.8 0.0 Greenfield 0 0 50 75 

Glascock/GA 107.8 – 112.6 0.0 Greenfield 0 0 50 75 

112.6 – 114.8 0.0 Greenfield 0 0 50 75 

Warren/GA 

114.8 – 116.2 0.0 Greenfield 0 0 50 60 

McDuffie/GA 116.2 – 117.5 0.0 Greenfield 0 0 50 60 

Warren/GA 117.5 – 121.3 0.0 Greenfield 0 0 50 60 

McDuffie/GA 121.3 – 135.0 0.0 Greenfield 0 0 50 60 

Wilkes/GA 135.1 – 161.1 0.0 Greenfield 0 0 50 60 

Elbert/GA 161.1 – 182.5 0.0 Greenfield 0 0 50 60 

Hart/GA 182.5 – 187.7 0.0 Greenfield 0 0 50 60 

Anderson/SC 187.7 – 187.9 0.0 Greenfield 0 0 50 60 

Total South 

Segment 104.8 104.8 

Total North 

Segment 83.1 1.3 

Total 

Georgia 187.5 106.1 

Total South 

Carolina 0.4 0.0 

Total 

Pipeline 187.9 106.1 

_______________________________________________________________________ 

a/ Upland configuration. 

b/ Additional temporary ROW would occur primarily in uplands and in limited wetlands only where required due to site-specific 

conditions. 
 4-112 4.0 – Environmental Impact Analysis 

Northern Segment – 42 inch 

EEC proposes to use a 125-foot-wide construction ROW for the 42-inch-diameter portion of the 

Northern Segment. The first 1.3 miles of the Northern Segment (MP 104.8 to MP 106.1) would 

be collocated with Southern’s existing pipeline ROW. Temporary construction and additional 

permanent ROW would be located on the southern side of the existing ROW. EEC would retain 

up to 20 feet of new permanent easement in addition to the existing 90 feet of permanent 

easement currently held by Southern along this segment. The resulting permanent easement of 

up to 110 feet would be sufficient to maintain both the existing pipelines and the new Elba 

Express Pipeline. The remaining 8.7 miles (MP 106.1 to MP 114.8) of 42-inch-diameter pipeline 

would be greenfield construction. EEC would retain 50 feet of the 125-foot-wide construction 

corridor to maintain the proposed pipeline. 

Northern Segment – 36 inch 

EEC proposes to use a 110-foot-wide construction ROW for the 36-inch-diameter portion of the 

Northern Segment (MP 114.8 to MP 187.9). This pipeline would be greenfield construction. 

EEC would retain 50 feet of the 110-foot construction corridor for new permanent easement to 

maintain the new Elba Express Pipeline. 

Aboveground Facilities

One compressor station, 8 meter stations, one mixing station, 10 MLVs, 2 pig launchers, and 2 

pig receivers would be constructed as part of the Project. Table 4.8-1 summarizes the land 

requirements for these facilities. 

The Elba Express Compressor Station would require approximately 25.04 acres for construction 

and operation, and to provide visual screening and noise buffers, near MP 58.30 in Jenkins 

County, Georgia. The compressor station site is surrounded by older growth pine plantation, 

which would visually screen the compressor station from nearby residences, and is bordered to 

the south by an existing Southern ROW. The majority of land that would be affected by 

construction and operation of the proposed compressor station would be early stage planted pine, 

which would be converted to a commercial/industrial cover type for the life of the Project. 

The eight new meter stations (see table 2.2-2 for name and MP location) would require 10.17 

acres for construction and 4.21 acres for operation. The majority of the land use for the meter 

stations would be upland forest and planted pine, which also would be converted to a 

commercial/industrial cover type for the life of the Project. One new mixing station would 

require about 2.7 acres for construction and operation. The majority of land use for this mixing 

station would be upland forest. 

MLVs would be installed at intervals required by the DOT regulations to facilitate operation, 

repair, and ESD of the pipeline system. MLVs would be located within the footprint of the 

permanent pipeline ROW and would not result in additional land requirements beyond those 

noted for the permanent ROW. 
 4-113 4.0 – Environmental Impact Analysis 

Two pig launcher/receiver facilities, the 42-inch-diameter Port Wentworth pig launcher and 36-

inch-diameter Transco Zone 5 pig receiver, would be located within their associated meter 

station sites, and would not result in additional land requirements beyond those noted for those 

facilities. The Wrens 42-inch-diameter pig receiver and Wrens 36-inch-diameter pig launcher 

would permanently occupy 1.61 acres of existing commercial/industrial land, and would not 

result in a change in current land use cover type. 

Warehouse/Storage Yards

Sixteen warehouse/storage yard sites are proposed to store pipe and equipment for the Project, as 

well as to provide areas for temporary contractor office space. The sites were selected for their 

convenient location in relation to each of the pipeline spreads and were surveyed for biological 

and cultural resource concerns. Approximately 295.92 acres would be required for construction 

of the warehouse/storage yards. Most of the land that would be affected would be 

industrial/commercial, agriculture and open space. Location maps for the warehouse/storage 

yard sites are included in appendix B. 

Extra Work/Staging Areas

EEC has identified 247.1 acres of ATW that would be required adjacent to the proposed 

permanent and temporary pipeline ROW. Land requirements for ATWs are included within the 

pipeline land requirements in table 4.8-1. The ATWs would be located primarily in upland 

forest, planted pine, open space, and agricultural land; however, EEC has identified 6 ATW areas 

that would be required in wetlands due to site-specific construction conditions to allow 

conventional bore of roadways and a railroad. Deviations from this 50-foot setback would 

require our approval prior to construction. We have reviewed the route and alternatives to 

minimize the level of impact to wetlands. Additionally, we have reviewed EEC’s Procedures for 

crossing wetlands and found them acceptable. 

Access Roads

EEC would use 96 public and private roads that intersect or parallel the proposed pipeline route 

to access the ROW during construction (see appendix C for a complete list of access roads). 

EEC anticipates that several of these access roads may require improvements. These roads and 

the anticipated improvements are discussed in section 2.3.2.2. 

4.8.1.2 Land Use Impacts and Mitigation 

Forested Wetlands

Forested wetlands cleared for construction of the Project would undergo both short and longterm impacts. Following pipeline installation, the temporary construction ROW would be 

allowed to revert to its pre-construction condition. Forested wetlands within this area would 

regenerate to pre-construction conditions within 20 to 40 years, depending on the woodland 

species and management practices. The regeneration of forested wetlands in the temporary 
 4-114 4.0 – Environmental Impact Analysis 

construction ROW would not be immediate, but construction in these areas would not result in 

permanent impacts. 

Permanent ROW generally would be maintained in an herbaceous state in accordance with DOT 

regulations for safe operation and maintenance of the pipeline. Therefore, forested wetlands 

located within the permanent pipeline ROW would endure long-term impacts, as they would be 

converted permanently to scrub-shrub or emergent wetlands. These modifications would result in 

a change in wetland habitat type, but would not result in a net loss of wetlands. In wetland areas, 

the maintained area of the permanent ROW would be 0 to 30 feet, depending on the amount of 

permanent ROW overlap with existing corridors. The remaining 20 feet of construction ROW, 

where needed, would be allowed to revegetate from existing rootstocks and seed banks to preconstruction conditions. EEC’s limitation of the maintained 30-foot-wide permanent ROW in 

wetlands would greatly reduce permanent impacts to forested wetlands. 

Scrub-Shrub and Emergent Wetlands

Scrub-shrub and emergent wetland areas would be disturbed temporarily during construction. 

No long-term impacts to these wetlands are anticipated because, following construction, the 

ROW would be restored to its pre-construction topographical and hydrological patterns, and 

would be allowed to revegetate from the existing seed bank and root stock material found within 

the topsoil. This process would result in no net loss of wetland acreage within the pipeline 

corridor. Wetlands within the ROW would be maintained in an emergent or scrub-shrub state 

after construction by periodic clearing for pipeline maintenance and safety reasons. 

Upland Forest and Planted Pine

Both short- and long-term impacts are expected to occur in upland forest and planted pine as the 

result of construction and operation of the Project. Trees would be cleared from the construction 

corridor as a necessary part of construction. Several landowners voiced concern regarding 

protecting and/or minimizing the impacts of construction to large, old growth hardwoods on the 

proposed construction ROW and/or near residences. In response, EEC has stated that it would 

consider making adjustments to the work plan, construction procedures, and workspace 

requirements to minimize impacts to trees where it is practicable and feasible. Possible methods 

to minimize impacts include moving or re-configuring workspaces and using special 

construction methods such as "stovepiping", relaying trench spoil, matting workspaces, and open 

cutting roads, all of which could serve to reduce overall workspace. EEC has also stated that it 

would work with landowners during the easement acquisition process to identify the appropriate 

alternate methods for their property. For additional discussion, see section 4.8.2, Landowner and 

Easement Requirements. 

Following construction, the temporary workspace outside of the permanent ROW used for 

construction would be allowed to revert to pre-construction conditions. Upland forest and 

planted pine areas would regenerate to pre-construction conditions within 20 to 40 years, 

depending on the woodland species and management practices. The disturbed areas would be recontoured and re-vegetated following pipeline construction to control soil erosion. The 

permanent ROW would be maintained in a herbaceous state by seeding with a grass mixture 
 4-115 4.0 – Environmental Impact Analysis 

recommended by the appropriate state and federal agencies, including the NRCS, and mowed 

periodically for safety and maintenance reasons. 

Open Space

Open space is considered to be non-agricultural fields and open land in the early stages of 

succession. Open space would be cleared of herbaceous growth during grading operations 

before construction. The construction ROW would remain unvegetated until pipeline 

construction is completed. After final construction clean-up, these areas would be re-seeded and 

mulched according to recommendations from state agencies and the NRCS. After the vegetation 

is established, these areas are expected to revert to pre-construction land uses. No long-term 

impacts are expected from construction of the pipeline on open land dominated by herbaceous 

vegetation. 

Existing ROWs

During construction, the pipeline would traverse public roads. In order to minimize public 

disturbance, the pipeline would be installed by boring underneath the roadway. In the event that 

a public road is open cut, at least one traffic lane would be maintained, except for brief periods 

essential to laying the new pipeline. If pipeline construction crosses roads that access private 

residences or businesses and no alternate entrance exists, measures would be taken to maintain 

passage for landowners during construction. Attempts would be made to avoid peak traffic time 

periods during construction that temporarily closes roads. 

To maintain safe conditions, EEC would keep roads free of mud that may be left by crossing 

construction equipment. Track-driven equipment would cross paved roads on tires or equipment 

pads to minimize damage to the road surface. EEC would make efforts to minimize road 

damage by enforcing local weight limitations and restrictions. Roadways damaged during 

construction would be repaired to pre-construction conditions. 

Open Water

Open water is considered to be perennial waterbodies greater than 100 feet wide. Construction 

of the Project would temporarily affect about 40.13 acres of open water. The pipeline would 

impact 6.82 acres of open water during construction. Any impacts on open water are expected to 

be short-term. Efforts would be made before, during, and after pipeline construction to minimize 

the extent and duration of project-related disturbances to water resources. EEC would follow 

procedures found in its Plan and Procedures to minimize short-term impacts on open water 

during construction. Recommended construction timing constraints requested by federal and 

state agencies would be incorporated into the construction schedule. No long-term impacts are 

anticipated to occur from the construction of the Project facilities across open water. 

Commercial/Residential Lands

The level of impact on adjacent commercial and residential lands would be moderate and shortterm and would stem primarily from construction activities such as increased levels of noise and 
 4-116 4.0 – Environmental Impact Analysis 

dust. After the pipeline has been installed and all construction-related activities have been 

completed, the landowners may use the ROW provided they do not interfere with the rights 

granted to EEC. Typically, no trees or bushes greater than five feet in height would be permitted 

on the permanent ROW because they impair access to the pipelines, and roots can damage the 

coating or positioning of the pipeline. No structures, including houses, tool sheds, garages, guy 

wires, catch basins, swimming pools, trailers, leach fields, septic tanks, and any other objects not 

easily removable would be permitted on the permanent ROW. 

The principal measures that would be used to mitigate impacts on existing commercial and 

residential areas are to ensure that construction proceeds quickly through such areas (thus 

minimizing exposure to nuisance effects such as noise and dust) and to limit the hours during 

which construction activities with high decibel noise levels (i.e., drilling and boring) would be 

conducted. 

Landowners and commercial property owners would be notified prior to construction; access and 

traffic flow would be maintained during construction activities, particularly for emergency 

vehicles; open ditches would be secured during non-construction activities; and dust from 

construction would be minimized by utilizing dust abatement techniques. In addition, mature 

trees and landscaping would be preserved to the extent possible while ensuring the safe operation 

of construction equipment. Immediately after backfilling the trench, all lawn areas and 

landscaping within the construction work area would be restored consistent with the 

requirements of EEC’s Plan. Accordingly, the edge of the construction work area adjacent to a 

residence would be fenced for a distance of 100 feet on either side of the residence to ensure that 

construction equipment and materials, including the spoil pile, would remain within the 

construction work area. Lighted barricades would be used for locations where the trench must be 

kept open after work hours. 

At a minimum, fencing would be maintained throughout the open trench phases of pipe 

installation. If the pipeline centerline is within 25 feet of a residence, EEC would ensure that the 

trench is not excavated until the pipe is ready for installation and that no ditch would be left open 

for more than 48 hours. EEC has developed site-specific drawings depicting how it would 

construct in the vicinity of each residence within 50 feet of the proposed construction workspace. 

Although the route would require clearing of wooded areas along the ROW, several methods for 

mitigating the long-term effects of a cleared ROW would be utilized. During construction, 

precautions would be taken to protect trees located outside the specified construction ROW. In 

addition, landowners would be compensated for the trees removed during construction. If the 

ROW is visible from an adjacent thoroughfare or residential area, mitigation measures such as 

screen plantings to reduce line-of-sight visibility may be utilized to the extent practicable. 

ROW Vegetation

The establishment of a 50-foot-wide permanent ROW maintained in a grassy condition located 

within an otherwise open field, scrub-shrub, or forested landscape would not necessarily increase 

the risk or spread of fire over current conditions. The permanent ROW could in fact act as an 

advantageous fire break for uncontrolled forest fires that may result from either lightening 
 4-117 4.0 – Environmental Impact Analysis 

strikes, accidental fires, or an uncontrolled prescribed burn associated with management of 

private or commercial forest lands. 

4.8.2 Landowner and Easement Requirements 

Terminal Expansion

The existing Terminal is completely contained on Elba Island which is owned by Southern LNG 

in its entirety; therefore, no landowner or easement requirements would be necessary. 

Elba Express Pipeline

Prior to initiating construction, EEC would secure an easement to convey both temporary (for 

construction) and permanent (for operation) ROWs. The easement acquisition process is 

designed to provide fair compensation to the landowners for the right to use the property for 

construction and operation. During the easement acquisition process, EEC would compensate 

landowners for loss of value to specific parcels. The easement agreement between the company 

and landowner typically specifies compensation for loss of use during construction, loss of 

nonrenewable or other resources, damage to property during construction, and allowable uses of 

the permanent ROW after construction. During negotiations, EEC and affected landowners may 

address the following: 

• allowable uses within the ROW; 

• minor route adjustments to accommodate landowner needs (provided the route 

adjustments do not affect environmentally sensitive areas or other non-consenting 

landowners); and 

• mechanisms required to allow the pipeline to be traversed by heavy equipment such as 

log skidders; and 

For instance, EEC has stated that during easement negotiations it would work to accommodate 

those landowners who have identified a need to frequently cross the pipeline ROW with heavy 

logging loads (such as tandem axle trucks with loads up to 30,000 pounds per axle) or have plans 

for a future permanent road crossing at a specific location along the ROW. EEC can 

accommodate a reasonable number of these crossings with additional depth of cover, heavier 

wall pipe, or other suitable methods of protection for the pipeline if needed. However, these 

needs must be identified as early as possible in the negotiations. 

If an easement cannot be negotiated with a landowner and the Project has been authorized by the 

FERC, EEC could use the right to eminent domain granted to it under Section 7(h) of the NGA 

and the procedure set forth under the Federal Rules of Civil Procedure (Rule 71A) to obtain the 

ROW and extra workspace areas. The company would still be required to compensate the 

landowner for the ROW and for any damages incurred during construction. However, a court 

would determine the level of compensation. In either case, the landowner would be compensated 

for the use of the land. Eminent domain would not apply to lands under federal ownership. 
 4-118 4.0 – Environmental Impact Analysis 

4.8.3 Proposed Alternative Measures to the FERC Plan 

EEC stated that in residential areas, landowners commonly request annual vegetation 

maintenance to address concerns regarding aesthetics and increased interaction with nuisance 

wildlife (e.g., rats, snakes, opossums, and mosquitoes). EEC would limit vegetative maintenance 

to a frequency of not greater than once every 3 years, except in DOT Class 3 Locations where 

annual maintenance may be preformed only if requested by the landowner. 

4.8.4 Residences and Planned Developments 

In residential areas, the two most significant impacts associated with construction and operation 

of natural gas facilities are disturbance during construction and encumbrance of property for 

future uses (e.g., the limitation on future permanent structures within the permanent ROW). 

Residences within 50 feet of construction work areas would be most likely to experience the 

effects of construction and operation of the Project. 

Temporary construction impacts on residential areas can include inconveniences caused by noise 

and dust generated by construction equipment, personnel, and trenching through roads or 

driveways; ground disturbance of lawns; removal of trees, landscaped shrubs, or other vegetative 

screening between residences and/or adjacent ROW; potential damage to existing septic systems 

or wells; and removal of aboveground structures, such as shed or trailers, from within the ROW. 

Impacts on residential areas are discussed by facility below. 

Terminal Expansion

There are no residences within one mile of the proposed Terminal Expansion facilities. The 

nearest residence is approximately two miles southeast of the existing Terminal. 

There is one development that has been proposed within one mile of the proposed Terminal 

Expansion facilities, the Jasper County Port. Pursued by Jasper County, South Carolina officials 

since the early 1990s, the port is proposed to be constructed along the northern banks of the 

Savannah River Channel directly across from the Terminal. The South Carolina State Ports 

Authority, however, has long opposed the development, and most recently won a court case to 

condemn the land on which the port is proposed to be developed. Despite the condemnation, 

both state governors have vowed to build the port and hope to come to an agreement with all 

state agencies in order to do so. 

Elba Express Pipeline

EEC identified five houses, seven mobile home structures, three sheds, two carports and one 

non-specified structure that would be within 50 feet of the proposed construction work area 

(table 4.8-4). At these locations, EEC would line the construction boundary with hay bales and 

silt fence and reduce construction work areas in order to minimize impacts on residences. EEC 

developed site-specific drawings depicting how construction in the vicinity of these residences 

would be conducted. We have reviewed these drawings and believe EEC’s implementation of 

the measures depicted on the drawings would lessen impacts on most of the affected residences. 
 4-119 4.0 – Environmental Impact Analysis 

However, the proximity of five residences to construction work areas merits further 

consideration. Therefore, we recommend that for each residence closer than 25 feet to the 

construction work area, EEC file a site-specific plan for the review and written approval of 

the Director of OEP before construction. These plans should include: 

(1) a description of construction techniques to be used (such as reduced pipeline 

separation, centerline adjustment, use of stovepipe or drag-section 

techniques, working over existing pipelines, pipeline crossover, bore, etc.), 

and include a dimensioned site plan that shows: 

i. the location of the residence in relation to the new and existing pipelines; 

ii. the edge of the construction work area; 

iii. the edge of the new permanent ROW; and 

iv. other nearby residences, structures, roads, or waterbodies. 

(2) a description of how EEC would ensure the trench is not excavated until the 

pipe is ready for installation and the trench is backfilled immediately after 

pipe installation; and 

(3) evidence of landowner concurrence if the construction work area and fencing 

would be located within 10 feet of a residence. 

Additionally, to help us monitor the implementation of construction procedures and mitigation 

measures used on these areas, we would require EEC to file weekly status reports during 

construction that would include a description of landowner/resident complaints and how these 

complaints were addressed or resolved (see section 5.5, recommendation 7). Our Environmental 

Compliance Monitors would be available to follow-up on these issues or concerns. 

EEC contacted local planning commissions in all counties within the Project area to identify any 

proposed or planned development projects that might be affected by the Elba Express Pipeline 

facilities. Table 4.8-5 outlines all planned developments crossed by and within 0.25 mile of the 

proposed pipeline. 

The Effingham County Industrial Development Authority owns the Research Forest - Tract B 

parcel. This parcel consists of 1,752 acres intended for industrial development within the next 5 

to 10 years. 

The proposed Effingham Parkway near MP 3.5, near Moss Loop and Squirrel Run, is on the 

opposite (east) side of the existing Southern ROW from the proposed pipeline alignment, 

paralleling the existing ROW for approximately 15,000 feet. The proposed parkway ROW 

would abut the pipeline ROW. A 6-foot-wide paved shoulder would be located approximately 

48 feet from the existing ROW edge and the area would be sloped for drainage. The developer 

intends to license the work with an environmental assessment to the Federal Highway 

Administration, but it may become an EIS. The developer is acquiring a 200-foot-wide 

easement, with acquisition to begin in the middle of 2008. 
 4-120 4.0 – Environmental Impact Analysis 

TABLE 4.8-4 

Residences and Structures Within 50 Feet of the Elba Express Pipeline Construction ROW 

Facility County/State Milepost 

Distance to 

Construction Work 

Area (feet) a/

Distance to 

Pipeline Centerline 

(feet) a/

Proposed 

Mitigation b/

House Effingham/GA 5.65 23 100 1, 2,3 

House Effingham/GA 6.35 45 65 1,2 

Carport Effingham/GA 6.35 2 22 1,2 

Shed Effingham/GA 6.45 within workspace 15 

Shed Effingham/GA 6.45 within workspace 13 

Shed Effingham/GA 6.45 within workspace 12 

Carport Effingham/GA 6.45 within workspace 11 

House Effingham/GA 6.45 24 44 1,2,3 

House Effingham/GA 6.55 43 120 1,2 

Structure Effingham/GA 13.80 25 67 1, 2 

House Effingham/GA 13.83 31 73 1, 2 

Mobile Effingham/GA 14.15 2 32 1, 2,3 

Mobile Screven/GA 32.27 1 31 1, 2,3 

Mobile Screven/GA 32.31 38 67 1, 2 

Mobile Screven/GA 39.65 within workspace 26 1, 2,3 

Mobile Jefferson/GA 101.74 25 67 1, 2 

Mobile Jefferson/GA 105.92 28 58 1, 2 

Mobile Hart/GA 183.90 34 59 1, 2 

_______________________________________________________________________________ 

a/ Distances are approximate. 

b/ Proposed Mitigation: 

1. Reduce construction work area to minimize impact on residence. 

2. Line the construction boundary with hay bales and silt fence. 

3. Condition regarding residences closer than 25 feet applies. 

TABLE 4.8-5 

Planned Developments Crossed or Within 0.25 Mile of the Elba Express 

Pipeline Construction ROW 

Planned Development County/State Milepost 

Crossed by the Elba Express Pipeline Construction ROW

Newport Subdivision Chatham/GA 2.25 

Keller Works Trust Properties Chatham/GA 2.85 

Effingham Parkway (Southern Connector) Effingham/GA 3.50 

Coldbrook Plantation Effingham/GA 5.25 

Research Forest Tract (“Tract B”) Effingham/GA 7.45 

Effingham County Industrial and Economic 

Commission Effingham/GA 7.45 

Parkway Place Effingham/GA 14.15 

Highway 17 Widening Project Wilkes/GA 140.35 

Within 0.25 miles of the Elba Express Pipeline Construction ROW

Planned Development County/State Distance (ft)a/

Herman Woods Effingham/GA 100 

Stafford Shire Estates Effingham/GA 1,050 
 4-121 4.0 – Environmental Impact Analysis 

Northpoint Industrial Park Chatham/GA 1,000 

Pine Hill Estates Effingham/GA 100 

Windsor Forest Subdivision Effingham/GA 200 

Highway 17 Widening Project near Tignall Wilkes/GA 150 

________________________________________________________________ 

a/ Distances are approximate. 

Stafford Shire Estates, Pine Hill Estates, and Windsor Forest Subdivision are proposed housing 

developments in Effingham County, Georgia. There are two housing developments in the 

construction phase; Newport Subdivision in Chatham and Parkway Place in Effingham. EEC is 

in consultation with the Effingham County Board of Commissioners concerning the phase of 

development of these housing projects. 

Coldbrook Plantation is an established residential subdivision in Effingham County, Georgia. A 

restrictive covenant was placed on the undeveloped wetland areas within the subdivision by the 

developer to mitigate for dredge and fill activities associated with the subdivision road. Because 

the existing pipeline corridor transects the covenanted properties, construction is unavoidable 

through this area. Additionally, EEC would require temporary workspace through this area. 

Affected wetlands would be located outside of the existing permanent ROW and allowed to 

revert to preconstruction conditions. The areas impacted would remain within the restrictive 

covenant. EEC plans to negotiate a waiver to the restrictive covenant with affected landowners 

and regulatory agencies.

Currently, the widening of State Highway 17/U.S. 1 to four lanes is proposed. This 331-mile 

highway traverses Georgia from U.S. 441 in Habersham County to the Florida state line at 

Folkston, Georgia. Approximately 133 miles of the corridor is open to traffic or under 

construction. EEC is evaluating alignment shifts where the proposed pipeline crosses the 

corridor in Wilkes County. 

As shown in table 4.8-5, the pipeline would traverse two proposed highway or highway 

expansion projects, two planned industrial developments, three planned residential developments 

and one established residential subdivision. With the exception of the Highway 17 Widening 

Project (which is crossed by the non-collocated Northern Segment), the proposed route would 

minimize potential land use impacts on these planned development projects by collocating with 

the existing Southern pipeline corridor, thus avoiding multiple crossing locations and minimizing 

the width of the pipeline easement across each planned development. To further minimize 

impacts, EEC proposes to construct the pipeline prior to construction of the industrial facility and 

individual residences that would be located adjacent to the pipeline easement, thus avoiding 

temporary construction-related impacts (i.e., land disturbance, access, noise, visual impacts) on 

these areas. Prior to initiating construction, EEC would secure an easement to convey temporary 

and permanent ROWs from affected developers, per the procedures described in section 4.8.2, 

Land Ownership and Easement Requirements. 

Based on consultations to date, the developers have not requested any site-specific construction 

and mitigation measures or restoration plans. However, because all construction - the proposed 

developments listed in table 4.8-5 and the proposed pipeline - is at least one to two years from 

commencing, consultations between EEC and developers remain on-going and will continue 
 4-122 4.0 – Environmental Impact Analysis 

until construction activities are imminent for either EEC or the developer. Therefore, we 

recommend that prior to construction, EEC file with the Secretary updated documentation 

of consultations detailing any site-specific construction and mitigation measures or 

restoration plans requested by developers crossed by or immediately adjacent to the 

pipeline route, and identifying what measures EEC has agreed to implement. 

4.8.5 Recreation and Special Interest Areas 

No designated recreational or special interest areas would be directly affected by implementation 

of the Terminal Expansion Project. Construction of the Elba Express Pipeline facilities would 

affect three recreational areas. 

Terminal Expansion

No parks, conservation easements, recreation areas, or other public land or designated areas are 

located on Elba Island. Neither the Terminal Expansion site nor the waterway for LNG marine 

traffic is located within a portion of the Savannah River that is designated under the National 

Rivers Inventory pursuant to the Wild and Scenic Rivers Act (P.L. 90-542). Designated areas in 

the general vicinity of Elba Island include Ft. Pulaski National Monument (approximately 7 

miles to the visitor’s center on Cockspur Island; park property boundary is 0.63 mile from the 

existing Terminal in the marsh land across the South Channel), Savannah River National 

Wildlife Refuge (NWR) (approximately 7 miles), Tybee NWR (approximately 4 miles), and 

Savannah’s Oatland Island Education Center (approximately 3 miles). The City of Savannah lies 

approximately 5 miles upstream of the Project, and is home to the 8th largest shipping port in the 

U.S. None of these areas would be directly affected by construction or operation of the proposed 

Terminal Expansion Project. The Savannah River could be subjected to increased vessel traffic 

in the areas of Ft. Pulaski National Monument and Tybee NWR during operation of the new 

facilities, but any additional shipping in the river channel would be controlled by the Georgia 

Ports Authority and Coast Guard. 

Elba Express Pipeline

One of the primary concerns in crossing public areas is the impact that pipeline construction and 

operation can have on recreational activities. Disruption and noise during construction could be 

a nuisance to hikers, hunters, fisherman, sightseers, and campers, and could cause disturbance to 

wildlife, especially in protected management areas. Because pipeline construction is generally 

scheduled for summer, when recreational activities are typically at their peak, this impact to a 

large extent, is unavoidable. The duration of this impact in any one area, however, would be 

short-term, lasting several days to several weeks. 

The pipeline would cross three recreation and public interest areas that are used for public 

recreational purposes. Table 4.8-6 lists the public recreation areas crossed by the proposed 

pipeline. 
 4-123 4.0 – Environmental Impact Analysis 

Di-Lane Plantation WMA consists of 8,100 acres in Burke County, GA, and is managed by the 

GDNR and owned by the COE. Recreational activities include hunting, camping, interpretive 

trails, fishing, hiking, bird watching, field trails, and picnicking. Our review of the pipeline route 

in this area indicates that active construction could impact recreational activities within the DiLane Plantation WMA. EEC has consulted with the GDNR and the COE in regard to 

construction within the Di-Lane Plantation WMA. 

Clarks Hill WMA consists of 12,700 acres in McDuffie, Wilkes, and Lincoln Counties, Georgia, 

and is managed by the GDNR and owned by the COE. Recreational activities within Clarks Hill 

WMA consist of hunting, fishing, hiking, and bird watching. EEC has consulted with the GDNR 

and the COE in regard to construction within the Clarks Hill WMA. 

Magnolia Springs State Park consists of 1,071 acres and is located in Jenkins County, Georgia. 

It is managed by the Georgia State Parks and Historic Sites Division within the GDNR (Georgia 

State Parks 2006a). Magnolia Springs State Park is within 0.25 mile of the proposed pipeline 

route from MPs 67.91 to 68.54 and within 50 feet at approximate MP 68.3. EEC is analyzing a 

minor route variation to avoid impacting the park. If it is determined that EEC cannot avoid 

impacting the Magnolia Springs State Park, EEC would discuss possible mitigation measures 

with GDNR. EEC is currently consulting with GDNR to determine crossing methods, easement 

acquisitions and permitting required. Therefore, we recommend that prior to construction, 

TABLE 4.8-6

Recreational and Public Interest Areas Crossed or Within 0.25 Mile 

of the Proposed Elba Express Pipeline 

Centerline Crossing 

Facility 

Recreation and 

Public Interest 

Area Enter MP Exit MP 

Crossing 

Distance (miles) Comment 

Wilderness/Wildlife Areas 

Pipeline-Southern 

Segment 

Di-Lane Wildlife 

Management Area 74.43 78.13 3.70 None 

Pipeline-Northern 

Segment 

Clarks Hill Wildlife 

Management Area 134.84 135.27 0.43 None 

National and State Forests/Parks/Landmarks 

Pipeline-Southern 

Segment 

Magnolia Springs 

State Park Not Crossed Not Crossed 0.00 Within 0.25 mile from MP 

67.91 to MP 68.54 

Richard B. Russell Lake Project b/ 

Beaverdam Creek 170.73 171.08 0.35 Pipeline-Northern 

Segment 

Coldwater Creek 177.92 178.08 0.16 

None 

170.73 171.08 0.35 None 

Not Crossed Not Crossed 0.00 Within 0.25 miles from 

MP 171.13 to MP 171.15 

Pipeline-Northern 

Segment 

Richard B. Russell 

Lake

177.92 178.08 0.16 None 

Protected Rivers 

Pipeline-Northern 

Segment Broad River 160.96 161.01 0.05 

The Broad River would 

be crossed by utilizing 

the HDD construction 

technique. 
 4-124 4.0 – Environmental Impact Analysis 

EEC file with the Secretary updated documentation of consultations with the appropriate 

local officials or managers of the Di-Lane Plantation and Clark Hill WMAs regarding field 

surveys, easement acquisitions, and permitting processes. The documentation should 

identify any agree-upon mitigation measurers or restoration plans developed during the 

consultations. 

 

The proposed Elba Express Pipeline would cross the Broad River, which is designated a 

protected river. A protected river is defined in the State statute as a Georgia river that has an 

average flow rate of at least 400 cubic feet per second. A protected river corridor is all land, 

inclusive of islands, in areas of a protected river and being within 100 feet horizontally on both 

sides of the river as measured from the uppermost part of the river bank (usually delineated by a 

break in the slope). The protected area also includes the area between the uppermost part of the 

riverbank and the water’s edge; however, this strip of land is not included as part of the 100-foot 

buffer requirement contained in the minimum standards (Miness, 2001). EEC would cross the 

Broad River utilizing the HDD crossing technique; therefore, impact on the protected river and 

its corridor would be avoided or minimized. 

COE Project Lands

The COE’s Savannah District operates three interconnected dams and lakes (COE Projects) in 

the upper reaches of the Savannah River Basin: Hartwell, Richard B. Russell, and J. Strom 

Thurmond. These three COE Projects form a 120-mile-long chain of lakes that are managed as a 

multipurpose integrated system. The COE manages these projects giving consideration to all 

Congressionally authorized purposes including hydropower, flood control, recreation, fish and 

wildlife, water quality, water supply, and downstream navigation (COE, 2006a). 

The Hartwell Project is the northern most COE Project located on the Georgia and South 

Carolina border. It was built by the COE between 1955 and 1963 as part of a flood control, 

hydropower, and navigation project and authorized purposes include recreation, water quality, 

water supply, and fish and wildlife management. Hartwell Lake contains 55,900 acres of water, 

962 miles of shoreline, and is surrounded by 23,563 acres of public land (COE, 2006b). The 

Hartwell Project lies about 1.6 miles northwest of the Elba Express Pipeline at MP 187.9. 

The Richard B. Russell Project is located on the upper Savannah River about 30 miles 

downstream from Hartwell Dam and 37 miles upstream from J. Strom Thurmond Dam. It was 

built by the COE between 1974 and 1984 and was authorized for power production, incidental 

flood control, recreation, additional stream flow regulation, water supply, and fish and wildlife 

management. Lake Russell contains 26,650 acres of water, 540 miles of shoreline, and is 

surrounded by 26,500 acres of public land (COE, 2006b). The Russell Project lies about 7.0 

miles northeast of the Elba Express Pipeline at MP 157.0; however, the proposed route cross two 

tributaries, Beaverdam Creek and Coldwater Creek. 

The J. Strom Thurmond Project is located on the Georgia and South Carolina border about 22 

miles northwest of Augusta, Georgia and 240 miles from the mouth of the Savannah River. It 

was built by the COE between 1946 and 1954 as part of a flood control, hydropower, and 

navigation project. Authorized purposes now include recreation, water quality, water supply, 
 4-125 4.0 – Environmental Impact Analysis 

and fish and wildlife management. Thurmond Lake contains 71,100 acres of water, 1,200 miles 

of shoreline, and is surrounded by 79,900 acres of public land (COE, 2006b). The Thurmond 

Project lies about 5.0 miles northeast of the Elba Express Pipeline at MP 131.0. 

COE Mitigation Lands

During construction of the COE’s Hartwell, Russell, and Thurmond Projects, unavoidable and 

significant loss of wildlife and fisheries resources occurred. Terrestrial habitats of wildlife were 

converted to open water and fish habitat was converted from streams to open water. The Fish 

and Wildlife Coordination Act of 1958 required the COE to mitigate for the loss of habitat due to 

the construction of Russell Dam. Since the Thurmond and Hartwell Projects were authorized 

and construction was initiated before passage of the Fish and Wildlife Coordination Act of 1958 

they were not required to purchase and manage additional mitigation land to compensate for 

habitat loss; however, each of these COE Projects has an active wildlife management program. 

Lands that were purchased to mitigate for the loss of habitat by the Russell Project are 

specifically managed for wildlife and consist of a total of 49,236 acres of Mitigation Land in and 

around Russell Lake. Mitigation Land that would be crossed by the Elba Express Pipeline 

include the Di-Lane Plantation WMA and 20,590 acres of “collar land” (that extends for a 

distance of 300 feet from the shoreline) surrounding Richard B. Russell Lake. Table 4.8-7 

identifies the COE Project and Mitigation Lands that would be crossed by the pipeline. 

TABLE 4.8-7 

COE Project and Mitigation Lands Crossed by the Elba Express Pipeline 

COE Land Acreages Affected Name MP 

Project Mitigation Construction Operation 

Di-Lane Plantation WMA 74.43 – 78.13 Yes Yes 18.3 4.7 

Little River 134.8 – 135.2 Yes No 9.3 2.8 

Richard B Russell Lake / 

Beaverdam Creek 

170.5 – 171.0 

173.1 – 173.3 

Yes Yes 10.7 

3.2 

3.3 

1.4 

Coldwater Creek 179.3 – 179.5 Yes Yes 6.5 1.1 

Savannah River 187.1 – 187.2 

187.4 – 187.7 

187.7 – 187.9 

Yes 

Yes 

Yes 

No 

No 

Yes 

1.1 

4.6 

3.0 

0.4 

2.1 

1.2 

Total - - - 56.7 17.0 

EEC met with the COE on May 7, and subsequently developed a mutually-acceptable mitigation 

plan for the crossing of COE-managed properties. The FWS and GDNR have submitted a 

concurrence to the mitigation plan. A summary of the mitigation plan is located in appendix M. 

Additional information in regard to potential construction related impacts and proposed impacts 

on COE lands associated with Beaverdam Creek and Coldwater Creek are discussed in section 

4.3.3. 
 4-126 4.0 – Environmental Impact Analysis 

4.8.6 Visual Resources 

Terminal Expansion

The degree of visual impact that may result from a proposed project is typically determined by 

considering the general character of the existing landscape and the visually prominent features of 

the proposed facilities. The Terminal Expansion facilities would be constructed entirely on 

unused portions of the existing terminal site. 

The existing LNG storage tanks and the north and south dock LNG unloading arms adjacent to 

the slip currently are the dominant visual elements in the vicinity and can be seen from the 

Savannah River from points adjacent to downtown Savannah. The older three existing storage 

tanks stand 168 feet high and 166 feet in diameter, whereas the newer existing tank (D-4) stands 

185 feet high and 258 feet in diameter. The proposed new LNG tanks (D-5 and D-6) would be 

192 feet high and 289 feet in diameter and would be the largest tanks on Elba Island. The new 

LNG tanks would be painted in the same color as the existing tanks (sky blue) and would blend 

in with the visual environment, which includes the existing four tanks. 

There would be a noticeable impact on the visual environment of the site vicinity due to 

construction of the Terminal Expansion. The new LNG tanks would be larger in diameter (31 

feet) and taller (7 feet) than the next largest existing tank (D-4). The proposed new tanks, 

however, would be visually consistent with the adjacent existing tanks and would be visually 

consistent with the current visual environment in the area. 

Elba Express Pipeline

Clearing, pipeline construction, and maintenance of the ROW would result in short-term and 

long-term adverse impacts on local visual resources. At the overall project level, the majority of 

the proposed pipeline facilities would be located in rural areas or pine or other forest with low 

population densities. Along the looping portion of the proposed route (MP 0 to MP 104.8), there 

would be only an incremental change to the existing viewscapes. The construction ROW would 

be cleared and the establishment of new permanent ROW would be limited. Visual impact on 

private or commercial pine plantations would be negligible as plantations are periodically 

harvested. Although long-term, these changes would not be significant. 

Along the greenfield portion of the route (MP 104.8 to MP 189.7), we have identified no areas of 

particular visual sensitivity where pipeline construction or establishment of a new ROW would 

be frequently seen by a large number of individuals. Therefore, the visual impact of the overall 

project would not be significant. At the level of individual properties, the severity of the longterm visual impact of tree removal would depend on the sensitivity of the landowner. 

Restoration measures are available which could mitigate visual impact on individual properties, 

but these would be the subject of easement negotiations. The effectiveness of mitigation 

measurers can only be judged by the landowner. 
 4-127 4.0 – Environmental Impact Analysis 

The pipeline route crosses two tributaries of Russell Lake – Beaverdam Creek and Coldwater 

Creek. A 110-foot wide work area would be cleared along the pipeline route on both sides of 

these two tributaries. Once construction is completed the area would be reseeded. Sixty feet of 

the 110 feet would be allowed to return to its natural state, and the remaining 50 feet would be 

maintained as a permanent ROW. The permanent ROW would be periodically mowed and 

would appear somewhat like a 50-foot wide, rough golf fairway. This ROW would not be 

visible to campers at the Richard B. Russell State Park campground as it is approximately 6 

miles from Beaverdam Creek pipeline crossing and approximately 5 miles from the Coldwater 

Creek crossing. Without mitigation, the ROW would be visible, however, to people who may be 

boating or fishing on the tributaries and would be an unavoidable visual impact along these 

tributaries. The COE, however, plans to require EEC to replant shallow rooted shrubs adjacent 

to the lake 20+ feet from the shoreline to provide a visual buffer. 

Construction and operation of the aboveground facilities would result in minor permanent visual 

impacts. Existing hedge rows or landscaping would be maintained where practical to lessen the 

visual impact of construction to landowners. One residence at MP 105.92 would be within 50 

feet of MLV-010; and nine residences within 50 feet of the edge of the construction ROW 

4.8.7 Coastal Zone Management 

The Georgia Coastal Management Program is administered by the GDNR Coastal Resources 

Division under the authority of the Georgia Coastal Marshlands Protection Act. The Act 

requires review of certain activities and structures within tidal water areas in order to protect 

habitat, nursery sites, and food sources for marine and wildlife, as well as to protect those areas 

that act as a buffer against flooding and erosion, and as a filter to help control and disseminate 

pollutants. The portion of the Project located within the designated coastal zone management 

area in Georgia consists of the Terminal Expansion site and the Elba Express Pipeline facilities 

from MP 0.0 to MP 31.8. 

To date, GDNR Coastal Resources Division has modified or issued all necessary permits to 

Southern LNG, including a Coastal Zone Management Act (CZMA) consistency determination, 

for work on the Terminal site. The permits examined the affect of the Project on both right 

whale and manatee populations within the waterway for LNG marine traffic. GDNR Coastal 

Resources Division has not yet, however, issued its final determination of consistency with the 

CZMA for the pipeline portion of the Project however. Therefore, we recommend that EEC 

not begin construction of the Elba Express Pipeline facilities until it files a copy of the 

Coastal Zone consistency determination issued by the GDNR. 

Waterway for LNG Marine Traffic

For the purposes of determining potential impacts associated with a release of LNG, section 

4.12.4.3 identifies thermal radiation hazard zones (Zones of Concern). The zones move with the 

LNG vessel along the transit route and are depicted in figures 4.12-1 and 4.12-2. The waterway 

considered in this analysis extends beyond the Savannah River Channel to include the islands 

within the channel and the banks along its sides, which is an area approximately 4.4 miles wide 

and 20 miles long comprised of a static Zone 1-3. The banks along both the north and south 
 4-128 4.0 – Environmental Impact Analysis 

sides of the channel are largely undeveloped and primarily comprised of wetlands, with some 

bare lands, grasslands, and forests. Elba, Long and Cockspur Islands are located within the 

channel. Elba Island is classified industrial as it is the location of the Terminal. Long Island is 

undeveloped. Commercial and recreational facilities are located on Cockspur Island, which 

hosts a USCG Station, the Savannah River Pilot Boat Dock Facility, and the Fort Pulaski 

National Monument, a National Park Service site that continues along the southern banks of the 

channel. 

On the northern banks of the channel are Jones, Hog and Turtle Islands. The eastern half of 

Jones Island is set aside for the Tybee Island National Wildlife Refuge, a sanctuary for migratory 

birds that is closed to all public use. The remainder of Jones Island and Hog Island are 

undeveloped and used by the Georgia Department of Transportation to dispose of dredge spoil in 

maintaining the Savannah River Channel. Turtle Island, just north of Jones, hosts the South 

Carolina Department of Natural Resources Turtle Island Wildlife Management Area, a migratory 

bird nesting and roosting area. 

Located at the south side of the mouth of the channel are a three islands that have residential, 

commercial, and recreation areas. Tybee Island is home to Tybee Island City, a year-round 

beach community of 3,392 people that swells to approximately 9,000 during the summers as 

tourists come to visit the beach and/or the national register historic properties of Fort Screven 

Historic District and the Tybee Lighthouse. Just west of Tybee Island is Wilmington and Talahi 

Islands with a collective population of 14,213. 

Additional uses in the waterway include commercial and recreational crabbing, fishing and 

boating; shellfish harvest areas; and an ocean dredged material disposal site. 

Residences within the Zones of Concern are limited to those on Tybee, Wilmington, and Talahi 

Islands (see figure 4.12-2). Residences on Tybee Island are within both Zones 2 and 3, and a 

fraction of the residences on Wilmington and Talahi Islands are within Zone 3. According to the 

Chatham County Islands Area Community Plan, island residents want to maintain the area’s low 

density housing. Currently, 76 percent of the community’s area is in residential land use; 74 

percent of the total area is single family. The Islands Area Community Plan proposes that it 

remain above 70 percent as a matter of public policy. Planned developments such as higher 

density housing and limited commercial areas are proposed for the town centers which are 

further inland, beyond of Zone 3. 

Possibilities for other development along the waterway are limited as much of the land is set 

aside as national park lands or wildlife refuges. One development plan that has been pursued by 

Jasper County, South Carolina officials since the early 1990s is the construction of a port along 

the northern banks of the Savannah River Channel directly across from the Elba Island Terminal. 

The South Carolina State Ports Authority, however, has long opposed the development, and most 

recently won a court case to condemn the land where the port was proposed for development. 

Despite the condemnation, both state governors have vowed to build the port and hope to come 

to an agreement with all state agencies in order to do so. 
 4-129 4.0 – Environmental Impact Analysis 

The Port of Savannah is one of the busiest ports in country, with passage of large cargo vessels 

along the Savannah River Channel a recurrent aspect along the waterway. The majority of land 

along the waterway is undeveloped shoreline and the developed areas are comprised of smaller 

residential and commercial buildings. The most prominent structure in the waterway is the 

Tybee Lighthouse, which is 154 feet high (approximately 13 stories). 

Under normal operations of the LNG vessel, there would be nominal impacts to land use, 

residences, or visual resources. While the likelihood of an emergency leading to a marine LNG 

spill is very remote, potential hazards resulting from an ignited or unignited LNG release are 

considered in this EIS (as detailed in section 4.12.4.3). Due to its physical properties, released 

LNG would quickly disperse in the atmosphere or, if ignited, burn in a pool of fire. A substantial 

unignited LNG release and dispersion would be a short-lived event that would have no impact on 

land use, residences or visual resources. Impacts from a substantial release of LNG with ignition 

would depend on the location of the incident within the waterway and the scope of the incident. 

In general, damage to man-made structures and vegetation ranges from mild to severe with the 

greatest impacts occurring within Zone 1 and decreasing outward through Zones 2 and 3. 

However, the implementation of safety and security measures during marine transit (see section 

4.12, Reliability and Safety), make the likelihood of a spill from an LNG vessel extremely 

remote. 

4.9 SOCIOECONOMICS 

Several potential socioeconomic effects may result from construction and operation of the 

proposed LNG facility. Many of these potential effects are related to construction and are 

associated with the number of local and non-local construction workers who would work on the 

Project, payrolls and local expenditures, and impacts on population, public services, and housing 

during the construction period. Other potential effects related to construction include increased 

traffic or disruption of normal traffic patterns in the Project vicinity, and increased expenditures 

for construction materials for the Project. Potential economic benefits associated with operation 

of the Project include increased property tax revenue, increased job opportunities and income, 

and ongoing local expenditures by the operating company. 

4.9.1 Population 

Terminal Expansion

The existing Southern LNG Terminal, site of the proposed Terminal Expansion facilities, is 

located on Elba Island, Chatham County, Georgia. Table 4.9-1 provides a summary of select 

population characteristics for Chatham County. The majority of Chatham County’s population 

resides in the city of Savannah. 
 4-130 4.0 – Environmental Impact Analysis 

TABLE 4.9-1

Existing Socioeconomic Conditions in the Vicinity of the Terminal Expansion 

State/County Estimated 2005 

Population a/

2000 Population 

Density 

(people/mile2

) a/

1999 Median 

Household Income 

a/

2000 Labor Force 

a/

Feb. 2006 

Unemployment 

Rate b/

Georgia 9,072,576 141 $42,433 4,129,666 5.0% 

Chatham 238,410 530 $37,752 113,087 4.3% 

____________________________________________________________________ 

a/ Data were obtained from the U.S. Census Bureau website 2005 (www.census.gov). 

b/ Data were obtained from the Department of Labor website 2005 (www.dol.gov). 

Population impacts resulting from Terminal Expansion Project activities would be associated 

with any temporary increase in residents, and would be a function of the total number of nonlocal construction workers required for the expansion, plus any family members accompanying 

them to the area. Based on workforce estimates provided by Southern LNG, a maximum of 208 

workers would relocate to the Savannah area. Accounting for additional family members 

coming to the area, Southern LNG calculated that a maximum of a total of 518 people would 

move to the area for the duration of construction of the Terminal Expansion facilities. The 

population increase would have minimal impact as this represents an increase of less than 0.01 

percent of the total population of Chatham County. 

Following construction, 20 full-time positions would be created to maintain and operate the new 

Terminal Expansion facilities. This small staff would likely be comprised of both existing 

residents and non-local personnel. 

Elba Express Pipeline

The Elba Express Pipeline facilities would be located in twelve counties in Georgia (Chatham, 

Effingham, Screven, Jenkins, Burke, Jefferson, Glascock, Warren, McDuffie, Wilkes, Elbert and 

Hart) and one county in South Carolina (Anderson). Table 4.9-2 provides a summary of select 

population characteristics for the areas affected by the Elba Express Pipeline. Chatham County 

is the largest and most dense population center affected by the pipeline. The majority of 

Chatham County’s population resides in the city of Savannah. 

Population impacts resulting from pipeline activities would be a function of the total number of 

non-local construction workers required for the project. Construction of the proposed Elba 

Express Pipeline would be organized into two construction phases (Phase A and Phase B). 

Construction on Phase A is scheduled to begin in mid 2009 and be completed early-to-mid 2010, 

lasting approximately 8 months. Phase A construction is proposed to be divided into two 

construction spreads, one spread for the southern portion of the pipeline route, and a second 

spread for the northern portion of the pipeline route. Each spread would require approximately 

450 construction personnel and 50 additional personnel to perform survey, radiographic and 

inspection services. Phase B construction, which would require approximately 30 construction 

personnel, is scheduled to begin in early-to-mid 2012 and would be completed by December 
 4-131 4.0 – Environmental Impact Analysis 

2012. As the two large construction spreads would be operating in different counties, the 

maximum population increase to any county is approximately 500 people. This would result in 

population increase ranging from less than 0.01 percent in Chatham County (the largest county) 

to an increase of 18 percent in Glascock County (the smallest county). Although this population 

increase is substantial in small counties, the impacts of the population are expected to be minimal 

because of the short construction time frame associated with the pipeline work. 

Following construction, operational activities associated with the pipeline facilities would 

require an estimated three new staff to provide daily operational support. This small increase in 

permanent residents would have a negligible effect on overall population of the area. 

4.9.2 Economy and Employment 

Terminal Expansion

The information from the 2005 U.S. Census for Chatham County shows that the educational, 

health, and social services sector employed the largest number of individuals. This sector was 

followed by retail trade, and arts, entertainment, recreation, accommodation, and food services. 

The 1999 median household income in the Chatham area ($37,752) was lower than the 1999 

median household income for Georgia ($42,433). 

TABLE 4.9-2

Existing Socioeconomic Conditions in the Vicinity of the Elba Express Pipeline 

State/County Estimated 2005 

Population a/

2000 Population 

Density 

(people/mile2

) a/

1999 Median 

Household Income 

a/

2000 Labor Force 

a/

Feb. 2006 

Unemployment 

Rate b/

Georgia 9,072,576 141 $42,433 4,129,666 5.0%

Chatham 238,410 530 $37,752 113,087 4.3% 

Effingham 46,924 78 $46,505 18,229 3.2% 

Screven 15,430 24 $29,312 6,569 5.2% 

Jenkins 8,729 25 $24,025 3,728 5.6% 

Burke 23,299 27 $27,877 9,108 6.8% 

Jefferson 16,926 33 $26,120 6,747 7.3% 

Glascock 2,705 18 $29,743 1,237 5.4% 

Warren 6,101 22 $27,366 2,581 8.2% 

McDuffie 21,743 82 $31,920 9,712 6.4% 

Wilkes 10,457 23 $27,644 4,754 6.5% 

Elbert 20,799 56 $28,724 9,291 7.5% 

Hart 24,036 99 $32,833 11,004 8.1% 

South 

Carolina 4,255,083 133 $37,082 1,974,222 6.4% 

Anderson 175,514 231 $36,807 81,305 7.9% 

____________________________________________________________________ 

a/ Data were obtained from the U.S. Census Bureau website 2005 (www.census.gov). 

b/ Data were obtained from the Department of Labor website 2005 (www.dol.gov). 
 4-132 4.0 – Environmental Impact Analysis 

The Terminal Expansion Project would be constructed over a 64-month period and would 

employ an average of 120 workers per month with a peak work force of 208 personnel. Southern 

LNG has stated that it would use local workers to the extent they possess the necessary skills and 

would hire workers from outside the local area as necessary. 

During the proposed 64-month construction period, the total payroll for the Terminal Expansion 

Project is estimated at $33 million (after subtracting an average of 25 percent for federal income 

tax, Federal Insurance Contributions Act (FICA) payments, and other fixed deductions). The 

total amount spent on local goods and services (construction materials and equipment, housing, 

food, etc.) is also estimated at $33 million. The payroll and dollars spent on goods and services 

would have a positive impact on the local economy of the region. 

Construction of the Terminal Expansion facilities would increase economic activity within the 

area through the sum of three effects: 1) the direct effect – hiring of local construction workers 

and purchases of goods and service from local businesses; 2) the indirect effect – the additional 

demands for goods and services, such as replacing inventory from the firms that sell goods and 

services directly to the project; and 3) the induced effect – the spending of disposable income by 

the construction workers at local businesses, which in turn order new inventory from their 

suppliers. The temporary increase in economic activity resulting from the sum of these three 

effects would provide a positive economic impact for the region. 

The Terminal Expansion Project would employ on average 120 personnel over a 64-month 

construction period. In addition to the direct employment and payroll impacts generated by 

implementation of the Terminal Expansion Project, secondary economic impacts also would 

occur, including both indirect and induced effects. The U.S. Department of Commerce, Bureau 

of Economic Analysis (BEA) has developed a methodology for determining these secondary 

impacts. Use of their Regional Input-Output (I-O) Modeling System (RIMS II) provides means 

for estimating secondary effects (combining both indirect and induced effects across all 

industries), based on the direct impacts (jobs and payroll) as inputs to the model. The use of 

RIMS II multipliers shows that in addition to the 120 jobs at the Terminal site during 

construction, the Terminal Expansion Project has the potential to result in approximately 99 

secondary impact jobs, and that in addition to the $8,250,000 in annual direct earnings by 

construction personnel during construction, there is the potential for approximately $5,979,600 in 

secondary earnings within the region for the duration of construction. With respect to operation, 

Southern LNG anticipates a need for up to 20 additional permanent staff to operate the LNG 

facility with an estimated annual payroll of $1.2 million. The use of economic multiplier here 

shows the potential for an additional 42 secondary impact jobs in other industries in the region 

and an additional $1.2 million in secondary earnings. 

Elba Express Pipeline

In Chatham, the area where the pipeline begins, the 2005 census information indicates that the 

educational, health, and social services sector employed the largest number of individuals. This 

sector was followed by retail trade, and arts, entertainment, recreation, accommodation, and food 

services. In the other counties located along the pipeline, manufacturing was the leading 

employment sector. The 1999 median household income in the Chatham area ($37,752) was 
 4-133 4.0 – Environmental Impact Analysis 

lower than the 1999 Georgia median household income of $42,433. In the other counties along 

the pipeline, median household income ranged from $24,025 in Jenkins County, to $46,505 in 

Effingham County. 

EEC has stated that it would use local workers to the extent they possess the necessary skills and 

would hire workers from outside the local area as necessary. It is estimated that the resultant 

labor costs during construction would be over $30 million (after subtracting an average of 

25 percent for federal income tax, FICA payments, and other fixed deductions). In addition, it is 

anticipated that workers would spend between 25 and 30 percent of their total income locally, 

which would equal nearly $7.5 million (during the construction of the pipeline facilities). 

In addition to the direct employment and payroll impacts generated by the Elba Express Pipeline, 

secondary economic impacts are also expected to occur, including both indirect and induced 

effects. Indirect impacts are the additional demands for goods and services from local businesses 

that sell directly to the project. Induced effects are the increases in employment and income 

generated by the expenditure of disposal income of the new workers at local businesses. Use of 

the U.S. Department of Commerce, BEA Regional I-O RIMS II multipliers provides a means for 

estimating potential secondary effects (combining both indirect and induced effects across all 

industries) based on the direct impacts (jobs and payroll). 

Based on the use of RIMS II multipliers from BEA 2003 regional economic accounts data, it is 

estimated that the Elba Express Pipeline has the potential to result in approximately 446 

secondary impact jobs during construction, in addition to the 538 jobs (average) at the project 

site within the region, and 16 secondary impact jobs for Phase B (in addition to the average of 19 

direct construction jobs). In addition to the earnings paid to pipeline project employees, the 

multipliers indicate the potential for approximately $29,424,000 in secondary earnings to be 

generated by the pipeline project within the region for Phase A construction and $687,786 in 

secondary earnings for Phase B construction. 

Additional beneficial impacts of the Elba Express Pipeline would result from payments for 

construction materials, as well as for the rental of space for field offices and for temporary 

storage of construction materials. 

Operation of the pipeline is also expected to have positive secondary economic impacts. The use 

of RIMS II multipliers for the “pipeline transportation” sector showed the potential of 

approximately 16 secondary impact jobs, in addition to the three operations jobs at the project 

site, within the region. In addition, the use of the RIMS II multipliers showed the potential for 

approximately $636,675 in secondary earnings to be generated by the Elba Express Pipeline, in 

addition to the $250,000 of earnings paid to pipeline project employees within the region. 

4.9.2.1 Economic Impacts to Forestry 

EEC would impact 516.78 acres of planted pine forest during construction, 375.94 acres of 

which would be within temporary easement, and 185.84 acres of which would be within 

permanent easement. For the 375.94 acres of forested land temporarily cut and cleared for 

pipeline construction, EEC would pay the landowner a fee to use the property during 
 4-134 4.0 – Environmental Impact Analysis 

construction and for the value of the timber EEC cuts, thereby mitigating short-term economic 

impacts on timber production. These temporary ROWs would be returned to the landowner 

following construction and available for future planting and use in timber production, thereby 

resulting in no long-term economic impact on future timber crops. For the 185.84 acres 

permanently impacted, production of future timber crops would be prohibited within the 

permanent easement during the life of the project. EEC would pay the landowner for the value 

of the timber EEC removes on permanent ROW, thereby mitigating short-term impacts on timber 

production. Additionally, EEC would compensate the landowner for loss of the permanent 

ROW easement and its use (including the loss of timber production if applicable), in accordance 

with the procedures identified in section 4.8.2, Land Ownership and Easement Requirements. 

Accordingly, minimal long-term economic impact is expected from this loss of timber 

production. 

4.9.3 Local Taxes and Government Revenue 

Terminal Expansion

Construction and operation of the Terminal Expansion facilities would have a positive effect on 

local tax revenue, based on tax projections. During construction, sales and use tax of 

approximately $5 million would be paid on materials used for the project and once in service, 

operation of the Terminal would contribute additional ad valorem taxes of approximately $3 

million per year and generate annual sales tax revenues of $129,000 per year. 

Elba Express Pipeline

The pipeline would provide total annual ad valorem taxes of approximately $4.1 million during 

Phase A of the proposed Project, and approximately $4.9 million during Phase B, which extends 

through the life of the Project. The ad valorem taxes are a property tax on public utility 

equipment. These ad valorem taxes would generate revenues for the counties along the pipeline 

route (see table 4.9-3). Construction of the Pipeline is expected to generate $5.2 million in sales 

taxes, which will also generate revenues for the counties along the pipeline route (see table 4.9-

4). Operation of the pipeline is expected to generate approximately $10,000 per year in local 

sales taxes on pipeline facilities during Phase A, and approximately $15,000 per year in local 

sales taxes during Phase B. 

4.9.4 Housing 

Terminal Expansion

According to the U.S. Census Bureau, Census 2000, there were 99,683 housing units in Chatham 

County, Georgia, in 2000. Of all the housing units, not just single-family homes, 89,865 were 

occupied and 9,818 were vacant. Of the vacant housing units, 1,137 were for seasonal, 

recreational, or occasional use. Table 4.9-5 provides a summary of housing statistics for C 

hatham County, as well as the state of Georgia. 
 4-135 4.0 – Environmental Impact Analysis 

TABLE 4.9-3

Annual Ad Valorem Tax Estimates by County 

for the Elba Express Pipeline Project 

Annual Estimated Ad Valorem Tax Based on 

2005 Rates and Annual Increases in 

County/State Assessments of 1% per Year ($) 2005 Effective Tax 

Rates (%) 

Phase A - 2010 Phase B - 2012 

Chatham/Georgia 1.3143 138,500 157,429 

Effingham/Georgia 1.2221 711,736 809,011 

Screven/Georgia 1.0381 554,472 630,253 

Jenkins/Georgia 1.1068 303,638 549,929 

Burke/Georgia 0.8846 424,693 482,737 

Jefferson/Georgia 1.0996 339,180 385,537 

Glascock/Georgia 1.3528 148,192 168,446 

Warren/Georgia 1.3292 193,566 220,021 

McDuffie/Georgia 0.9620 271,947 309,115 

Wilkes/Georgia 1.0176 505,388 574,460 

Elbert/Georgia 1.0772 425,932 484,145 

Hart/Georgia 0.7133 100,330 114,043 

Anderson/South Carolina 1.9800 58,741 66,769 

Total 4,176,315 4,951,895 

TABLE 4.9-4

Construction Cost Estimates by County 

for the Elba Express Pipeline Project 

County/State Labor Costs a/

($) 

Material Purchases b/

($) 

Expenditure By 

Construction 

Workers c/($) 

Estimated Sales Tax 

Revenues d/ 

($)

Chatham/Georgia 850,000 3,700,000 200,000 125,000 

Effingham/Georgia 4,600,000 22,300,000 1,100,000 746,000 

Screven/Georgia 4,200,000 20,300,000 1,000,000 679,000 

Jenkins/Georgia 2,100,000 10,500,000 520,000 351,400 

Jenkins/Georgia (Phase 

B) 700,000 8,800,000 175,000 275,000 

Burke/Georgia 3,700,000 18,100,000 900,000 606,000 

Jefferson/Georgia 2,300,000 10,900,000 500,000 362,000 

Glascock/Georgia 750,000 3,800,000 200,000 128,000 

Warren/Georgia 1,100,000 5,800,000 300,000 195,000 

McDuffie/Georgia 2,200,000 11,600,000 600,000 390,000 

Wilkes/Georgia 3,900,000 20,600,000 1,100,000 695,000 

Elbert/Georgia 3,000,000 16,800,000 850,000 563,500 

Hart/Georgia 1,100,000 4,100,000 200,000 137,000 

Anderson/South Carolina 200,000 550,000 30,000 18,600 

PROJECT TOTAL 30,700,000 157,850,000 7,675,000 5,271,500 
 4-136 4.0 – Environmental Impact Analysis 

TABLE 4.9-4

Construction Cost Estimates by County 

for the Elba Express Pipeline Project 

____________________________________________________________________ 

a/ Labor costs are based on historical experience and contractor estimates. 

b/ Material costs are costs for materials installed in each county and are based on manufacturer’s published prices or quotations,

conversations with equipment suppliers, and on historical experience. 

c/ It is estimated that workers can be expected to spend between 25 percent – 30 percent of their income locally. In areas where 

aboveground facilities will be installed, estimates may be higher due to an extended presence of workers. 

d/ Estimated tax revenues are generated by combining the sales taxes from estimated material purchases (3% tax rate used) and 

sales taxes from estimated expenditures by construction workers (7% tax rate used). It does not include annual ad valorem taxes 

or other annual taxes generated by the operation of EEC’s facilities. 

In addition to the large number of rental units available in Chatham County, there are 11,085 

total motel/hotel rooms there as well. Accordingly, we find the available housing stock and 

hotel/motel stock, more than sufficient to address the maximum population scenario which 

would include the relocation of 518 construction workers and family members into the area for 

the duration of the Terminal Expansion Project. 

Elba Express Pipeline

With respect to the pipeline work, employees are more likely to stay in short term housing units 

due to the short duration of the work and frequent movement of the work location as the pipeline 

installation progresses. There are 2,789 hotel/motel/rental units and 251 RV/campsites for the 

southern section of the pipeline, and 2,133 hotel/motel/rental units and 689 RV/campsites for the 

northern section of the pipeline. Based upon the estimate made by Elba Express of non-local 

workers required during construction, an estimated maximum of 350 housing units (70 percent of 

500 workers) would be required for each construction spread during Phase A. Even assuming an 

80 percent occupancy rate at the above referenced facilities, there would still be sufficient 

lodging available to support the estimated maximum demand of 350 housing units for short-term 

temporary housing. Our review of this information concludes that there is adequate housing 

capacity to address this increase in population and any population impacts would be minimal and 

of short duration. 

TABLE 4.9-5

2000 Housing Characteristics in Chatham County a/

County/State 

Total 

Housing 

Units 

Occupied 

Housing 

Units 

Owner 

Occupied 

(percent) 

Renter 

Occupied 

(percent) 

Owner Vacancy 

Rate (percent) 

Rental Vacancy 

Rate (percent) 

Chatham, Georgia 99,683 89,865 60.4 39.6 1.7 9.8 

Georgia 3,281,737 3,006,369 67.5 32.5 1.9 8.4 

____________________________________________________________________ 

a/ Data from U.S. Census Bureau 2000 
 4-137 4.0 – Environmental Impact Analysis 

4.9.5 Public Services 

Terminal Expansion

In the area of the Terminal there are a wide range of public services and facilities. In Chatham, 

services and facilities include full-service law enforcement (575 officers and 180 civilian 

personnel), paid and volunteer fire departments, 48 primary and secondary public schools, six 

hospitals with a total of 876 beds, emergency response services that employ over 285 civilian 

personnel, water and sewer services, a library system, and social services. 

Because the non-local workforce would be small relative to the current population of the area, 

construction of the Terminal Expansion facilities would result in only minor temporary impact, 

or no impact to local community facilities and services such as police, fire, medical, and waste 

disposal services. Local communities have adequate infrastructure and community services to 

meet the needs of the relatively small increase of non-local workers that would be required for 

the expansion. Other construction-related demands on local agencies could include increased 

enforcement activities associated with issuing permits for vehicle load and width limits, local 

police assistance during construction to facilitate traffic flow, and emergency medical services to 

treat injuries resulting from construction accidents. 

We conclude that construction and operation of the proposed Terminal Expansion facilities 

would not result in significant impacts on local public services in the project area. 

Elba Express Pipeline

In Chatham, services and facilities include full-service law enforcement (575 officers and 180 

civilian personnel), paid and volunteer fire departments, 48 primary and secondary public 

schools, six hospitals with a total of 876 beds, emergency response services that employ over 

285 civilian personnel, water and sewer services, a library system, and social services. The other 

counties in the area of the pipeline are more rural and municipal services are more limited, but all 

counties have police/sheriff departments and fire/rescue departments. The effect of in-migration 

on municipal services in the area of the pipeline would also be minimal as pipeline construction 

crews would be spread out over a large distance. Therefore, there would be no large influx of 

people on any one municipality. Additionally, construction at any given location would take 

place over a short period of time, so no permanent additions to the region’s infrastructure would 

be necessary. Finally, few workers are expected to bring family members, which further reduces 

any need for public services. 

We conclude that construction and operation of the proposed Elba Express Pipeline would not 

result in significant impacts on local public services in the project area. 
 4-138 4.0 – Environmental Impact Analysis 

4.9.6 Transportation 

LNG Terminal Traffic

Access for transporting equipment, materials and personnel to the proposed Terminal Expansion 

site would be provided by existing roads. The entrance to the Terminal is located on Elba Island 

Road near its intersection with the Islands Expressway. The Islands Expressway is classified as 

a four-lane divided major county road. Based on this classification, the daily capacity of Islands 

Expressway is 33,900 vehicles per day. 

The intersection of Islands Expressway with Elba Island Road and Runaway Point Road was 

evaluated to determine individual approach delay and corresponding level of service. No 

mitigation at this intersection is recommended, because 1) all projected vehicle queues can be 

accommodated so that the mainline through-traffic is not impeded, 2) the relatively low side 

street volumes during the peak hours would not warrant a traffic signal or turn lane 

improvements, and 3) it is expected that some of the construction traffic would occur outside the 

A.M. and P.M. peak hours. 

Site access patterns for trucks were established for the Elba Island Recommissioning Project in 

2000 (FERC 2000). In order to avoid truck traffic in the downtown area of Savannah, Terminalgenerated truck traffic would access the site by traveling Interstate 516 east to Harry S. Truman 

parkway, ending as Islands Expressway eastbound, and accessing Elba Island Road via a left 

turn. Conversely, all exiting truck traffic would follow this route in reverse. Approximately 

70 percent of the automobile traffic is expected to access Elba Island Road from Islands 

Expressway west, and 30 percent is expected to access Elba Island Road from Islands 

Expressway east. 

Construction and operation worker parking and equipment storage would be provided on the 

Terminal site. Material deliveries to the site would occur throughout the majority of the 

construction phase, peaking in the thirtieth month at approximately 210 vehicles per month. On 

average, 80 to 100 material deliveries per month would be anticipated through all but the final 

three months of the construction period. Southern LNG has stated it would schedule the arrival 

of material deliveries to occur during the non-peak traffic periods to the extent possible. 

An average of approximately 120 workers would be employed over the 64-month construction 

period. A conservative estimate in accordance with industry norms indicates that the occupancy 

rate for each vehicle transporting workers to and from the Terminal Expansion site would 

average 1.3 persons per vehicle. This number translates into about 92 cars per day transporting 

workers to and from the site twice per day (total of 184 trips to and from the site each day). At 

the peak of construction, approximately 208 workers would travel to and from the site. This 

figure translates into approximately 160 cars per day to and from the site twice per day (total of 

320 trips to and from the site each day). 

We conclude based on the Traffic Impact Analysis that no new intersection traffic control 

improvements would be necessary to offset increased intersection approach delays resulting from 

construction and operation of the Terminal Expansion facilities. In addition, no mitigative 
 4-139 4.0 – Environmental Impact Analysis 

measures would be necessary to maintain an acceptable level of service for the intersection 

during current and future projected construction and operational phases. 

The Traffic Impact Analysis does, however, make recommendations for posting speed limit signs 

on Elba Island Road to ensure adequate sight distance and paving the shoulders at the 

intersection of Elba Island Road and Islands Expressway to improve the turning radii. Southern 

LNG has provided the Traffic Impact Analysis to the Chatham County Department of 

Engineering and asked for guidance on whether and how the report’s recommendations should 

be implemented. We request that Southern LNG comply with recommendations made by the 

Chatham County Department of Engineering. 

4.9.6.1 Marine Traffic Impacts 

Expected LNG Vessel Volume

When fully operational and assuming full utilization, the Terminal Expansion Project would 

result in approximately an additional 95 shipments of LNG, annually. Assuming full utilization 

of the post-Elba III capacity of the Terminal and assuming LNG vessel capacities of either 

125,000 m3

 on the low end or 266,000 m3 on the high end, the Terminal would receive LNG 

from a total of 142 to 299 LNG vessel visits per year. Assuming an even spread of 95 visits 

among 52 weeks in a year, the number of additional LNG vessel visits per week resulting from 

the Elba III Project would average less than two. This represents approximately three percent 

increase to the 3,041 vessel calls to the Port of Savannah in the year 2020. 

As experienced with Elba Island operations thus far, it is not anticipated that LNG shipments 

would immediately fill new Terminal capacity when it first becomes available, but would ramp 

up with the upstream liquefaction projects and with the downstream demand for natural gas. The 

new Elba III capacity is expected to phase in to service from 2010 through 2012. 

Existing Vessel Traffic in the Port of Savannah

Vessel traffic on the Savannah River has increased by approximately 15 percent over the last 

decade, based on data provided by the Savannah Pilots Association in the Elba II Expansion 

application. If this rate of increase continues, then the number of vessel calls to the Port of 

Savannah would be as shown in Table 4.9-6. In its most recent annual report, the Georgia Ports 

Authority indicates even more rapid growth rates. According to press releases, in fiscal year 

2002, the Georgia Port Authority served 2,180 vessels carrying 1.137 million twenty foot 

equivalent containers units (TEUs) handled by the Port of Savannah. In fiscal year 2005, total 

TEUs increased to 1.76 million, which is an annual growth rate of approximately 15 percent. By 

2015, Georgia Port Authority projects the Port of Savannah would have the capacity to handle 

4.37 million TEUs, an almost 11 percent annual increase in the number of containers over the 

2002 level. 
 4-140 4.0 – Environmental Impact Analysis 

TABLE 4.9-6

Summary of Vessel Calls to the Port to be Handled by the Savannah Pilots 

Association Over the Next 50 Years a/

 

Year No. of Vessels 

2010 2,645 

2020 3,041 

2030 3,497 

2040 4,021 

2050 4,624 

__________________________________________________________ 

a/ Data from Southern LNG 

Savannah Harbor Expansion Project

Current traffic in the Port of Savannah is typified by a container vessel of approximately 4,614 

TEUs. Many of the container vessels currently calling on the Port of Savannah are already 

considered operationally constrained, meaning the vessels cannot carry full loads at all tides. 

Due to constrained operations, Georgia Port Authority is spearheading a Savannah Harbor 

Expansion Project (SHEP) now undergoing NEPA review by the COE. The SHEP would relieve 

the tidal constraints on commercial vessels and would prepare the Savannah River for the next 

generation of post-Panamax container vessels. Larger vessels associated with the SHEP are 

represented by a container vessel of approximately 7,226 TEUs. 

The SHEP, by deepening the navigable channel, would increase the time each day during which 

commercial vessels can get underway while complying with the under-keel clearance guidelines 

set by the Savannah River Pilots and acknowledged by the Coast Guard. Both the SHEP and the 

Terminal Expansion Project can proceed fully independent of each other. The stretch of river 

from Elba Island downstream to the sea buoy already is deep enough for current and projected 

LNG vessels to get underway and meet the under-keel clearance guidelines throughout the entire 

tide cycle. However, by relieving the tide constraints on other commercial vessels with deeper 

drafts and those traveling farther upstream to the Port of Savannah, the SHEP would reduce the 

opportunities for commercial vessels to delay each other. 

Impacts on Commercial Shipping

While moored at the Elba Island LNG Terminal, LNG vessels do not affect other commercial 

vessels, since having LNG vessels moored in the new marine slip avoids the need for other 

commercial vessels to obtain tug escorts past Elba Island. The only physical restriction on 

commercial vessels operating near the Terminal while LNG vessels are moored is to limit the 

speed to “bare steerage way.” This limit, if continued following the Terminal Expansion Project, 

should not itself cause LNG operations to impact commercial vessels. “Bare steerage way” 

clarified a pre-existing limit of “minimum safe speed” from the Marine Safety Information 

Bulletin issued on December 20, 2005. Existing safety/exclusion zones surrounding the LNG 

vessels while they are underway were established in 2004 and consist of a minimum two-mile 
 4-141 4.0 – Environmental Impact Analysis 

distance from other commercial traffic. The zone moves with the LNG vessel while transiting 

the Savannah River. There is no evidence to date of the zones causing significant delays. 

A discrete-event stochastic simulation model of shipping in the Port of Savannah was used to 

assess delays associated with vessel traffic now and in the future. The model showed that in 

2005, approximately 3.5 percent of the total delays to non-LNG vessels were caused by LNG 

vessels, half of the delays were caused by the adverse effect of ocean tides on vessel movement 

in the river, and the remaining delays were attributable to adverse weather, non-LNG vessel 

movement conflicts, or waiting for a berth to become available. In percentage terms, the current 

cost of delays caused by LNG vessels represents less than one percent of the total cost of delays 

to non-LNG vessels. In the future, assuming LNG received at Elba Island is 100 percent of 

expected contract volumes, the model shows that the percentage of delay cost attributable to 

LNG vessels would increase to approximately 2.5 percent in 2011, but return in 2012 to around 

one percent after the assumed completion of the harbor deepening project. After 2012, assuming 

LNG received is 100 percent of contract volumes, the model shows the percentage increases to 

approximately 2.75 percent in 2015. Each year the percentage of delay cost caused by LNG 

vessels is significantly less than the percentage of total traffic represented by LNG vessels, 

which is only about six percent. 

In terms of dollars, the simulation model showed that total costs of delays caused by inbound 

LNG vessels in 2005 were around $165,000 and by outbound LNG vessels around $22,500. The 

total costs of delays to non-LNG vessels (all causes) in 2006 are around $12 million. Of these 

costs, about $75,000-$150,000 (depending on the percentage of contract volumes delivered to 

Elba Island) are direct results of LNG vessels in 2006. The costs of delays to non-LNG vessels 

caused by LNG vessels go up to at most $375,000 in 2011 under the scenario with 100 percent 

contract volumes and with the existing outbound Regulated Navigation Area (RNA) Rule 

continued. Costs in 2012 are expected to drop considerably, due to the effect of the harbor 

deepening project. After 2012, costs are expected to slowly rise again, because of an increasing 

number of LNG and non-LNG vessels. 

One intended purpose of the simulation model is to evaluate and predict the impact or benefit of 

modifications to the Coast Guard RNA. At present, the local Coast Guard COTP has proposed 

to discontinue the RNA Outbound Rule for unloaded LNG vessels (i.e., vessels carrying less 

than 5 percent of LNG). This modification was evaluated as a part of this report and is predicted 

to result in a reduction of the delay costs caused by outbound LNG vessels by up to $65,000 per 

year in 2015. 

We note that the referenced simulation model analysis discussed above likely provides an 

overestimation of the delays and costs of delays caused by LNG vessels because it cannot make 

intuitive human-like decisions to anticipate and prevent shipping conflicts. In practice, the pilots 

and Coast Guard routinely work to coordinate shipping activities between LNG and other 

commercial vessels to reduce delays. In addition, the shipping model does not take into account 

that the Terminal is highly unlikely to receive 100 percent of its contracted LNG volume each 

year due to weather and market forces, and thus the model overestimates total deliveries. 
 4-142 4.0 – Environmental Impact Analysis 

Based on the lack of traffic issues experienced today at the existing Terminal, and the simulation 

model results predicted above, we do not foresee the additional 95 LNG vessels per year causing 

a significant marine traffic or navigational issue in the Port of Savannah. 

Waterway for LNG Marine Traffic

The socioeconomic impacts of normal operations of the LNG vessels are detailed above in the 

subsection, Impacts on Commercial Shipping. While the likelihood of an emergency leading to a 

marine LNG spill is very low, potential hazards (as described in section 4.12.4.3) are considered 

in this EIS. Without proper safety measures and mitigation, there is a potential for significant 

socioeconomic impacts from an ignited or unignited LNG spill depending on the location, 

severity, and the time of year the incident occurred. However, marine transit safety and security 

mitigation measures committed to in Section 4.12.4.5 render socioeconomic impacts to a level 

comparable with the level of impacts associated with existing LNG vessel operation/transit. In 

all likelihood, ship traffic would be halted until the affected LNG vessel could be safely removed 

from the river channel. The time and cost associated with removing an LNG vessel would be 

substantially the same as that required to remove any other similarly incapacitated large vessel 

from the channel. The complexity and costs of removal would vary greatly depending on the 

location of the vessel when damaged and the extent to which it is damaged. 

Because of its physical properties, released LNG would quickly disperse in the atmosphere or, if 

ignited, burn in a pool fire. A substantial unignited LNG release and dispersion would be a 

short-lived event and may result in a temporary closure of the port. Based on information from 

the University of Georgia’s The Economic Impact of Georgia’s Deepwater Ports on Georgia’s 

Economy, the associated cost could be up to $50 million and would consist primarily of the cost 

to transport and repair the LNG vessel. A substantial release of LNG with ignition resulting in a 

pool fire may cost more than $650 million as a result of severe damage to the shore-side 

facilities, potential total loss of the LNG vessel and cargo, fatalities, and closure of the port for 

up to 14 days. Any substantial release of LNG would require the response of local and state 

emergency responders – police, fire, and medical personnel, which would put a financial burden 

on those agencies. To address any potential financial impacts to those agencies from emergency 

response, the FERC, under Section 3A(e) of the NGA, requires an applicant to include a CostSharing Plan in the Emergency Response Plan that contains a description of any direct cost 

reimbursements to these agencies. (See section 4.12.5, Emergency Response and Evacuation 

Planning.) 

Elba Express Pipeline

Because construction would move sequentially along the pipeline route, any transportation 

impacts would be temporary on any given roadway, and the transportation system would be 

minimally impacted by construction. An increased number of vehicles would be encountered 

during morning and evening peak times, corresponding to normal workday hours. 

Where the pipeline route crosses major roadways, the pipeline would be installed by boring 

underneath the roadways. Crossing of minor roadways and dirt roadways would usually be 

performed by open trenching which may cause minor disruptions in local traffic patterns. 
 4-143 4.0 – Environmental Impact Analysis 

Access across these minor roadways and dirt roadways would be maintained for emergency 

vehicles and passenger vehicles through the use of metal plates and other measures. Appropriate 

control measures would be used during construction, such as detouring of traffic where possible, 

flagmen, signage, and flashing lights. All roadways would be repaired to their preconstruction 

condition when installation of the pipeline is completed in those areas. We note that EEC must 

prepare and file information with counties and other appropriate agencies for permitting the 

installation of the pipeline under roads. 

An increase in traffic is expected from commuter (both local and non-local workers) traffic and 

from the transportation of equipment and materials for the Elba Express Pipeline. Because of the 

general nature linear natural gas pipeline construction, the location of worksites would migrate 

along the 187.9-mile pipeline throughout the construction process. Construction materials 

moved to and from the worksites along the route generally would be transported first to 

predetermined staging and storage areas near the route and then dispatched from those areas on 

an as-needed-basis to the worksites. The initial staging, which would involve transporting the 

bulk of the construction equipment and materials to the respective staging and storage areas, and 

the daily transportation of additional equipment and materials, may temporarily affect local 

transportation systems. To minimize the effect, major highways would be used as much as 

possible to transport slow-moving, heavy construction equipment to the staging and storage 

areas. The specific travel routes utilized to transport work materials from the staging areas to the 

worksites generally would follow the shortest accessible public or private roads near the pipeline 

ROW. 

As construction progresses, much of the equipment movement would occur along the 

construction ROW. When it is necessary for construction equipment and material to cross 

roadways, traffic flow may be interrupted. The transportation of equipment and materials would 

be minimized through planning and coordination. For example, the scheduling of heavy loads 

and delivery of materials would be coordinated so that it would not conflict with commuting 

hours. 

Operation and maintenance of the pipeline facilities would not significantly affect traffic flow on 

any of the paved roads or highways. Periodic maintenance and inspection procedures would be 

required and involve a low frequency of light vehicle movement on and off roadways. Because 

these occasions would be infrequent, no additional impact is expected. 

In summary, no significant long-term impact of the transportation infrastructure is anticipated. 

Temporary and minor disruptions of traffic flow and pattern are expected to result from pipeline 

facility construction. 

4.9.7 Environmental Justice 

Terminal Expansion

Executive Order 12898 on Environmental Justice requires that each federal agency address 

disproportionately high and adverse human health or environmental impacts of its programs, 

policies, and activities on minority and low-income populations. Federal agencies’ 
 4-144 4.0 – Environmental Impact Analysis 

responsibilities under this Order also apply equally to Native American programs. Table 4.9-7 

presents the general ethnic mix and economic status in the Project Area. 

The Terminal Expansion site in Chatham County has a minority population of 45.8 percent, 

which is somewhat higher than the state average of 37.4 percent. The county also shows 11.8 

percent persons living below the poverty level, which is only slightly higher than the state 

average of 9.9 percent. The Terminal Expansion Project would be located on the existing 

Terminal site on Elba Island, Georgia, which is owned entirely by Southern LNG and has no 

resident population. Therefore, we conclude implementation of the Terminal Expansion Project 

would not result in any disproportionately high or adverse environmental and human health 

impacts to low-income and minority populations. 

Zones of Concern

To address concerns about the potential for minority and low-income populations within the 

Zones of Concern, census track data for these areas were reviewed. As figure 4.9-1 shows, the 

census tracks extend well beyond Zone 3, making it impossible to determine with any accuracy 

the numbers of these populations specifically within the Zones of Concern. The figure shows 

that the majority of residential development is on Tybee Island in census tract 111.03. Skirting 

the edge of Zone 3 west of Tybee Island are other residential areas. The largest development is 

located at the western end of Zone 3 in census tract 101.01 and consists of two existing industrial 

facilities with over 300 employees combined. 

However, because the proposed project would only increase the number of offloading vessels 

and storage capacity at the Terminal, and under No-Action Alternative current operations would 

continue, there would not be a significant change from an operational standpoint, and therefore 

no change to the current effects on low-income and minority populations. 

Waterway for LNG Marine Traffic

It is important to consider the population that could potentially be exposed to the effects of a 

substantial marine LNG release. Cockspur Island, located within Zone 1 (described in section 

4.12.4.3), does not have a resident population. The island does, however, house three nonresidential structures: a Coast Guard Station; the Savannah River Pilot Boat Dock Facility; and 

the Fort Pulaski National Monument, a National Park Service site that hosts an average of 900 

visitors a day. Within Zones 2 and 3, the majority of the land along the LNG marine transit route 

is largely undeveloped and unpopulated, consisting of wetlands, bare lands, grasslands and 

forests. 

Two populated areas that are partially in Zones 2 and 3 (see figure 4.12-2) are Tybee and TalahiWilmington Islands. According to the 2000 Census, Tybee Island City, a beach community and 

tourist attraction located at the northeast end of the island, has a year round population of 3,392, 
TABLE 4.9-7 

A Comparison of Racial/Ethnic Mix and Income Statistics Within the 

Project Area a/, b/, c/ 

County 

Total 

Minority White 

Black or 

African 

American 

Native 

American 

Hispanic 

or Latino 

of any 

Race Asian 

Native 

Hawaiian 

and 

Other 

Pacific 

Islander 

Other 

race 

Two or 

more races 

White 

alone, not 

Hispanic 

H

Georgia CountiesChatham 45.8% 55.3% 40.5% 0.2% 2.3% 1.7% 0.1% 0.9% 1.3% 54.2% Effingham 16.1% 84.7% 13.0% 0.3% 1.4% 0.5% 0.0% 0.5% 1.0% 83.9% Screven 46.8% 53.6% 45.3% 0.1% 1.0% 0.3% 0.1% 0.2% 0.5% 53.2% Jenkins 44.4% 56.3% 40.5% 0.2% 3.3% 0.2% 0.1% 2.1% 0.7% 55.6% Burke 53.5% 46.9% 51.0% 0.2% 1.4% 0.3% 0.0% 0.6% 1.0% 46.5% Jefferson 58.2% 42.1% 56.3% 0.1% 1.5% 0.2% 0.0% 0.8% 0.5% 41.8% Glascock 9.7% 90.6% 8.3% 0.2% 0.5% 0.0% 0.0% 0.1% 0.7% 90.3% Warren 60.8% 39.5% 59.5% 0.2% 0.8% 0.1% 0.0% 0.3% 0.5% 39.2% McDuffie 39.7% 60.8% 37.5% 0.2% 1.3% 0.3% 0.0% 0.3% 0.8% 60.3% Wilkes 46.1% 55.1% 43.1% 0.2% 2.0% 0.2% 0.0% 0.5% 0.9% 53.9% Elbert 34.2% 66.9% 30.9% 0.2% 2.4% 0.2% 0.0% 1.1% 0.7% 65.8% Hart 21.4% 79.1% 19.4% 0.2% 0.9% 0.5% 0.0% 0.2% 0.6% 78.6% Project Average 39.7% 60.9% 37.1% 0.2% 1.6% 0.4% 0.0% 0.6% 0.8% 60.3% State Average 37.4% 65.1% 28.7% 0.3% 5.3% 2.1% 0.1% 2.4% 1.4% 62.6% South Carolina CountiesAnderson 19.1% 81.6% 16.6% 0.2% 1.1% 0.4% 0.0% 0.4% 0.8% 80.9% State Average 33.9% 67.2% 29.5% 0.3% 2.4% 0.9% 0.0% 1.0% 2.4% 66.1% ____________________________________________________________________ a/ All information was provided by the U.S. Census Bureau – Census 2000 Summary (www.census.gov), the latest information available as of April 20b/ Percent Total Minorities was calculated by taking the percent white alone, not Hispanic and subtracting it from 100 percent. c/ Census data on individual minority percentages of the total population plus the white percentage do not add up to 100 percent as Hispanic category 

4-145 4.0 – Environmental ImpactAnalysis
Non-Internet Public 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED ELBA III PROJECT 

Docket Nos. CP06-470-000, CP06-471-000, CP06-472-000, 

CP06-473-000, and CP06-474-000 

Page 4-146 

Figure 4.9-1 

Census Tract Location within Zones of Concern 1, 2 and 3 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 
 4-147 4.0 – Environmental Impact Analysis 

 but the island itself is considered to be a medium population density area (between 1,000-9,000 

people per square mile). During the summer, Tybee Island hosts a tourist population of up to 

9,000. Similarly, Talahi and Wilmington Islands, with a combined resident population of 

14,213, is also considered a medium population density area. The highest population densities 

within Savannah are located beyond Zone 3 at a distance greater than 3,500 meters 

(approximately 2.2 miles) from the Terminal location and the LNG marine transit route. 

Socioeconomic impacts of a substantial marine LNG release would not differentiate effects 

based on demographic characteristics of the population. Therefore, there would not be any 

disproportionately high or adverse environmental and human health impacts to low-income and 

minority populations. The severity of impacts on populations within Zones 1-3 would depend on 

the location of the incident relative to the population, the scope of the incident, and whether the 

LNG released ignited or evaporated. This could be a significant impact, with injuries ranging 

from mild to fatal, being most severe in Zone 1 and decreasing outward through Zones 2 and 3. 

However, because of the implementation of safety and security measures during marine transit 

(See section 4.12, Reliability and Safety), the likelyhood of a marine LNG spill is extremely 

remote and significant socioeconomic impacts are not expected. 

Elba Express Pipeline

Table 4.9-7 presents the general ethnic mix and economic status by county and state affected by 

the Elba Express Pipeline facilities. In Georgia, nine of the 12 counties through which the 

pipeline passes have minority populations higher than the state average of 37.4 percent. These 

minority populations range from 39.7 percent in McDuffie County to 60.8 percent in Warren 

County. Similarly, 10 of the 12 counties have a percentage of individuals below the poverty 

level greater than the state average of 9.9. These low income populations range from 11.8 

percent in Chatham County to 24.1 in Warren County. In South Carolina, both the percentage of 

minority and low income populations in Anderson County were below the state averages. 

To further assess the potential for impact on areas of minorities and low income populations, the 

information on percent minorities and poverty rates was evaluated using a smaller geographic 

unit (i.e. census tract). This further analysis was focused on the Northern Segment of the 

pipeline (from Elbert County, Georgia to Anderson County, South Carolina), where there is 

currently no other pipeline along the route. This information is shown below in Table 4.9-8. 

Similar to the Georgia county data for the whole pipeline route, 6 of the 11 census tracks showed 

minority populations higher than the state average with percentages ranging from 32.5 in Elbert 

County to 60.8 in Warren County. Nine of the 11 census tracks showed higher than state 

average for the percentage of individuals below the poverty line, ranging from 10.9 in Elbert 

County to 24.1 in Warren County. 

Although percent minorities and poverty rates are well above the state average in some of these 

tracts, the pipeline project once buried would have minimal impact on the environment and 

surrounding population of these areas. Therefore, we conclude that implementation of the Elba 

Express Pipeline would not result in any disproportionately high or adverse environmental and 

human health impacts to low-income an dminority populations. 
TABLE 4.9-8 

Data on Minorities, Income and Poverty Rates for Census Tracts Crossed by the Greenfield Portion of the Pipeline. 

County 

Census 

Tract 

No. 

Total 

Minority 

a/ White 

Black or

African 

American 

Native 

American Asian 

Native 

Hawaiian 

and 

Other 

Pacific 

Islander Other 

Two 

or 

more 

races Hispanic 

White 

alone, 

not 

Hispanic 

M

Hou

In

Elbert, GA 9905 32.5 67.5 30.9 0.2 0.1 0.03 0.07 0.5 2.2 67.5 2Elbert, GA 9902 17.8 82.2 14.8 0.04 0.1 0 2.2 0.5 4.1 82.2 3Glascock, GA 

9901 9.7 90.6 8.3 0.2 0 0 0.2 0.7 0.5 90.3 2

Hart, GA 9605 21.4 79.1 19.4 0.2 0.5 0.004 0.4 0.6 0.9 78.6 3Jefferson, GA 

9601 58.2 42.1 56.3 0.1 0.2 0.006 1.03 0.5 1.5 41.8 2

McDuffie, GA 

9501 7.6 92.4 6.1 0.7 0.04 0.08 0.1 0.5 0.8 92.4 4

McDuffie, GA 

9503 49.3 50.7 47.7 0.3 0.5 0 0.03 0.7 1.5 50.7 3

McDuffie, GA 

9504 39.1 60.9 37.4 0.2 0.5 0.04 0.3 0.7 1.2 60.9 3

Warren, GA 

9704 60.8 39.5 59.5 0.2 0.1 0 0.4 0.5 0.8 39.2 2

Wilkes, GA 9801 36.2 63.8 33.4 0.3 0.2 0 1.2 1.2 3.6 63.8 2Wilkes, GA 9803 49.3 50.7 48.1 0.2 0.3 0.06 0.1 0.7 1.6 50.7 2Anderson, SC 

122 19.1 81.6 16.6 0.2 0.4 0.4 0.6 0.8 1.1 80.9 3

GA State 

Average 37.4 65.1 28.7 0.3 2.1 0.05 2.4 1.4 5.3 62.6 4

SC State 

Average 33.9 67.2 29.5 0.34 0.9 0.04 1.0 1.0 2.4 66.1 3

National Average 30.9 75.1 12.9 0.9 3.6 0.14 5.5 2.4 12.5 69.1 4

___________________________

a/ Percent Total Minorities was calculated by taking the percent white alone, not Hispanic and subtracting it from 100 percent 

b/ Census data on individual minority percentages plus white percentage do not add up to 100% as Hispanic category includes other races

4-148 4.0 – Environmental Impact Analysis
 4-149 4.0 – Environmental Impact Analysis 

4.10 CULTURAL RESOURCES 

Section 106 of the NHPA, as amended, requires the FERC to take into account the effect of its 

undertakings (including issuance of a certificate) on properties listed, or eligible for listing, on 

the NRHP and to afford the ACHP an opportunity to comment on the undertaking. Southern 

LNG and EEC, as non-federal parties, are assisting the FERC in meeting its obligations under 

Section 106 and the implementing regulations in 36 CFR 800 by preparing the necessary 

information, analyses, and recommendations. 

Construction and operation of the proposed expansion facilities could potentially affect historic 

properties (i.e., cultural resources listed on or eligible for listing on the NRHP). These could 

include prehistoric or historic archaeological sites, districts, buildings, structures, and objects, 

and locations with traditional value to Native Americans or other groups. Such properties 

generally must possess integrity of location, design, setting, materials, workmanship, feeling, and 

association, and must meet one or more of the criteria specified in Title 36 CFR 60.4. 

4.10.1 Cultural Resource Surveys 

Terminal Expansion

Southern LNG completed a cultural resources survey (both archaeological and architectural) of 

the proposed Terminal Expansion site. A 106-acre parcel was studied. The remaining areas to 

be disturbed by the expansion construction activities, as well as the turning basin, had been 

previously surveyed with no historic properties identified. The report resulting from the current 

survey was provided to the FERC and the Georgia State Historic Preservation Office (SHPO) 

(Lackowicz 2006). The report also summarized the results of previous surveys at the Terminal 

site (Kraus et al. 2002, 2003; Pelletier et al. 2001). Of the 106 acres studied, 74 acres consisted 

of existing plant facilities and were found to be previously disturbed. The remaining 32 acres 

were examined for cultural resources through pedestrian survey and 35 backhoe trenches. No 

cultural resources were identified. In a letter dated May 25, 2006, the Georgia SHPO concurred 

that the proposed undertaking would have “no effect on archaeological or historic resources 

eligible for inclusion in the NRHP.” We also concur. 

Elba Express Pipeline

In Georgia, EEC conducted a Phase I cultural resources survey, which included both 

archaeological and historic architectural resources (Eberwine et al. 2006). The report resulting 

from this survey was provided to the FERC, the Georgia SHPO, and the COE. A 300-foot-wide 

corridor was examined for the pipelines. For those areas where the proposed pipeline would 

parallel an existing pipeline ROW, the survey corridor was 100 feet wide east of the proposed 

centerline, and 200 feet west of the proposed centerline. For greenfield areas of the proposed 

pipeline, the survey corridor was 150 feet on either side of the proposed centerline. In addition, a 

compressor station site, meter station sites, contractor yards, pipe storage yards, rail sidings, and 

numerous access roads and extra work spaces were also surveyed. Approximately 6.8 miles of 

the pipeline ROW, six access roads, and numerous extra work spaces have not been surveyed 

due to denied access. 
 4-150 4.0 – Environmental Impact Analysis 

A total of 295 cultural resources were identified in Georgia, including 152 archaeological sites, 

110 archaeological non-site loci, 28 architectural resources, and five cemeteries. Eleven of these 

archaeological sites, one historic structure, and three non-site loci were identified on COE 

property, with the survey conducted under ARPA Permit No. DACW21-4-07-5203 (of these 

resources, only one, archaeological site 9BK144, was recommended as potentially eligible for 

the NRHP). In all, six archaeological sites have been recommended as potentially eligible for 

the NRHP. The sites consist of five prehistoric artifact scatters (9SN223, 9BK435, 9BK444, 

9JF329, and 9EB739), and one scatter of prehistoric and historic artifacts (9BK144). Avoidance 

or further work has been recommended to evaluate the NRHP eligibility of these six sites. An 

additional eight sites have not been assessed for their NRHP eligibility and would be avoided. 

The five cemeteries identified (9JF332, 9GL15, 9MF931, 9WS365, and 9EB748) would be 

avoided during construction; those that are within the proposed construction corridor would be 

fenced to ensure avoidance. In a letter dated December 22, 2006, the Georgia SHPO agreed with 

these recommendations for archaeological sites, non-site loci, and cemeteries, and requested 

additional information for ten historic structures. In a letter dated February 23, 2007, the SHPO 

agreed that historic structures JE-0505-01, CMC-001-03, and CMC-001-04 were eligible for the 

NRHP, and in addition, historic structures CMC-001-01, and CMC-001-02 were also eligible for 

the NRHP. In its January 10, 2007 comments, the COE agreed with the recommendations for 

the eleven archaeological sites and three non-site loci on COE property, and requested additional 

information regarding the historic structure on COE property. EEC has provided this 

information. 

EEC submitted a supplemental report for Georgia for the Savannah River crossing reroute, two 

access roads, two extra work spaces, and the Transco Zone 4 meter station. As a result of this 

survey, only one archaeological non-site loci was identified and recommended as not eligible for 

the NRHP. In a letter dated April 19, 2007, the SHPO indicated that “no archaeological or 

historic resources...will be affected...”. EEC submitted an additional supplemental report for a 

denied access segment, five access roads, two realignments, and one extra work space, and 

included an assessment for site 9EB729 and the additional information requested (noted above) 

by the SHPO for ten historic structures. Two archaeological sites, two non-site loci, and one 

historic structure were identified. None of the archaeological resources, including 9EB729, were 

recommended as eligible for the NRHP. The historic structure, along an access road, would be 

avoided. In a letter dated June 29, 2007, the SHPO concurred wit these conclusions. We also 

concur. 

In South Carolina, EEC completed a Phase I cultural resources survey (both archaeological and 

architectural) for its originally proposed route. The report resulting from the survey was 

provided to the FERC and the South Carolina SHPO. The survey corridor was 300 feet wide, 

and included a 150-foot area on either side of the centerline. Two cultural resources were 

identified in the South Carolina portion of the pipeline: one previously recorded site that was not 

relocated, and one new historic archaeological site defined during the survey, which was 

recommended as not eligible for the NRHP. In a letter dated December 28, 2006, the South 

Carolina SHPO concurred that the proposed undertaking would have “no effect on historic 

properties.” 
 4-151 4.0 – Environmental Impact Analysis 

EEC submitted a supplemental report for South Carolina for the Savannah River crossing 

reroute, two access roads, and the Transco Zone 5/Plant Rainey meter station, thus completing 

surveys in South Carolina of all project components identified to date. As a result of this survey, 

only one archaeological site was identified and recommended as not eligible for the NRHP. In a 

letter dated May 11, 2007, the SHPO indicated that “there will be no effect to historic properties 

by the proposed project.” We agree. 

Waterway for LNG Marine Traffic

A records search identified 18 previously recorded archaeological sites situated along the 

Savannah River shoreline within 1,600 meters of Elba Island. In addition, three historic 

properties listed on the NRHP (Fort Pulaski National Monument, Fort Screven Historic District, 

and Tybee Island Lighthouse) and eight shipwrecks (five of these offshore) were identified up to 

3,500 meters from the waterway centerline. Of the 18 archaeological sites, 12 have been 

assessed as not eligible for the NRHP, three have not been assessed, two are potentially eligible, 

and one has been mitigated through Phase III excavations. Of the eight shipwrecks, two were 

considered potentially eligible for the NRHP, with the remainder not assessed. 

No significant impact on cultural resources (archaeological sites or historic structures) is 

expected as a result of routine LNG and support vessel transit. The Lower Savannah River 

already experiences a high volume of vessel traffic, and wave induced erosion resulting from 

increased vessel traffic is expected to be minimal. Similarly, no significant impact on cultural 

resources is expected as a result of an unignited release of LNG, since LNG is less dense than 

water and would vaporize upon contact with water and air. 

A portion of Fort Pulaski National Monument is located in Zone 1. The Fort Screven Historic 

District and Tybee Island Lighthouse are both located within Zone 2 (see figure 4.12-1). 

Potential significant impact on these historic aboveground properties may occur from an ignited 

release of LNG, depending on the scope of the incident and their proximity to the incident 

location. However, marine transit safety and security mitigation measures committed to in 

section 4.12.4, greatly reduce the likelihood of an ignited LNG release from a transiting LNG 

vessel and, thus, minimize impacts on cultural resources to a level of insignificance. No 

significant impacts on submerged cultural resources in the Zones of Concern or offshore cultural 

resources are expected as a result of routine LNG and support vessel transit, unignited release of 

LNG, or an ignited release of LNG because of the submerged nature of the resources. 

No concerns have been expressed regarding tribal fishing rights from any of the Native 

American groups contacted. 

4.10.2 Unanticipated Discoveries Plan 

Terminal Expansion

Southern LNG submitted a Plan for the Unexpected Discovery of Cultural Resources and 

Human Remains to be used in the event that any unanticipated historic properties or human 

remains are encountered during construction of the proposed Terminal Expansion Project. We 
 4-152 4.0 – Environmental Impact Analysis 

requested revisions to the plan. Southern LNG has provided a revised plan which we find 

acceptable. 

Elba Express Pipeline

EEC submitted a Plan for the Unexpected Discovery of Cultural Resources and Human Remains

to be used in the event that any unanticipated historic properties or human remains are 

encountered during construction of the proposed Elba Express Pipeline facilities. We requested 

revisions to the plan. EEC provided a revised plan which the COE commented on. We 

requested that EEC revise the plan in light of the COE’s comments. EEC has provided a revised 

plan to the FERC and the COE. 

4.10.3 Native American Consultation 

Terminal Expansion

Southern LNG contacted the federally-recognized Catawba Indian Nation, Eastern Band of 

Cherokee Indians, Muscogee (Creek) Nation of Oklahoma, and Poarch Creek Indian Tribe, as 

well as the state-recognized Georgia Tribe of Eastern Cherokee, Lower Muscogee Creek Tribe 

and the Cherokee of Georgia Tribal Council (letters dated June 6, 2006) to elicit any concerns 

about the proposed Terminal Expansion Project with regard to potential impacts to traditional 

cultural properties and historic properties. Follow-up letters were submitted to each Native 

American group listed above on September 4, 2006. No responses have been received to date. 

Elba Express Pipeline

EEC contacted the federally recognized Catawba Indian Nation, Eastern Band of Cherokee 

Indians, Muscogee (Creek) Nation of Oklahoma, and Poarch Creek Indian Tribe, as well as the 

state-recognized Georgia Tribe of Eastern Cherokee, Lower Muscogee Creek Tribe and the 

Cherokee of Georgia Tribal Council (letters dated June 6, 2006) to elicit any concerns about the 

proposed Elba Express Pipeline with regard to potential impacts to traditional cultural properties 

and historic properties. Follow-up letters were submitted to each Native American group listed 

above on September 7, 2006. 

The Muscogee (Creek) Nation responded by letter and indicated that the pipeline project area is 

within their aboriginal lands. Although the Muscogee (Creek) Nation was aware of cultural sites 

in the general area, they indicated that they were not aware of any particular site that may be 

impacted by the pipeline project. They also requested to be informed if any cultural resource 

sites are encountered during pipeline construction. The Eastern Band of Cherokee responded in a 

telephone call, stating that the Elba Express Pipeline is anticipated to cross an area of 

significance to the group, and requested contact information so that the information could be 

forwarded directly to EEC. No information has currently been received by EEC from the 

Eastern Band of Cherokee to date, and EEC submitted an additional letter requesting their 

continued input on June 7, 2007. 
 4-153 4.0 – Environmental Impact Analysis 

A letter also was received from the Cherokee of Georgia stating that they had no concerns about 

the pipeline project unless it interferes with American Indian burial sites or artifacts. No other 

responses have been received to date. 

4.10.4 Compliance with the NHPA 

Terminal Expansion

Cultural resources surveys have been completed for the Terminal Expansion Project site, and the 

Georgia SHPO and the FERC agree that no historic properties would be affected. Therefore, 

compliance with Section 106 of the NHPA is complete. 

Elba Express Pipeline

In South Carolina, cultural resources surveys have been completed for all project components 

identified to date, and the South Caroline SHPO and the FERC agree that no historic properties 

would be affected. Therefore, compliance with Section 106 of the NHPA is complete in South 

Carolina. In Georgia, evaluation of sites, and survey of some portions of the project still need to 

be completed. Consequently, we have not completed the process of complying with Section 106 

of the NHPA. When the surveys and evaluations are completed and comments addressed, the 

FERC, in consultation with the Georgia SHPO and the COE, as appropriate, will determine 

whether construction of the Elba Express Pipeline project would affect any properties listed, or 

eligible for listing, on the NRHP. If a property would be adversely affected, mitigation would be 

proposed. 

To ensure that the FERC’s responsibilities under the NHPA and its implementing regulations are 

met, we recommend that EEC defer construction of the pipeline, compressor station, meter 

stations, and establishment and use of all staging, storage, and temporary work areas and 

new or to-be-improved access roads until: 

a. EEC files a cultural resources survey report for the denied access areas, and 

any additional or newly identified areas requiring survey, evaluation report(s), 

any required avoidance or treatment plan(s), and the Georgia SHPO’s 

comments and any COE comments, as appropriate, on the reports and any 

plan(s); and 

b. the Director of OEP reviews all cultural resources survey and evaluation 

reports and plans and notifies EEC in writing that construction may proceed. 

All material filed with the Commission containing location, character, and ownership

information about cultural resources must have the cover and any relevant pages therein 

clearly labeled in bold lettering: “CONTAINS PRIVILEGED INFORMATION--DO NOT 

RELEASE.” 
 4-154 4.0 – Environmental Impact Analysis 

4.11 AIR QUALITY AND NOISE 

4.11.1 Air Quality 

4.11.1.1 Regional Climate 

The State of Georgia has a humid, subtropical climate, with long, hot summers and short, mild 

winters. The average temperatures range from 46.8 degrees Fahrenheit (oF) in January to 80.0°F 

in July. The coldest month is January when the daily mean maximum and minimum 

temperatures are 60.3 F and 38.3 F, respectively. July is the warmest month with the daily mean 

maximum and minimum temperatures of 91.6°F and 72.2°F, respectively. The average annual 

temperature is 66.4 oF. The average annual rainfall is 50.18 inches. July has the highest average 

monthly rainfall at 5.64 inches. For Savannah the annual prevailing wind direction is West at a 

mean wind speed of 8 miles per hour (mph) and a peak gust of 68 mph (NOAA, 1998). The 

region typically receives 49.58 inches of annual precipitation (water equivalent), including a 

typical annual snowfall of 0.6 inches. The precipitation is generally well distributed throughout 

the year with winter being the driest season and late summer receiving the most rainfall. 

4.11.1.2 Existing Air Quality 

Ambient Air Quality Standards 

The EPA has established National Ambient Air Quality Standards (NAAQS) for criteria 

pollutants for the purpose of protecting human health (primary standards) and public welfare 

(secondary standards). The EPA set NAAQS for the following air contaminants designated 

“criteria pollutants”: nitrogen dioxide (NO2), carbon monoxide (CO), ozone (O3), SO2, lead 

(Pb), particulate matter with an aerodynamic diameter less than or equal to 10 microns (PM10), 

and particulate matter with an aerodynamic diameter less than or equal to 2.5 microns (PM2.5). 

As of June 15, 2005 the 1-hour O3 standard was revoked in all but 14 Early Action Compact 

(EAC) Areas and replaced by the new 8-hour O3 standard. Revisions to the particulate matter 

standards, affecting both PM10 and PM2.5 were approved by the Administrator of the EPA on 

October 10, 2006. These revised standards which became effective December 18, 2006 include; 

a reduction in the PM2.5 24-hour standard from 65 to 35 μg/m3

, retention of the PM2.5 annual and 

PM10 24-hour standards and revocation of the PM10 annual standard. The secondary standards 

were revised to match the primary standards. In addition, the form of the PM2.5 annual standard 

was revised in regard to the criteria for spatial averaging. 

The State of Georgia has essentially adopted the NAAQS as state standards. However, the 

recent changes to the particulate matter standards have yet to be incorporated in state regulations. 

Air Quality Control Regions and Attainment Status

Air quality control regions (AQCR) are areas established for air quality planning purposes in 

which implementation plans describe how ambient air quality standards will be achieved and 
 4-155 4.0 – Environmental Impact Analysis 

maintained. The existing terminal is located in Chatham County part of the Savannah (Georgia)-

Beaufort (South Carolina) Interstate Air Quality Control Region. The proposed compressor 

station would be located in Jenkins County, part of the Augusta (Georgia)-Aiken (South 

Carolina) Interstate Air Quality Control Region. 

AQCRs were established by the EPA and local agencies, in accordance with Section 107 of the 

CAA, as a means to implement the CAA and comply with the NAAQS through state 

implementation plans. The AQCRs are intra- and interstate regions such as large metropolitan 

areas where improvement of the air quality in one portion of the AQCR requires emission 

reductions throughout the AQCR. Each AQCR, or portion thereof, is designated based on 

compliance with the NAAQS. AQCR designations fall under three categories as follows: 

“attainment” (areas in compliance with the NAAQS); “nonattainment” (areas not in compliance 

with the NAAQS); or “unclassifiable”. The existing terminal is located near Savannah, Georgia 

in Chatham County, an attainment area for all criteria pollutants. The Elba Express Pipeline 

facilities would be located in twelve Georgia counties and one South Carolina county, and the 

proposed Elba Express Compressor Station would be located in Jenkins County, Georgia, which 

are all attainment areas for all criteria pollutants except Anderson County, SC. EPA has 

classified Anderson County as non-attainment for the 8-hour O3 standard for which NOx and CO 

are precursors. However, because Anderson County has entered into the EAC, its effective date 

of non-attainment designation is deferred until April 15, 2008. The EAC process requires each 

area involved to reduce ground-level O3 pollution earlier than the CAA requires. 

General Conformity

40 CFR 51 and 93 define the requirements for determining conformity for federal actions to state 

or federal implementation plans. A conformity analysis is required for each criteria pollutant 

where the total of direct and indirect emissions in a nonattainment or maintenance area caused by 

a federal action would equal or exceed any of the rates specified in the applicable 

implementation plan. As mentioned previously, Anderson County’s nonattainment designation 

has been deferred until April 15, 2008. The length of the proposed pipeline in Anderson County 

would consist of less than one mile and construction emissions within the county would be 

minimal. Given this limited scope we do not believe that general conformity would apply if the 

county is designated as nonattainment before the project commences. Therefore, the general 

conformity requirements do not apply to the proposed Project. 

Air Quality Monitoring and Existing Air Quality

Air quality monitors are located throughout the state and region for a variety of purposes. The 

monitoring site nearest the project area that measures O3, SO2, Pb, PM2.5, and PM10 is in 

Savannah, Georgia. The nearest monitoring locations for CO are in Atlanta, Decatur and 

Clarkston, Georgia. The nearest monitoring locations for NO2 are in Atlanta, Decatur, Tucker 

and Conyers, Georgia. The available monitoring data from 2002 through 2006 are summarized in 

table 4.11.1-1 along with the standards established under the NAAQS. The values reported are 

the maximum monitored concentration for the 5-year period reviewed. 

As indicated previously and demonstrated by the local monitoring data, areas within the State of 
 4-156 4.0 – Environmental Impact Analysis 

Georgia that could be influenced by the proposed project are classified as attainment for all 

criteria pollutants. The measured O3 8-hour concentration above the current standard was 

TABLE 4.11.1-1 

National Ambient Air Quality Standards 

Pollutant Primary 

Standard Averaging Times Secondary 

Standard 

5-Year 

Maximum 

Monitoring Station 

Number/ Location 

9 ppm 

(10 mg/m3

) 

8-hour a/ None 3.7 ppm 130891002 / 

Clarkston, GA 

Carbon Monoxide 

35 ppm 

(40 mg/m3

) 

1-hour a/ None 10.8 ppm 130890002 / 

Decatur, GA 

Lead 1.5 μg/m3 Quarterly Average Same as Primary 0.00 μg/m3 130510021 / 

Savannah, GA 

Nitrogen Dioxide 0.053 ppm 

(100 μg/m3

) 

Annual (Arithmetic Mean) Same as Primary 0.019 ppm 131210048 / 

Atlanta, GA 

Particulate Matter (PM10) Revoked b/ Annual b/ (Arith. Mean) N/A N/A 

150 μg/m3

 24-hour c/ Same as Primary 76 μg/m3 130510014 / 

Savannah, GA 

15.0 μg/m3 Annual d/ (Arith. Mean) Same as Primary 15 μg/m3 130510017 / 

Savannah, GA 

Particulate Matter 

(PM2.5) 

35 μg/m3

 24-hour e/ Same as Primary 31μg/m3 130510091 / 

Savannah, GA 

0.08 ppm 8-hour f/ Same as Primary 0.086 ppm 130510021 / 

Savannah, GA 

Ozone 

0.12 ppm 1-hour g/ 

(Applies only in limited 

areas) 

Same as Primary 0.095 ppm 130510021 / 

Savannah, GA 

0.03 ppm 

(80 μg/m3

) 

Annual (Arith. Mean) ------- 0.005 ppm 130511002 / 

Savannah, GA 

0.14 ppm 

(365 μg/m3

) 

24-hour a/ ------- 0.048 ppm 130511002 / 

Savannah, GA 

Sulfur Oxides 

------- 3-hour a/ 0.5 ppm 

(1300 μg/m3

) 

0.099 ppm 130511002 / 

Savannah, GA 

____________________________________________________________________ 

a/ Not to be exceeded more than once per year. 

b/) Due to a lack of evidence linking health problems to long-term exposure to coarse particle pollution, the agency revoked the 

annual PM10 standard in 2006 (effective December 17, 2006). 

c/ Not to be exceeded more than once per year on average over 3 years. 

d/ To attain this standard, the 3-year average of the weighted annual mean PM2.5 concentrations from single or multiple 

community-oriented monitors must not exceed 15.0 μg/m3

. 

e/ To attain this standard, the 3-year average of the 98th percentile of 24-hour concentrations at each population-oriented monitor 

within an area must not exceed 35 μg/m3

 (effective December 17, 2006). 

f/ To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone concentrations 

measured at each monitor within an area over each year must not exceed 0.08 ppm. 

g/ (a) The standard is attained when the expected number of days per calendar year with maximum hourly average concentrations 

above 0.12 ppm is < 1, as determined by appendix H. 

(b) As of June 15, 2005 EPA revoked the 1-hour ozone standard in all areas except the fourteen 8-hour ozone non-attainment 

Early Action Compact (EAC) Areas. 

reported in 2002 prior to standard taking effect. From 2002 through 2006 there were no reported 

8-hour O3 exceedances. The nearest monitors for CO are located in Atlanta, Decatur and 

Clarkston Georgia. Data from 2002 to 2006 was reviewed for all CO monitoring stations and the 

highest 5-year value was reported. The nearest monitors for NO2 are located in Atlanta, Decatur, 

Tucker and Conyers, Georgia. Data from 2002 to 2006 was reviewed for all NO2 monitoring 

stations and the highest 5-year value was reported. 
 4-157 4.0 – Environmental Impact Analysis 

4.11.1.3 Existing Facility Emissions 

Terminal Expansion

Table 4.11.1-2 lists the air emission sources currently permitted to operate at the Elba Terminal. 

Table 4.11.1-3 summarizes approximate potential-to-emit (PTE) for each source group. The 

emissions indirectly associated with operation of the existing terminal are summarized in table 

4.11.1-4. 

TABLE 4.11.1-2 

Summary of Air Emissions Equipment 

Equipment Manufacturer Model Rated Capacity (ISO) Site Rating 

LNG Vaporizer T-Thermal Sub-X 90-135 88.1 MMBtu/hr 88.1 MMBtu/hr 

LNG Vaporizer T-Thermal Sub-X 90-135 88.1 MMBtu/hr 88.1 MMBtu/hr 

LNG Vaporizer T-Thermal Sub-X 90-135 88.1 MMBtu/hr 88.1 MMBtu/hr 

LNG Vaporizer T-Thermal Sub-X 90-135 88.1 MMBtu/hr 88.1 MMBtu/hr 

LNG Vaporizer T-Thermal Sub-X 90-135 88.1 MMBtu/hr 88.1 MMBtu/hr 

LNG Vaporizer T-Thermal Sub-X 120-180 121.4 MMBtu/hr 121.4 MMBtu/hr 

LNG Vaporizer T-Thermal Sub-X 120-180 121.4 MMBtu/hr 121.4 MMBtu/hr 

LNG Vaporizer T-Thermal Sub-X 120-180 121.4 MMBtu/hr 121.4 MMBtu/hr 

Reciprocating Engine Generator Cooper-Bessemer LSV-12-SG-4 3,920 hp 3,920 hp 

Reciprocating Engine Generator Cooper-Bessemer LSV-12-SG-4 3,920 hp 3,920 hp 

Gas Turbine Generator Solar Centaur T4000 3,800 hp 3,800 hp 

Gas Turbine Generator Solar Centaur T4000 3,800 hp 3,800 hp 

Fuel Gas Heater NATCO A51998 1.25 MMBtu/hr 1.25 MMBtu/hr 

Fuel Gas Heater NATCO A51998 1.25 MMBtu/hr 1.25 MMBtu/hr 

Heated Vent Stack Heater Johnston N/A 11.74 MMBtu/hr 11.74 MMBtu/hr 

Air Compressor N/A N/A 15 hp 15 hp 

Firewater Pump Engine Cummins N/A 215 hp 215 hp 

Firewater Pump Engine Cummins N/A 700 hp 700 hp 

LNG Vessel Unloading N/A N/A N/A N/A 

TABLE 4.11.1-3 

Summary of Potential Emissions From the Existing Terminal Equipment a/ 

Equipment Group 

NOX

Emissions 

(tpy) 

CO 

Emissions 

(tpy) 

SO2 Emissions

(tpy) 

PM b/ 

Emissions 

(tpy) 

VOC 

Emissions 

(tpy) 

Existing Equipment 

Elba I LNG Vaporizers 220 316 1 4 19 

Elba II LNG Vaporizers 128 262 1 3 16 

Emergency Generator Engines c/ 13 11 < 0.5 < 0.5 30 

Gas Turbine Generators 141 12 1 2 1 

Fuel Gas Heaters 1 1 < 0.5 < 0.5 < 0.5 

Heated Vent Stack Heater No. 1 5 4 < 0.5 < 0.5 < 0.5 
 4-158 4.0 – Environmental Impact Analysis 

TABLE 4.11.1-3 

Summary of Potential Emissions From the Existing Terminal Equipment a/ 

Equipment Group 

NOX

Emissions 

(tpy) 

CO 

Emissions 

(tpy) 

SO2 Emissions

(tpy) 

PM b/ 

Emissions 

(tpy) 

VOC 

Emissions 

(tpy) 

Firewater Pump Drives 6 1 1 < 0.5 < 0.5 

Air Compressor < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 

Vessel Unloading d/ -- -- -- -- 1 

Oil Storage Tanks -- -- -- -- 3 

Existing Equipment Total 513 608 4 9 72 

____________________________________________________________________ 

a/ Summary values reflect rounding to the nearest whole number expressed in tons per year. 

b/ All PM emissions from exclusive natural gas combustion are less than 2.5 micrometers, therefore PM emissions represent 

potential emissions of both PM10 and PM2.5. 

c/ Potential emissions from the emergency generator engines are based on 500 hundred hours per year of operation, as 

documented in the January 2006 minor modification to designate the existing RICE for emergency use only. 

d/ Existing vessel unloading emissions represent fugitive VOC emissions from landside stationary source operations. 

TABLE 4.11.1-4 

Summary of Indirect Emissions Due to Current Vessel Operations a/ 

Operation 

NOX

Emissions

(tpy) 

CO 

Emissions

(tpy) 

SO2

Emissions 

(tpy) 

PM10

Emissions 

(tpy) 

VOC 

Emissions

(tpy) 

LNG Vessel Offloading (2004-2006) 33 2 136 12 0.5 

LNG Vessel Hotelling (2004-2006) 6 0.4 27 2 0.1 

LNG Vessel Transit (2004-2006) 10 4 15 2 2 

Tug Assist Vessel Standby (2004-2006) 17 0.8 0.7 0.8 0.6 

Tug Assist Vessel Berthing/Unberthing (2004-2006) 28 2 0.9 2 1 

Coast Guard Escort Vessels (2004-2006) 4 115 0.09 0.03 3 

Total Secondary Vessel Emissions based on 

current operations b/ 

56 3 163 15 1 

Total Indirect Vessel Emissions based on current 

operations 

98 124 180 18 8 

LNG Vessel Offloading (Current Capacity) 131 7 240 21 3 

LNG Vessel Hotelling (Current Capacity) 18 1 27 2 0.4 

LNG Vessel Transit (Current Capacity) 22 9 33 4 4 

Tug Assist Vessel Standby (Current Capacity) 45 2 2 2 1 

Tug Assist Vessel Berthing/Unberthing (Current 

Capacity) 

53 4 2 4 3 

Coast Guard Escort Vessels (Current Capacity) 10 280 0.2 0.07 8 

Total Secondary Vessel Emissions based on 

current capacity b/

194 10 270 26 5 

Total Indirect Vessel Emissions based on current 

capacity 

279 302 305 33 20 

____________________________________________________________________ 

a/ Current operation emissions are based on receiving approximately 50 vessels per year. Current capacity emissions are based

on receiving 126 vessels per year, which is the number of estimated port calls that Southern LNG would expect at full utilization 

of the Elba II Project. 

b/ Secondary emissions for PSD impact analyses include emissions generated during LNG Vessel Offloading, LNG Vessel 

Hotelling, and Tug Assist Vessel Standby during Vessel Offloading and Hotelling. 
 4-159 4.0 – Environmental Impact Analysis 

Elba Express Compressor Station

Currently, no sources of air emissions exist at the proposed location of the Elba Express Pipeline 

and Compressor Station. 

4.11.1.4 Regulatory Requirements for Air Quality 

The proposed project is potentially subject to a variety of federal and state regulations pertaining 

to the construction and/or operation of air emission sources. The GDNR has primary jurisdiction 

over air emissions produced by the sources to be located at either the expanded terminal, the new 

compressor station or along the pipeline. The GDNR enforces its own regulations as well as 

EPA’s federal requirements. The following sections summarize the applicability of various 

GDNR and federal regulations. 

Terminal Expansion

Federal Air Quality Requirements 

New Source Review/Prevention of Significant Deterioration

Expansion of the Elba Terminal would take place in Chatham County an attainment area for all 

criteria pollutants. Due to the attainment status of the area federal non-attainment New Source 

Review requirements do not apply. 

PSD regulations (40 CFR Part 52.21) address construction in air quality attainment areas and 

define a major source as any source with a PTE listed pollutants in amounts equal to or greater 

than 250 tons per year (tpy) or 100 tpy for 28 specific source categories. If the construction 

consists of a modification to an existing major source, then lower emission thresholds triggering 

the need for PSD review apply (i.e., 40 tpy of NOX, 100 tpy of CO). 

The existing Terminal is a major source under PSD as its PTE of NOX and CO each exceed 250 

tpy. As a result, a PSD review and PSD netting analysis were required for the proposed 

Terminal Expansion facilities. Southern LNG conducted a PSD netting analysis as part of the air 

construction permit application process. The PSD netting analysis demonstrated that both NOX

and CO net emission increases exceed the PSD significance thresholds, and a PSD construction 

permit was required. Southern LNG prepared and submitted a PSD permit application to GDNR 

EPD in April 2006. On May 15, 2007, GDNR EPD issued its Final Determination and approved 

the proposed modifications at the Elba terminal as part of Southern LNG’s Part 70 Operating 

Amendment. 

Projects subject to PSD review must complete a Best Available Control Technology (BACT) 

analysis to determine the feasible and cost-effective control technology to be applied in order to 

limit the impacts from the proposed new emission sources. As presented in the proposed Elba III 

Terminal Expansion PSD Permit Application, the six new LNG vaporizers would utilize 

submerged combustion vaporizer technology, good combustion practices, and proper operation 

and maintenance to limit emissions of NOX and CO, for which PSD review was required. 
 4-160 4.0 – Environmental Impact Analysis 

Table 4.11.1-5 summarizes the BACT determination and corresponding emission rate for each 

PSD significant pollutant as part of the Elba III Terminal Expansion, and includes BACT 

determinations for prior projects to illustrate the improvements in emission control technology 

for SCV applications. 

TABLE 4.11.1-5 

BACT Determinations for Elba Island LNG Terminal 

Project Year Permitted a/ NOX BACT (lb/MMBtu) CO BACT (lb/MMBtu) 

Recommissioning/Elba I Expansion 2001 0.114 0.164 

Elba II Expansion 2003 0.08 0.164 

Elba III Expansion 2007 0.037 0.030 

____________________________________________________________________ 

a/ Denotes year in which PSD permit was issued. 

New Source Performance Standards

Southern LNG would comply with applicable New Source Performance Standards (NSPS) 

through exclusive natural gas firing and proper operation and maintenance of combustion 

devices. Two NSPS subparts were identified as being applicable to sources at the proposed 

Terminal Expansion site. 

If a source is found to be subject to a source-specific NSPS, the general requirements of Subpart 

A apply, unless specifically excluded by the source-specific NSPS. Subpart A requires initial 

notification and performance testing, recordkeeping, monitoring, reference test methods, and 

general control device requirements that support all other subparts as applicable. 

Subpart Db applies to each steam generating unit of 100 million British thermal units per hour 

(MMBtu/hr) or greater heat input capacity that was constructed or modified after June 19, 1984. 

Each existing and proposed 121.4 MMBtu/hr vaporizer is subject to this subpart. Accordingly, 

Subpart Db applies to the new vaporizers associated with the Terminal Expansion Project. 

For units firing exclusively natural gas, Subpart Db requires a NOX emission standard of 0.20 

lb/MMBtu and the use of a Continuous Emissions Monitoring System (CEMS) or a Predictive 

Emissions Monitoring System (PEMS) to monitor NOX emissions. Subpart Db also requires 

hourly fuel records and quarterly records of excess NOX emissions and daily records of NOX

emission rates and other operational parameters. Subpart Db is noted in the current facility Title 

V permit (Condition 3.3.3) as a rule currently applicable to the existing vaporizers constructed as 

part of the previous Elba II Project. 

National Emissions Standards for Hazardous Air Pollutants

The Elba Island LNG Terminal is not predicted to be a major source of hazardous air pollutants 

(HAP) because potential emissions of combined HAPs would be less than 25 tpy and emissions 

of any individual HAP would be less than 10 tpy. The potentially applicable National Emissions 
 4-161 4.0 – Environmental Impact Analysis 

Standards for Hazardous Air Pollutants (NESHAPs) that do not apply because of the facility’s 

minor source status include the following: 

• Subpart HH, National Emissions Standards for Hazardous Air Pollutants: Oil and Natural 

Gas Production; 

• Subpart HHH, National Emissions Standards for Hazardous Air Pollutants: Natural Gas 

Transmission and Storage; 

• Subpart YYYY, National Emissions Standards for Hazardous Air Pollutants: Combustion 

Turbines; 

• Subpart ZZZZ, National Emissions Standards for Hazardous Air Pollutants: 

Reciprocating Internal Combustion Engines; and 

• Subpart DDDDD: National Emissions Standards for Hazardous Air Pollutants: Industrial, 

Commercial, and Institutional Boilers and Process Heaters. 

Title V Operating Permit 

The Terminal Expansion Project is a major source with respect to the Title V (Part 70) Major 

Source Operating Program as administered by GDNR EPD pursuant to Section 391-3-1-.03(10), 

“Title V Operating Permits,” of Georgia’s Rules for Air Quality Control (GRAQC). The facility 

is a major source because potential emissions of NOX, among other pollutants, exceed the 

applicable major source threshold of 100 tpy. The facility currently operates under Title V 

Permit No. 4922-051-0003-V-02-2. Southern LNG has submitted an application to modify the 

Title V permit as part of the PSD Permit Application. On May 15, 2007, GDNR EPD issued its 

Final Determination and approved the proposed modifications at the Elba terminal as part of 

Southern LNG’s Part 70 Operating Amendment. 

Applicable State Air Quality Requirements 

GDNR EPD administers state construction permit programs and State Implementation Plan 

(SIP)-approved permitting programs for the federal PSD and Title V permit programs. GDNR 

EPD requires that Southern LNG secure appropriate construction permit authorization prior to 

the installation of equipment associated with the Terminal Expansion Project. Southern LNG 

prepared and submitted a PSD air permit application to EPD in April 2006. Southern would not 

initiate construction prior to the issuance of the required permit. 

A number of applicable state emission standards, which differ from federal requirements, were 

addressed in the air permit application. The state regulations with which Southern LNG’s 

operations must comply include: 

• GRAQC §391-3-1-.02(2)(b) - Visible Emissions 

• GRAQC §391-3-1-.02(2)(d) - Fuel-Burning Equipment 

• GRAQC §391-3-1-.02(2)(g) - Sulfur Dioxide 
 4-162 4.0 – Environmental Impact Analysis 

Elba Express Compressor Station

Federal Air Quality Requirements 

New Source Review/Prevention of Significant Deterioration

Due to the attainment status of the project area, federal non-attainment NSR requirements do not 

apply. 

The PTE of the proposed compressor station would not exceed 250 tpy for any criteria pollutant. 

The Elba Express Compressor Station would be classified as a new “minor” source and not 

subject to PSD review; therefore, BACT and PSD modeling would not be required. 

Additionally, GEPD does not require state BACT or modeling for minor sources. 

For minor sources, the GEPD allows for the issuance of either a combined construction and 

operating permit or alternatively, separate construction and operating permits. At a minimum, a 

state construction permit would be required from the GEPD prior to the start of construction of 

the Elba Express Compressor Station. EEC would submit the appropriate permit application to 

the GEPD in advance of construction activities. 

New Source Performance Standards

The proposed turbine would have a heat input rate greater than 10 MMBtu/hr, therefore it is 

subject to Federal NSPS for Stationary Combustion Turbines (40 CFR 60 Subpart KKKK). Due 

to the turbine’s heat input rate, greater than 10 MMBtu/hr but less than 850 MMBtu/hr, the 

applicable NOx emission standard is 25 ppmv (parts per million by volume) at 15 percent oxygen 

(O2). The utilization of dry-low NOx technologies will be employed to meet the NSPS for NOx. 

Furthermore, the proposed turbine would be required to meet a SO2 emission limit of 0.90 

lb/MW-hr. Alternatively, a fuel limit of 0.06 lb/MMBtu could be met. The utilization of natural 

gas as fuel ensures compliance with any of the referenced SO2 standards. 

As the proposed turbine would be subject to NSPS subpart KKKK, the provisions of the NSPS 

Subpart GG would not apply, although as noted for the Terminal Expansion, the unit would be 

subject to the general requirements contained in NSPS Subpart A. 

National Emissions Standards for Hazardous Air Pollutants

Potential emissions of HAPs from the new compressor station would be less than the major 

source threshold of 10 tpy for any single HAP and 25 tpy for total HAPs. Therefore, the 

provisions of NESHAP do not apply. 

Title V Operating Permit 

The total potential emissions of all criteria pollutants would be less than the Title V major source 

threshold of 100 tpy and as noted above the station would not be a major source of HAPs. As 
 4-163 4.0 – Environmental Impact Analysis 

such, the proposed Elba Express Compressor Station would not be subject to the Title V 

permitting requirements. 

Applicable State Air Quality Requirements 

GDNR EPD requires that EEC secure appropriate construction permit authorization prior to the 

installation of equipment associated with the proposed compressor station. EEC would obtain an 

air construction permit prior to any construction or installation of the proposed equipment. 

The same state regulations applicable to the expanded terminal would apply to the compressor 

station. 

• GRAQC §391-3-1-.02(2)(b) - Visible Emissions 

• GRAQC §391-3-1-.02(2)(d) - Fuel-Burning Equipment 

• GRAQC §391-3-1-.02(2)(g) - Sulfur Dioxide 

4.11.1.5 Air Emissions Impacts 

Construction Air Pollutant Emissions

Terminal Expansion

Air quality impacts associated with construction projects generally can be classified as impacts 

associated with fugitive dust generation and impacts associated with construction activities that 

may result in a minor temporary increase in emissions. Project construction would last 

approximately five years to complete both phases of the Terminal Expansion Project. 

The construction related emissions would be comprised of two components, fugitive dust 

generated by vehicle travel and vehicle exhaust emissions. The vehicle-related fugitive 

emissions would be comprised of emissions associated with construction equipment, commuter 

vehicles, and delivery vehicles traveling in and around the construction area. The impact of 

fugitive dust emissions associated with vehicle travel around the construction area would remain 

localized to the specific area disturbed by construction. 

The vehicle exhaust emissions would be generated by construction equipment, commuter 

vehicles, and delivery vehicles that travel in and around the construction area and generally 

include gasoline- or diesel-fueled engines in land clearing/grading equipment, cranes, bulldozers, 

various types of trucks, and cars. 

Table 4.11.1-6 provides the proposed estimates of criteria pollutant emissions due to construction 

related activities. For comparison purposes, table 4.11.1-7 shows the yearly emissions inventory 

for Chatham County, Georgia, for 2001, the most recent data (EPA 2001). The data lists 

aggregate annual emissions of criteria air pollutants from source categories defined by EPA. 

This includes emissions from both point sources (facilities) and area sources (small businesses, 

residences, wildfires, vehicles, etc.). The yearly constructed-related emissions estimated for the 

terminal expansion would be temporary and would account for only a minimal portion of the 
 4-164 4.0 – Environmental Impact Analysis 

county’s yearly emissions inventory. Therefore, we believe that the associated construction 

emissions would not result in a significant impact on air quality. 

TABLE 4.11.1-6

Summary of Construction Related Emissions From Terminal Expansion Project 

Operation NOX Emissions 

(tpy) 

CO Emissions 

(tpy) 

SO2 Emissions

(tpy) 

PM10 Emissions 

(tpy) 

VOC Emissions

(tpy) 

2007 

Construction Equipment a/ 0.58 0.21 0.08 0.04 0.05 

Commuter Traffic b/ 6.62E-02 9.52E-01 6.87E-04 2.29E-03 8.73E-02 

Delivery Vehicles b/ 5.67E-03 8.06E-03 1.42E-05 7.26E-04 4.65E-03 

Fugitive Dust c/ - - - 571.2 - 

2008 

Construction Equipment a/ 107.99 36.48 15.55 6.88 5.33 

Commuter Traffic b/ 6.08E-02 9.02E-01 6.25E-04 2.30E-03 8.02E-02 

Delivery Vehicles b/ 5.51E-03 8.00E-03 1.41E-05 7.07E-04 4.61E-03 

Fugitive Dust c/ - - - 571.2 - 

2009 

Construction Equipment a/ 130.28 43.61 19.46 8.49 8.57 

Commuter Traffic b/ 5.58E-02 8.58E-01 6.23E-04 2.28E-03 7.30E-02 

Delivery Vehicles b/ 5.33E-03 7.90E-03 1.43E-05 6.91E-04 4.54E-03 

Fugitive Dust c/ - - - 571.2 - 

2010 

Construction Equipment a/ 67.25 17.72 9.37 4.43 4.91 

Commuter Traffic b/ 5.09E-02 8.18E-01 6.23E-04 2.28E-03 6.62E-02 

Delivery Vehicles b/ 5.20E-03 7.89E-03 1.42E-05 6.76E-04 4.53E-03 

Fugitive Dust c/ - - - 571.2 - 

2011 

Construction Equipment a/ - - - - - 

Commuter Traffic b/ 4.02E-02 6.75E-01 5.38E-04 1.97E-03 5.20E-02 

Delivery Vehicles b/ 4.37E-03 6.75E-03 1.25E-05 5.41E-04 3.86E-03 

Fugitive Dust c/ - - - 571.2 - 

Total Construction Related 

Emissions associated with 

Elba III 

306 102 44 2,876 19 

____________________________________________________________________ 

a/ Construction equipment emissions based on EPA NONROAD model. 

b/ Commuter and delivery vehicle traffic emissions based on EPA MOBILE 6.2 model. 

c/ Fugitive dust emissions based on EPA AP-42 Chapters 13.2.1 for paved roads, 13.2.2 for unpaved roads, and 13.2.3 for heavy 

construction operations. 

Elba Express Pipeline and Compressor Station

Emissions from construction of the pipeline and compressor station would be temporary and last 

only during the construction period, anticipated to be approximately 9 to 12 months for Phase I 

(the pipeline) and 6 to 9 months for Phase II (the compressor station). Although pipeline 

construction is projected to require 9 to 12 months, the emissions associated with the burning of 
 4-165 4.0 – Environmental Impact Analysis 

vegetation typically occur over a few days. Open burning may occur during construction; 

however, EEC would comply with any local ordinances on open burning. 

TABLE 4.11.1-7 

Chatham County Emissions Inventory (2001) 

NOX

Emissions 

(tons)

CO 

Emissions 

(tons)

SO2

Emissions 

(tons)

PM10

Emissions 

(tons)

PM2.5

Emissions 

(tons) 

VOC 

Emissions

(tons)

Area Source Emissions 15,419 91,284 1,414 5,860 1,712 16,823 

Point Source Emissions 15,801 36,083 17,586 9,404 7,129 3,273 

Total Emissions 31,220 127,367 19,000 15,264 19,000 20,096 

The construction-related emissions are comprised of the similar components associated with 

construction of the Terminal Expansion. The types of construction equipment, commuter, and 

delivery vehicles for pipeline construction consist of dozers, tractors, boom trucks, pickup trucks, 

compressors, sidebooms, and other mobile equipment. Table 4.11.1-8 provides a summary of 

estimated vehicle exhaust emissions associated with construction of the pipeline. 

TABLE 4.11.1-8

Summary of Construction Emissions for the Elba Express Pipeline 

Pollutants Construction Emissions (tpy) 

NOx 84.23 

CO 18.15 

NM/NE VOC 6.83 

PM/PM10 5.98 

SO2 5.57 

____________________________________________________________________ 

Notes: 

1. Emission factors for NOx, CO, PM, PM10, SO2 and VOC taken from AP-42, Section 

3.3, table 3.3-1, dated October 1996 for diesel fuel. 

2. Estimated HP ratings 

3. Assumed load factors, equipment weeks, and days per week 

Air Pollutant Emissions From Operation 

Terminal Expansion

The new emission sources resulting from the Terminal Expansion Project would include 

installation of six new LNG vaporizers, each with a heat input of 121.4 MMBtu/hr and one new 

vent stack heater. Table 4.1.1-9 summarizes the proposed air emission sources at the terminal. 

Table 4.11.1-10 summarizes approximate potential emissions from each source group, Terminal 

Expansion facilities, and facility-wide potential emissions. 
 4-166 4.0 – Environmental Impact Analysis 

TABLE 4.11.1-9 

Summary of Air Emissions Equipment 

Equipment Manufacturer Model Rated Capacity (ISO) Site Rating 

LNG Vaporizer T-Thermal Sub-X 120-180 121.4 MMBtu/hr 121.4 MMBtu/hr 

LNG Vaporizer T-Thermal Sub-X 120-180 121.4 MMBtu/hr 121.4 MMBtu/hr 

LNG Vaporizer T-Thermal Sub-X 120-180 121.4 MMBtu/hr 121.4 MMBtu/hr 

LNG Vaporizer T-Thermal Sub-X 120-180 121.4 MMBtu/hr 121.4 MMBtu/hr 

LNG Vaporizer T-Thermal Sub-X 120-180 121.4 MMBtu/hr 121.4 MMBtu/hr 

LNG Vaporizer T-Thermal Sub-X 120-180 121.4 MMBtu/hr 121.4 MMBtu/hr 

Heated Vent Stack Heater Johnston N/A 11.74 MMBtu/hr 11.74 MMBtu/hr 

TABLE 4.11.1-10 

Summary of Potential Emissions From The Proposed Terminal Expansion a/ 

Equipment Group 

NOX

Emissions 

(tpy) 

CO 

Emissions 

(tpy) 

SO2 Emissions

(tpy) 

PM b/ 

Emissions 

(tpy) 

VOC 

Emissions 

(tpy) 

Terminal Expansion 

Elba III LNG Vaporizers 118 96 2 6 19 

Heated Vent Stack Heater No. 2 c/ 5 4 < 0.5 < 0.5 < 0.5 

Elba III Potential Emissions 

Increase d/ 123 100 2 6 20 

Facility-wide Total 

(After Expansion III) e/ 636 708 6 16 92 

____________________________________________________________________ 

a/ Summary values reflect rounding to the nearest whole number expressed in tons per year. 

b/ All PM emissions from exclusive natural gas combustion are less than 2.5 micrometers, therefore PM emissions represent 

potential emissions of both PM10 and PM2.5. 

c/ Potential emissions from the emergency generator engines are based on 500 hundred hours per year of operation, as 

documented in the January 2006 minor modification to designate the existing RICE for emergency use only. 

d/ Existing vessel unloading emissions represent fugitive VOC emissions from landside stationary source operations. 

e/ Facility-wide total Hazardous Air Pollutants emissions for all sources is 5.26 tons/year. 

As shown above, the Terminal Expansion facilities would cause increased emissions due to the 

operation of the new LNG vaporizers and would be subject to federal and state air quality 

regulations. PSD air quality impact analyses were conducted using EPA-approved regulatory air 

quality models to quantify the impacts associated with the Terminal Expansion facilities and 

continued operation of the existing terminal facilities. Southern LNG conducted a full air quality 

analysis as part of the PSD permit application process to determine impacts of the proposed 

Terminal Expansion Project on the ambient air. The air quality dispersion modeling analysis 

presented in the PSD permit application can be summarized as follows: 

• Ambient impacts on NO2 due to PSD increment-consuming emissions from the existing 

terminal facilities and significant regional sources were computed to be below PSD 

Increment thresholds. 
 4-167 4.0 – Environmental Impact Analysis 

• Ambient impacts on NO2 due to all emissions from the terminal facilities and significant 

regional sources demonstrated compliance with the NAAQS. 

• No significant ambient impacts of CO were predicted and compliance with applicable 

NAAQS is presumed. 

• Additional impacts to the soils, vegetation, and visibility of the surrounding area are not 

anticipated to be significant. 

• The Terminal Expansion Project and continued operation of the PSD Increment-affecting 

sources at the terminal would neither cause nor contribute to exceedances of applicable 

PSD Increment or Air Quality Related Values thresholds at federally protected Class I 

areas within 300 km of the facility. When the frequency, magnitude, and duration of 

visibility impairment events were considered, as well as visibility impairment due to 

natural occurring phenomena (e.g., sea salt and precipitation), the continued operation of 

the Increment-consuming sources at the terminal would not contribute to excessive levels 

of regional haze at the Wolf Island, Cape Romain, or Okefenokee Class I areas. 

• Computed ambient impacts of toxic air pollutants would be below allowable ambient 

concentrations as defined by GDNR EPD’s guidelines. 

Indirect Emissions from LNG Carrier

The Terminal Expansion Project would cause increases of indirect emissions of air pollutants 

from LNG carrier calling at the terminal and from various support vessels. GDNR EPD has 

previously determined that under state law and the Georgia State Implementation Plan for air 

quality, marine vessels are not part of the stationary source, even when docked at a facility that is 

a stationary source (GDNR EPD 2003). GRAQC 391-3-1-.03(9)(c) defines a stationary source 

as “all of the pollutant-emitting activities which belong to the same industrial grouping, are 

located on one or more contiguous or adjacent properties, and are under the control of the same 

person (or persons under common control) except the activities of any vessel,” which is 

consistent with the PSD definition of a stationary source at 40 CFR 52.21(b)(6). 

EPA air quality regulations for PSD permitting define secondary emissions as follows (40 CFR 

52.21(b)(18)): 

Secondary emissions means emissions which would occur as a result of the construction or 

operation of a major stationary source or major modification, but do not come from the major 

stationary source or major modification itself. Secondary emissions include emissions from any 

offsite support facility which would not be constructed or increase its emissions except as a 

result of the construction or operation of the major stationary source or major modification. 

Secondary emissions do not include any emissions which come directly from a mobile source, 

such as emissions from the tailpipe of a motor vehicle, from a train, or from a vessel. 

The GDNR EPD issued a letter to Southern LNG on June 5, 2006, requesting that LNG vessel 

emissions and modeling be included as part of the air permit application for the Terminal 

Expansion Project. After further discussions with GDNR EPD, it was determined that emissions 

generated during certain vessel operations may be considered secondary emissions. Although 

the regulatory definition of secondary emissions excludes emissions from the tailpipe of mobile 

sources, such as LNG cargo vessels, the emissions from the vessels while at berth are included as 
 4-168 4.0 – Environmental Impact Analysis 

secondary emissions. The mobile source exclusion is the basis for excluding “to and fro” 

emissions of LNG vessel vessels and support vessels from the secondary emissions analyses. 

Activities conducted while the vessels are at berth include hotelling operations and LNG 

offloading. Accordingly, Southern LNG submitted a response to GDNR EPD’s June 5 letter in 

the form of an updated air quality modeling analysis which included secondary vessel emissions. 

This report provides a summary of secondary emissions, which represent a subset of all indirect 

emissions from vessels. Southern LNG has quantified indirect vessel emissions based on all 

reasonable vessel activity associated with the terminal, including transit or “to and fro” 

emissions. Secondary emissions only include emissions generated while the LNG vessel is at 

berth, except for mobile Coast Guard vessels which may be patrolling the area while the vessel is 

at berth. 

The nature, size, frequency, and fuel-burning characteristics of LNG vessel vessels that call at 

the terminal are not under Southern LNG’s control or regulated for uniformity, but rather are 

dictated by Southern LNG’s customers that utilize LNG vessels from foreign sources. The LNG 

vessel emissions presented in this analysis are based on vendor-specific LNG vessel emission 

data as provided by Southern LNG customers. Emissions from the tug assist vessels are 

estimated based on the Tier II IMO/EPA Requirements (effective 2007). Coast Guard escort 

vessel emissions were based on factors for four-stroke outboard, precontrolled engines, as 

presented in EPA’s “Exhaust Emission Factors for Nonroad Engine Modeling – Spark Ignition.” 

Air emissions from these vessels are quantified using energy-based emission factors along with 

fuel types. Indirect emissions presented in this analysis include emissions from the LNG vessel 

while berthed at dockside for LNG offloading operations, the LNG vessel while in transit, tug 

assist vessels, and Coast Guard escort vessels. 

Prior to making the channel transit of the Savannah River and into the terminal, each arriving 

LNG vessel must gain permission from the Coast Guard to proceed. A summary description of 

the vessel and accompanying tugs’ activities once the vessel is authorized to proceed is provided 

below: 

• Following departure from the load port, the LNG vessel would have planned to arrive at 

the Pilot Boarding Position, designated as 2 miles east of the Sea Buoy. At this point, 

which is approximately 16 to 18 nautical miles from the terminal, one Savannah River 

Pilot, one Docking Pilot, and one tug assist vessel would join the vessel. To facilitate 

boarding by the River and Docking Pilot, the LNG vessels’ speed is reduced to 

approximately 10 knots. Once the pilots have safely boarded, the transit continues at 

approximately 12 knots. The inbound transit from Pilot Station to the Elba Island berths 

is estimated to take approximately one hour and forty-five minutes. During inbound 

transit operations, LNG cargo vessels may burn marine diesel heavy fuel oil (HFO) 

and/or boil-off LNG fuel gas. 

• Prior to the LNG vessel passing the Savannah River jetties, (a point approximately 6 to 8 

nautical miles from the terminal), an additional tug assist vessel meets the LNG vessel for 

escort purposes. 

• At a point approximately 1 to 2 nautical miles from the terminal (approaching the slip 

entrance), one or two additional tug assst vessels join the LNG vessel for purposes of 

docking assistance. At this point, a total of three or four tug assist vessels are engaged 
 4-169 4.0 – Environmental Impact Analysis 

with docking duties. Docking maneuvers take approximately 30 minutes. (The emission 

calculations for the tug assist vessel berthing/unberthing category conservatively assumed 

four tugs for the current operations at the terminal, and for the Terminal Expansion 

Project, as shown in tables 4.11.1-4, 4.11.1-11, and 4.11.1-12. However, it should be 

noted that four tugs normally would be used only for the larger LNG vessels. Smaller 

vessels are safely docked with three tugs.) 

• Once the LNG vessel is moored, one or two tug assist vessels are released, whilst two tug 

assist vessels remain on station at the facility in a stand-by mode for emergency response. 

A Docking Pilot remains onboard the LNG vessel throughout her port stay. 

• Once the vessel is moored, the means of propulsion is shut down, while auxiliary engines 

are used to provide power for both operational use and general “hotelling” purposes. 

During the discharge operation, auxiliary means are used to power the cargo pumps to 

offload the cargo. Hotelling and offloading operations typically last a period of 20 to 30 

hours. 

• Following completion of the offloading operation and granting of the required approvals 

by both the local authorities and the Coast Guard, the Docking Pilot is joined onboard by 

a Savannah River Pilot for departure. The two stand-by tugs are joined by one or two 

additional tugs to assist the LNG vessel in her undocking maneuver and subsequent 

channel departure transit. A total of three or four tugs are now engaged with undocking 

duties. Undocking maneuvers take approximately 15 to 30 minutes. (The emission 

calculations for the tug assist vessel berthing/unberthing category conservatively assumed 

four tugs for the current operations at the terminal and for the Terminal Expansion 

Project, as shown in tables 4.11.1-4, 4.11.1-11, and 4.11.1-12. Again four tugs normally 

would be used only for the larger LNG vessels. Smaller vessels are safely docked with 

three tugs.) 

• At a point approximately 0.5 to 1 nautical mile from the facility, one or two of the tug 

assist vessels are released, whilst two remain with the LNG vessel for the duration of the 

outbound escort. Once the outbound transit is underway, the vessel would proceed at 

approximately 12 knots. The outbound transit is estimated to take approximately one 

hour and thirty minutes. During outbound transit operations, LNG vessels may burn 

marine diesel HFO and/or boil-off LNG fuel gas. 

• At a point approximately 6 to 8 nautical miles from the terminal (at the Savannah River 

jetties), one of the escort tug assist vessels is released, and one tug remains with the 

vessel. 

• At a point approximately 16 nautical miles away from the terminal, the Savannah River 

Pilot and Docking Pilot depart the vessel, disembarking to the pilot boat and tug assist 

vessel, which is then released from service. 

Occasionally, Coast Guard vessels may escort the LNG vessels to Elba Island and patrol the area 

while LNG is offloaded to the terminal. For the purpose of this analysis, it was estimated that 

two escort vessels would accompany each vessel port call, and one vessel would patrol the island 

during hotelling and offloading operations. The transit emissions from the LNG vessels are an 

approximation, based on an LNG vessel traveling at 12 knots for 2 hours while in the reduced 

speed zone, which equates to a distance of 24 nautical miles each way. The transit emissions 

were estimated out to this distance, because this point is where vessels receive approval from the 
 4-170 4.0 – Environmental Impact Analysis 

Coast Guard to proceed, and the tugs begin assisting the vessels to enter the Savannah River 

channel and the Elba Island Terminal. 

Annual indirect emissions were estimated based on emission factors provided by Southern 

LNG’s customers, the type of fuel burned, and the estimated time required to complete the 

offloading operation. 

Southern LNG quantified indirect emissions due to current operations at the terminal. Actual 

emissions are based on vessel log data collected at Elba Island from August 3, 2004 to August 4, 

2006. The facility received 99 LNG vessels over this 2-year period. Prior to implementation of 

the Terminal Expansion Project, Southern LNG estimates the maximum annual number of 

vessels that will call on Elba Island to be approximately 126 vessels per year. This estimate 

includes vessels associated with both the Elba Island Recommissioning Project and the Elba II 

Project. However, the Elba II Project was just recently completed in February 2006. Therefore, 

actual operations over the past 2 years do not represent the current capacity of the facility, and 

Southern LNG expects the current average of 50 port calls per year to increase as Elba II reaches 

its full capacity. Table 4.11.1-4 provides the annual average estimate of criteria pollutant 

emissions due to actual operations at Elba Island over the past 2 years, as well as an estimate of 

indirect emissions after Elba II reaches full capacity (approximately 126 vessels per year). 

Southern LNG also estimated annual indirect emissions following the Terminal Expansion 

Project, based on the expected increase in port calls associated with the project. Table 4.11.1-11 

provides the estimated increase in criteria pollutant emissions associated with the current 

expansion project. 

TABLE 4.11.1-11

Summary of Indirect Emission From the Terminal Expansion Project a/ 

Operation 

NOX

Emissions 

(tpy) 

CO 

Emissions 

(tpy) 

SO2

Emissions 

(tpy) 

PM10

Emissions 

(tpy) 

VOC Emissions

(tpy) 

LNG Vessel Offloading 101 5 175 16 2 

LNG Vessel Hotelling 14 0.8 20 2 0.3 

LNG Vessel Transit 16 7 25 3 3 

Tug Assist Vessel Standby 34 2 1 2 1 

Tug Assist Vessel 

Berthing/Unberthing 

40 3 1 3 2 

Coast Guard Escort Vessels 7 211 0.2 0.05 6

Total Secondary Vessel 

Emissions associated with the 

Elba III Project b/

149 8 197 19 4 

Total Indirect Vessel Emissions 

associated with Elba III Project 

213 228 223 25 15 

_______________________________________________________ 

a/ Estimated emissions are based on 95 port calls per year, which includes LNG vessel traffic associated with the Terminal 

Expansion Project. Emission factors were vendor specific data provided by Southern LNG’s customers. 

b/ Secondary emissions for PSD impact analyses include emissions generated during LNG Vessel Offloading, LNG Vessel 

Hotelling, and Tug Assist Vessel Standby during Vessel Offloading and Hotelling. 
 4-171 4.0 – Environmental Impact Analysis 

Table 4.11.1-12 provides a cumulative summary of emissions from the future Elba Island LNG 

Terminal. 

TABLE 4.11.1-12 

Cumulative Summary of Emissions from the Future Elba Island LNG Terminal a/ 

Emission Source

NOX

Emissions

(tpy)

CO 

Emissions

(tpy)

SO2

Emissions

(tpy)

PM 

Emissions 

(tpy)

VOC 

Emissions

(tpy)

Existing Equipment 513 608 4 9 72 

Elba III Potential Emissions Increase 123 100 2 6 20 

Future Terminal 

(After Expansion III) b/ 636 708 6 16 92 

LNG Vessel Offloading 232 12 416 37 5 

LNG Vessel Hotelling 32 2 47 4 0.7 

LNG Vessel Transit 38 15 58 6 7 

Tug Assist Vessel Standby 79 4 3 4 3 

Tug Assist Vessel Berthing/Unberthing 93 7 3 7 5 

Coast Guard Escort Vessels 17 490 0.4 0.1 14 

Secondary Vessel Cumulative Emissions c/ 343 18 466 45 8

Indirect Vessel Cumulative Emissions 492 530 528 58 34

Future Elba LNG Terminal Total (including 

mobile sources) 1128 1238 534 74 126 

a/ Estimated emissions are based on 221 port calls per year, which includes cumulative LNG vessel traffic following the 

Terminal Expansion Project.

b/ Facility-wide total Hazardous Air Pollutants emissions for all sources is 5.26 tons/year. 

c/ Secondary emissions for PSD impact analyses include emissions generated during LNG Vessel Offloading, LNG 

Vessel Hotelling, and Tug Assist Vessel Standby during Vessel Offloading and Hotelling.

In addition, FERC requested that Southern LNG conduct a refined air dispersion analysis for the 

proposed project to provide a more thorough evaluation of the potential impacts on air quality in 

the vicinity of the Terminal Expansion. The air dispersion modeling analysis was used to predict 

the off-site concentrations in the vicinity of the project for NO2, CO, and SO2 emissions 

associated with operation of the project for comparison to the appropriate federal air quality 

standards. A summary of the methodology and results of the analysis is provided below. 

A cumulative impacts evaluation was conducted including the emissions attributable to all 

stationary sources at the Elba Island LNG Terminal (existing and proposed), marine vessel 

emissions originating within the moored security zone, and regional sources. The resulting 

impacts were assessed against the NAAQS. Emissions originating inside and outside of the 

moored security zone are summarized in table 4.11.1-13. 
 4-172 4.0 – Environmental Impact Analysis 

Table 4.11.1-13 

Summary of Mobile Emissions Within and Outside of Moored Security Zone 

Inside the Moored Security Zone Outside the Moored Security Zone 

LNG Vessel Offloading Tug Assist Vessel Standby at Port 

LNG Vessel Hotelling LNG Vessel Transit 

LNG Vessel Berthing/Unberthing Tug Assist Vessel Escort/Transit 

Tug Assist Vessel Pushing/Pulling/Maneuvering Security Escort/Transit/Patrol 

 

The modeling was conducted using the ISC-PRIME model with a 5-year meteorological data set 

(1982-1986) which was approved by the EPA for Southern LNG’s PSD permit application. The 

model included background concentrations of NO2, CO, and SO2 emissions which were derived 

from GDNR EPD ambient monitoring data as an average of peak measurements in the Savannah 

area. Industrial sources in the surrounding region were also included where regional source 

inventories of NOx and SO2 emissions were compiled from data provided by GDNR EPD and the 

South Carolina Department of Health and Environmental Control. A regional source emission 

inventory was not available for CO. The emissions were modeled using receptors at 100-meter 

spacing within 10 km of the Terminal. This methodology represents a very conservative 

approach. 

The worst-case scenario was modeled which represented the presence of two LNG vessels at the 

Terminal and the presence of two tug assist vessels for each LNG vessel only during berthing 

and unberthing. Although the expansion would be designed for two vessels to offload 

simultaneously, the likelihood of this is not expected to be great. Southern LNG estimated the 

duration of LNG operations during which the LNG vessel would have the highest level of 

emissions due to combustion of heavy fuel oil for steam turbine operation. The results of the 

cumulative NAAQS analysis are presented in table 4.11.1-14. 

TABLE 4.11.1-14 

Summary of Modeled Air Quality Impacts Attributable to Elba Island LNG Terminal 

Pollutant Averaging 

Period 

Maximum 

Modeled Impact 

(μg/m3) a/

Background 

Value (μg/m3) 

Total Impact 

(μg/m3) 

NAAQS 

(μg/m3) 

NO2 Annual 26.4 b/ 13 39.7 100 

CO 1-hour 795.3 c/ 3,406 4,201.29 40,000 

8-hour 384.2 c/ 2,266 2,650.17 10,000 

SO2 3-hour 1,076.8 c/ 143 1,219.80 1,300 

24-hour 386.9 c/ 52 438.9 365 

Annual 20.4 b/ 10 30.4 80 

a/ Maximum modeled impact from 5-year meteorological data b/ Impacts are assessed using highest impact at each receptor c/ Impacts are assessed using the highest, 2nd-high impact at each receptor 
 4-173 4.0 – Environmental Impact Analysis 

The modeling results show that the cumulative impacts of NO2, CO, and SO2 for the 3-hour and 

annual periods are all below the corresponding NAAQS. The cumulative impacts attributable to 

the Terminal exceed the NAAQS for the SO2 24-hour averaging period. Further analysis showed 

that the exceedances of the 24-hour NAAQS were estimated for 2 of the 5 meteorological data 

years analyzed and the emissions from marine activities contributed substantially to the 

magnitude of the estimated exceedances. The highest 24-hour SO2 impacts for the analysis were 

shown to occur in a narrow band immediately adjacent to the boundary of Elba Island and the 

safety zone at the docking area. However, given this very conservative approach, we believe that 

the Terminal Expansion alone would contribute to only a fraction of the impacts shown in the 

modeling analysis. Although the Terminal Expansion would contribute to the degradation of the 

regional air quality, it would not result in significant impacts to the regional air quality. 

In addition, the mix of LNG vessel configurations expected to dock at Elba Island would be 

changing in the coming years to include more diesel engine-driven vessels that would have lower 

SO2 emissions. The Marine Environment Protection Committee of the International Maritime 

Organization has identified SOx Emission Control Areas (SECAs) for certain territorial waters 

around the world. The east coast of the U.S. is one of the SECAs and it is considering adopting 

this proposed 1.5 percent or lower sulfur limit around 2010 or 2011 which is about the same time 

that the Terminal Expansion would go into service. This would ultimately result in lower SO2

emission from the LNG vessels. 

Waterway for LNG Marine Traffic

During normal operation of the project, air emissions from the LNG marine traffic and escort 

vessel traffic would occur between the LNG terminal to the territorial seas. Because the air 

emissions due to the LNG vessel traffic and escort vessels were estimated to a distance of 24 

nautical miles (27.6 miles) from the terminal, the air quality impacts within the Zones of 

Concern (described in section 4.12.4.3) are included in the above analysis. During normal 

operating conditions, the impacts on air quality would occur along the entire waterway from the 

territorial seas to the terminal. Following the assumption that the number of vessels that visited 

the Port of Savannah in 2005 is similar to the current rate of Port use, the Elba III Terminal 

Expansion would increase the number of visiting vessels to the Port by about three percent. 

Although we cannot quantitatively determine the increase in air impacts due to the additional 

LNG vessels and support vessels we can assume that the increase in air pollutants along the 

waterway attributable to the Elba III Terminal Expansion could be about three percent. The 

medium population density areas in Zones 2 and 3 are currently subject to the air emissions 

generated by LNG marine traffic and other large vessels using the waterway to destinations such 

as the Port of Savannah, Georgia. Thus while we cannot quantify the impacts, we do expect a 

temporary increase in air quality impacts to the populations in Zones 2 and 3 along the 

waterway, which at times (based upon wind speed, direction, number of support vessels, and fuel 

mixtures) may be above ambient air quality levels for short periods. However, the emissions 

affecting any one localized area would be temporary as the LNG vessels and support vessels 

make the transit and would occur at distances allowing for considerable dispersion. The longterm impacts associated with the normal operation of the additional LNG vessels along the 

waterway should not have a significant impact on air quality. 
 4-174 4.0 – Environmental Impact Analysis 

If a marine LNG spill occurred, any unignited LNG would vaporize; because LNG is mostly 

composed of methane, no criteria air pollutants would be associated with the vaporized LNG. 

However, methane is considered a greenhouse gas and may contribute to global warming. The 

dispersion of the methane vapors would cause a temporary decrease in the ambient air quality. 

Wildlife and humans occupying the water’s surface near the release in Zone 1 could intercept the 

vapor cloud prior to dispersion and suffer asphyxiation. The duration of exposure to any 

substantial pollutant concentrations would be short and would not pose a significant health risk 

to sensitive receptors given the distance to shore from a potential LNG spill. Therefore, there 

would be no significant impacts to air quality in the unlikely event of a marine LNG spill. 

However, if ignition to the vapor cloud would occur, combustion emissions would be released to 

the atmosphere. Natural gas combustion typically is not complete in spill scenarios. The 

products of incomplete combustion of natural gas include criteria pollutants, hazardous air 

pollutants, unburned hydrocarbons, and soot (carbon particulates). The maximum increases in 

ambient air pollutant concentrations due to the natural gas vapor cloud fire would occur 

downwind of the LNG spill. These ambient air pollutant concentrations would likely exceed 

short-term NAAQS and State Ambient Air Quality Standards over the duration of the fire as well 

as soot deposition and diminished visibility due to soot transport. The more populated area of 

the transit route closer to the terminal receptors would be exposed to higher pollutant 

concentrations for the short duration of the fire. The types and amounts of emissions from the 

ignition of an LNG pool would depend on many factors, but the emissions to any one localized 

area would be temporary and depend on weather and other conditions along the waterway. 

Emissions at a particular location that would arise from ignited vegetation and any nearby manmade structures would likely have greater levels of unburned hydrocarbons and hazardous air 

pollutants. Any high acute exposures to smoke from LNG and induced fires may lead to a range 

of health problems such as a worsening of asthma conditions, irritation of the eyes, nose and 

throat, and difficulty breathing. In sensitive populations (children, elderly, or chronically ill) 

symptoms of exposure may be of greater magnitude. This could be a significant impact, with 

injuries ranging from mild to fatal, being most severe in Zone 1 and decreasing outward through 

Zones 2 and 3. However, because of the implementation of safety and security measures during 

marine transit (See section 4.12, Reliability and Safety), the likelihood of a marine LNG spill 

would be extremely remote and therefore is highly unlikely to impact air quality. 

Elba Express Compressor Station

EEC performed an analysis to assess the potential air emissions from the proposed Elba Express 

Compressor Station. This section provides summary of that analysis for the sources to be 

constructed at the proposed compressor station. 

The emissions provided below are estimates at this time and are not permit limits for this unit. 

The permit limits would be established during the air permitting of the compression station. 

Table 4.11.1-15 lists the equipment that EEC has identified for installation and operation at the 

proposed location. 
 4-175 4.0 – Environmental Impact Analysis 

TABLE 4.11.1-15 

Proposed Equipment for Elba Express Compressor Station 

Equipment 

No. of 

Identical 

Units 

Net Output 

Power/Unit 

Maximum Heat 

Input/Unit (MMBtu/hr) 

Potential Hours of 

Operation per Year 

Solar Taurus 70-CS Turbine a/ 1 10,310 hp b/ 86.94 8760 

Emergency Generator a/ 1 250 kW 3.95 500 

Fuel Gas Heater a/ 1 NA 1.5 8760 

_____________________________________ 

a/ The manufacturer, make and model of the units are not finalized; therefore, they are subject to change. However, the net 

output ratings would be equivalent to those proposed. 

b/ Engine rating at ISO conditions. 

NOTE: The emissions provided above are estimates at this time and they are not permit limits for this unit. The permit limits

would be established during the air permitting of the compression station. 

Table 4.11.1-16 provides a summary of the PTE from the compressor station operation. The new 

compressor station would be a minor source which is not subject to PSD regulations under NSR 

and would not require BACT. No additional controls are planned beyond the SoLoNOx controls, 

installed by the manufacturer, that are standard for the proposed units and limit NOx, CO, and 

volatile organic compound (VOC) emissions. 

TABLE 4.11.1-16

Summary of Potential Emissions For Elba Express Compressor Station 

Pollutants Elba Express Compressor Station 

Potential to Emit from Proposed Project (tpy) 

NOx 39.83 

CO 45.63 

NM/NE VOC 12.51 

PM/PM10 2.57 

SO2 1.30 

Formaldehyde 0.60 

HAPs 0.69 

No air quality impacts would be expected from the operation of pipeline, metering, or other 

auxiliary facilities associated with the Elba Express Pipeline. 

4.11.1.6 Mitigation 

Terminal Expansion

During construction, elevated levels of ambient pollutants are likely to occur in the immediate 

vicinity of the terminal site. However, this reduction of local ambient air quality due to fugitive 

dust and emissions generated by construction equipment would be temporary. Once the 
 4-176 4.0 – Environmental Impact Analysis 

construction phase is completed, the fugitive dust and emissions would subside, thus the length 

of time any one area would be exposed to dust and emission from construction activities would 

be limited. The specific measures Southern LNG would employ to minimize constructionrelated vehicle exhaust emissions could include the utilization of more efficient (newer model) 

heavy construction equipment, maintaining all construction equipment in proper working 

condition, and minimizing the amount of idling time of construction equipment. Any measures 

employed by Southern LNG would meet all GDNR EPD requirements for construction-related 

vehicle exhaust emissions. Vehicular exhaust and crankcase emissions from gasoline and diesel 

engines would comply with applicable EPA mobile source emission regulations (40 CFR 85) by 

using equipment manufactured to meet these specifications. 

The specific control measures to minimize fugitive dust due to vehicle travel would meet all 

GDNR EPD requirements for fugitive dust mitigation, which may include watering the disturbed 

construction area, washing construction equipment, and minimizing the area being disturbed to 

the extent possible during each phase of construction. By implementing these measures, as 

applicable, we anticipate that the fugitive dust emissions associated with vehicle travel in and 

around the construction area should not result in a significant impact on regional air quality. 

Potential impacts on air quality due to the operation of the new LNG vaporizers would be 

minimized by adherence to applicable federal and state regulations and the installation of BACT 

to minimize emission from significant sources. As presented in Southern LNG’s Terminal 

Expansion Project PSD Permit Application, the six new LNG vaporizers would utilize 

submerged combustion vaporizer technology, good combustion practices, and proper operation 

and maintenance to limit emissions of NOX and CO, for which PSD review was required. 

Elba Express Pipeline and Compressor Station

Because pipeline construction moves along through an area relatively quickly, air emissions are 

typically intermittent and short-term. EEC would employ the same mitigations measures for 

construction of the pipeline and compressor station as described for the terminal. 

Air quality impacts due to the operation of the proposed Elba Express Pipeline facilities are 

anticipated to be minor. EEC would comply with all state and local air permitting requirements 

prior to construction and operation of the compressor station. We do not believe the minor air 

quality impacts associated with the pipeline facilities would have a significant cumulative effect 

on air quality when aggregated with other emissions sources in the area. 

4.11.2 Noise 

Noise impacts generally fall into two categories: temporary impacts resulting from operation of 

construction equipment, and long-term or permanent impacts resulting from operation of the 

Terminal Expansion facilities, Elba Express Pipeline facilities, and Elba Express Compressor 

Station. Construction-related noise from heavy equipment would be of a similar nature 

regardless of project. Both the Terminal Expansion and compressor station projects would 

involve the addition or installation of equipment that would fall under the same noise level 

requirements. Noise would affect the local environment during both the construction and 
 4-177 4.0 – Environmental Impact Analysis 

operation of the Terminal Expansion and Elba Express Pipeline facilities, including the Elba 

Express Compressor Station. The ambient sound level of a region is defined by the total noise 

generated within the specific environment, and is usually comprised of sound emanating from 

natural and artificial sources. At any location, both the magnitude and frequency of 

environmental noise may vary considerably over the course of the day and throughout the week. 

Two measures used by federal agencies to relate the time-varying quality of environmental noise 

to its known effect on people are the 24-hour equivalent sound level (Leq(24)) and the day-night 

sound level (Ldn). The Leq(24) is the level of steady sound with the same total (equivalent) energy 

as the time-varying sound of interest, averaged over a 24-hour period. The Ldn takes into account 

the duration and time the noise is encountered. The Ldn is the Leq(24) with 10 decibels on the Aweighted scale (dBA) added to nighttime sound levels between the hours of 10 p.m. and 7 a.m., 

to account for people’s greater sensitivity to sound during nighttime hours. 

In 1974, the EPA published Information on Levels of Environmental Noise Requisite to Protect 

Public Health and Welfare with an Adequate Margin of Safety. This publication evaluates the 

effects of environmental noise with respect to health and safety. The document provides 

information for state and local governments to use in developing their own ambient noise 

standards. The EPA has determined that to protect the public from activity interference and 

annoyance outdoors in residential areas, noise levels should not exceed an Ldn of 55 dBA. The 

FERC has adopted this criterion for new compression and associated facilities, and it is used here 

to evaluate the potential noise impact from operation of the proposed Terminal Expansion 

facilities and Elba Express Compressor Station. An Ldn of 55 dBA is equivalent to a continuous 

noise level of 48.6 dBA for facilities that operate at a constant level of noise. 

Both the Terminal Expansion and the Elba Express Compressor Station sites are located in the 

state of Georgia. The state of Georgia does not have a noise standard applicable to either project. 

The Terminal Expansion site is located in Chatham County, Georgia. The county has a noise 

standard applicable to the proposed expansion. The Chatham County noise ordinance (24-304 

Noise Disturbance Prohibited) limits sound from the Elba Island LNG Terminal facility to no 

greater than 60 dBA during the day (7 a.m. to 10 p.m.) and 55 dBA at night (10 p.m. to 7 a.m.) at 

any residential property line. Facility sound levels at any industrial or commercial property line 

are limited to 75 dBA and 65 dBA, respectively. The ordinance also prohibits construction 

during the hours of 10 p.m. and 7 a.m. if it creates a noise disturbance across a residential real 

property boundary. At any other hours, construction noise levels at noise sensitive areas (NSA) 

are limited to 75 dBA. 

The proposed Elba Express Compressor Station would be located in Jenkins County, Georgia. 

There are no local or county standards applicable to the compressor station. 

The FERC standard, limiting operational noise from either project to an Ldn of no greater than 55 

dBA, is the most restrictive standard for both the Terminal Expansion and the compressor station 

projects for nearby NSAs in Georgia. 
 4-178 4.0 – Environmental Impact Analysis 

Southern LNG and Elba Express evaluated potential noise impacts by conducting both a 

background noise monitoring program at the nearest NSAs and a noise impact evaluation for 

both the proposed LNG expansion and compressor station facilities. The noise impact 

evaluations included calculating expected increases in noise associated with construction and by 

calculating expected noise levels due to operation of each project. The expected noise levels 

were then compared to our standard for permissible noise levels at NSAs. 

4.11.2.1 Existing Noise Environment 

Terminal Expansion

The existing terminal is operational and as such, an ambient noise monitoring program was 

required at nearby NSAs with the facility operating at or near full load conditions. Two existing 

NSAs were identified in the vicinity of the facility. These NSAs are depicted on the site area 

map (figure 4.11-1) and include the following: 

• NSA 1 – Houses on Causton Harbor Road and Bartow Point Road, 12,300 feet southwest 

of the facility; and 

• NSA 2 – Houses along Riverview Road, 12,000 feet southwest of the facility. 

Southern LNG’s noise consultant, Hoover and Keith, Inc. (H&K), conducted ambient noise 

monitoring at the two NSA locations on the afternoon of March 20, 2006. The monitoring 

program was intended to be conducted with the terminal operating at or near full capacity. 

However, pipeline conditions at the time did not require full load operation. The measured 

ambient sound levels at the NSAs are provided in table 4.11.2-1. 

TABLE 4.11.2-1

Measured Ambient Noise Levels Near the Existing Terminal Facility (dBA) 

Location Distance/Direction LDay a/ LNight b/ Ldn

NSA 1 12,300 feet / SW 52.5 --- 58.9 

NSA 2 12,000 feet / SW 44.7 --- 51.1 

______________________________________________________ 

a/ The Elba Island LNG facility was not audible at either NSA location. 

b/ Lnight was not measured. Assumed to be equal to LDay. 

Only daytime measurements were conducted, and the nighttime noise level was conservatively 

assumed to be the same as the daytime noise level for purposes of calculating the existing Ldn

noise level. Existing noise sources included other industrial facilities, aircraft, and natural 

sounds (wind induced sounds, birds). The LNG facility was not audible at either of the NSA 

locations during noise monitoring. 

Southern LNG therefore selected five additional locations (noted as positions 3 through 7) inside 

the LNG facility, at closer-in locations, for obtaining noise measurements. The LNG facility was 

audible at four of the five closer-in locations. The measured sound levels at all closer-in 

positions are presented in table 4.11.2-2. 
 4-179 4.0 – Environmental Impact Analysis 

TABLE 4.11.2-2

Measured Ambient Noise Levels at Closer-In Positions Near the Existing Terminal Facility (dBA) 

Position Distance/Direction a/ Measured Sound Level (Leq) 

3 800 Feet / NW 63.6 

4 1100 Feet / WSW 57.5 

5 2100 Feet / SW 51.5 

6 1600 Feet / SSE 44.5 

7 600 Feet / SE 61.0 

______________________________________________________ 

a/ Distance is from the approximate acoustic center of the facility. 

Of the closer-in locations where the facility was audible, observations made by H&K indicated 

that at position 4, the terminal was the dominant source of noise, was in a clear line of site to the 

major noise producing sources at the facility, and would be an ideal position for obtaining noise 

level data that could be used to predict offsite sound levels. The noise level measured at position 

4 was extrapolated for distances to each of the NSA locations, accounting for distance and 

atmospheric affects. In addition, the measured level was also increased to account for the part 

load operating condition of the terminal. The adjustment consisted of determining the total 

potential horsepower of all major facility sources (23,800 hp), and the horsepower in operation 

during the noise measurements (8,500 hp). This resulted in an increase of 4.5 dBA over the 

measured levels from position 4. Provided in table 4.11.2-3 are the calculated full load terminal 

noise levels at each NSA location and at the nearest industrial property line, as calculated from 

the position 4 data. 
Non-Internet Public 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED ELBA III PROJECT 

Docket Nos. CP06-470-000, CP06-471-000, CP06-472-000, 

CP06-473-000, and CP06-474-000 

Page 4-180 

Figure 4.11-1 

NSA Location Map for Proposed Terminal Expansion Project 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 
 4-181 4.0 – Environmental Impact Analysis 

TABLE 4.11.2-3 

Calculated Noise Level Due to Full Load LNG Operation (dBA) 

From the Existing Terminal Facility 

Position Distance/Direction Calculated LDay LNight a/ Calculated Ldn

NSA 1 12,300 feet / SW 31.1 --- 37.5 

NSA 2 12,000 feet / SW 31.4 --- 37.8 

Nearest Industrial 

Property Line 7,000 Feet / WSW 39.2 --- --- 

______________________________________________________ 

a/ LNight was not measured. Assumed to be equal to LDay. 

The calculated noise levels due to the existing Terminal are shown to be well below the FERC 

standard for residential properties, and well below the Chatham County noise standard for 

industrial property lines. 

Elba Express Compressor Station

Existing NSAs were identified in the vicinity of the proposed compressor station. These NSAs 

are depicted on the site area map (figure 4.11-2) and include the following: 

• NSA 1 – A church approximately 1,400 feet west of the center of the proposed site; and 

• NSA 2 – A house approximately 3,500 feet east-southeast of the center of the proposed site. 

EEC’s consultants, H&K, conducted ambient noise measurements at these two NSA locations on 

July 24, 2006. Measurements were conducted during daytime hours only. The nighttime 

ambient level was estimated from observations, and an ambient Ldn was calculated. Existing 

noise sources included vehicular traffic noise and natural sounds (birds). These measured 

ambient levels are presented in table 4.11.2-4. 

TABLE 4.11.2-4

Existing Ambient Noise Levels Near The Proposed Compressor Station Site (dBA) 

Location Distance/Direction LDay LNight a/ Ldn

NSA 1 1,400 Feet / West 42.6 40.0 46.9 

NSA 2 3,500 Feet / ESE 45.4 40.0 47.7 

______________________________________________________ 

a/ LNight was estimated, not measured. 
Non-Internet Public 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED ELBA III PROJECT 

Docket Nos. CP06-470-000, CP06-471-000, CP06-472-000, 

CP06-473-000, and CP06-474-000 

Page 4-182 

Figure 4.11-2 

NSA Location Map for Elba Express Compressor Station 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 
 4-183 4.0 – Environmental Impact Analysis 

 

4.11.2.2 Construction Noise 

Terminal Expansion

Construction activity, and associated noise levels, would vary depending on the phase of 

construction in progress at any one time. Southern LNG assumed that the highest level of 

construction noise would occur during earth work and foundation construction. Construction 

noise levels were calculated for three distinct phases: 1) construction of the Terminal Expansion 

facilities; 2) pile driving, and; 3) dredging of the marine berthing slip. The construction noise 

analysis considered the noise produced by any significant sound sources associated with each 

construction phase. Construction noise levels were calculated for the nearest NSA location 

(NSA 2), by phase, and are provided in table 4.11.2-5. 

Based on the analyses conducted and the results presented above, we do not anticipate any 

significant noise impacts associated with construction of the proposed Terminal Expansion 

facilities. 

TABLE 4.11.2-5

Maximum Calculated Construction Noise Levels at NSA 2 by Terminal Expansion Construction Phase (dBA) 

Calculated LNG 

Facility 

Construction 

Calculated LNG 

Facility 

Construction (Ldn) 

Calculated 

Marine 

Terminal Pile 

Driving 

Calculated 

Marine 

Terminal Pile 

Driving (Ldn) 

Calculated 

Marine Terminal 

Dredging 

Calculated Marine 

Terminal 

Dredging (Ldn) 

34.0 40.4 35.0 41.4 27.0 33.4 

Elba Express Pipeline and Compressor Station

Construction activity, and associated noise levels, would vary depending on the phase of 

construction in progress at any one time. Construction of the pipeline would occur over 

relatively short 50 to 400 foot stretches. Work in the proximity of any single general location on 

the pipeline route would likely last no more than a few days to one week, as construction 

activities move along the corridor. Therefore, no single receptor would be exposed to significant 

noise levels for an extended period. 

EEC assumed that the highest level of construction noise of the compressor station would occur 

during earth work (site clearing and grading). Maximum expected construction noise levels at 

the nearest NSA (NSA 1) were calculated to be 52.0 dBA. Since no nighttime construction is 

proposed, the construction noise Ldn would also be 52.0 dBA. 

In addition to construction of the compressor station, EEC identified the need to conduct HDDs 

at two locations along the pipeline route (Savannah River and Broad River crossings). In the 

draft EIS, we recommended that EEC develop a HDD noise analysis, mitigation, and compliance 

plan demonstrating that noise due to drilling operations would be below an Ldn of 55 dBA or, if 

that threshold were exceeded, to stop drilling and mitigate noise at the affected NSA to reduce 

noise levels below this threshold, or offer temporary housing until noise levels at the NSA are 55 
 4-184 4.0 – Environmental Impact Analysis 

dBA Ldn or lower. In its comments to the draft EIS, EEC prepared and submitted an analysis of 

expected noise levels due to HDD activities at the nearest NSAs to each crossing. The analysis 

revealed that without mitigation, our 55 dBA Ldn limit for HDD noise would be exceeded at only 

one NSA near the Savannah River entry point and one NSA near the Broad River entry point. 

HDD noise levels would be below the limit at all remaining NSA locations at both crossings. 

The analysis also evaluated and recommended noise mitigation measures that would reduce 

noise at the NSA near the Savannah River crossing to below the 55 dBA Ldn limit. The noise 

increase due to drilling at the NSA near the Broad River crossing would be below a 3 dBA 

increase, the threshold of noticeable difference. 

EEC would be required to maintain drilling noise levels to below 55 dBA Ldn, and as a general 

requirement, resolve any landowner complaints concerning noise in its weekly status reports. 

Based on the measures that would be implemented by EEC, we believe that noise impacts 

associated with the HDD operations would be satisfactorily mitigated. 

4.11.2.3 Operational Noise 

Terminal Expansion

Southern LNG performed a noise analysis to calculate noise levels that would be generated by 

operation of the proposed Terminal Expansion facilities. These levels were evaluated against the 

existing baseline Ldn noise levels and our impact criterion to determine potential impacts at the 

representative NSAs. 

The calculated noise levels for the Terminal Expansion under full load conditions, as well as the 

existing ambient sound level and future sound level for the nearest NSAs, are presented in table 

4.11.2-6. The noise analyses also included specific noise mitigation measures to reduce impacts. 

TABLE 4.11.2-6

Terminal Expansion 

Calculated Operation Noise Levels Summary (dBA) 

Location 

Calculated 

Existing 

LNG Ldn a/

Calculated 

Project Ldn 

b/

Existing Measured 

Ambient Ldn c/

Cumulative Future 

Noise Level d/ (Ldn) 

Increase Over 

Existing 

NSA 1 37.5 38.8 58.9 58.9 0.0 

NSA 2 37.8 38.8 51.1 51.3 0.2 

______________________________________________________ 

a/ Noise level of Terminal under full load conditions. 

b/ Terminal plus proposed expansion under full load. 

c/ Existing measured ambient. Elba Island LNG not audible at these locations. Only daytime levels measured, and nighttime 

assumed to equal daytime levels. 

d/ Existing ambient levels plus Elba Island after expansion. 

Increases in noise levels of 3 dBA or less are considered to be imperceptible. The analysis 

revealed that imperceptible increases in noise (near zero dBA) would occur with Terminal 

Expansion facility operations. 
 4-185 4.0 – Environmental Impact Analysis 

Waterway for LNG Marine Traffic

Noise generated by LNG marine traffic along the waterway from the territorial sea to the 

proposed LNG Terminal Expansion would be similar to noise from other large vessels currently 

using the waterway. Scientific data exists to suggest that underwater vessel noise does impact 

aquatic species. However, extensive scientific research has not been conducted to know the 

exact noise impacts of underwater vessel noise on these species. Given the volume of existing 

vessel traffic into the Port of Savannah, it is expected that any noise attributable to the additional 

LNG vessels would not be noticed by species tolerant of existing shipping. Underwater noise in 

the Zones of Concern (described in section 4.12.4.3) would cause a local and temporary 

avoidance behavior in aquatic species but would not result in significant impacts. 

The proposed project area already is subject to routine noise disturbances associated with 

construction, commercial and recreational vessels, maintenance dredging, other engine 

operations, industrial and municipal activities, and other sources. Noise associated with the 

normal operation of the additional LNG vessels along the waterway would cause an insignificant 

incremental increase in noise impacts. Following the assumption that the number of vessels that 

visited the Port of Savannah in 2005 is similar to the current rate of Port use, the Elba III 

Terminal Expansion would increase the number of visiting vessels to the Port by about three 

percent. By extrapolation, therefore, it is assumed that the maximum increase in noise events 

along the waterway attributable to the Elba III Terminal Expansion would be about three percent. 

Overall, the amount of noise resulting from the proposed increase in LNG vessel traffic would be 

comparable to that associated with the large amount of shipping (including LNG vessels) that 

already use the Port of Savannah. 

In the event of a marine LNG spill, any LNG released would vaporize. Subsequent ignition of 

the vapor cloud may also occur. Detonation of an unconfined natural gas cloud is extremely 

difficult to achieve and is considered by scientists and researchers to be very unlikely to occur 

during an LNG spill. Therefore, noise associated with such an event would not be significant. 

Given the known behavior of an LNG spill when ignited, and because no detonation would 

result, such an ignition event would not be expected to generate sound pressure waves that would 

affect nearby species or other resources in the Zones of Concern, either above or below the 

surface of the water. 

Compliance with Applicable Noise Standards

Calculated operational noise levels for the Terminal Expansion were shown to be well below the 

FERC criterion of 55 dBA Ldn for all nearby NSA locations. Calculated facility noise levels at 

the nearest industrial property line (39.2 dBA) were shown to be in compliance with the 

Chatham County noise ordinance. Based on the analyses conducted, and the data presented 

above, we conclude that no significant noise impacts would occur with the proposed expansion 

operations. 

Proposed Mitigation

Southern LNG indicated that the following site-specific noise mitigation measures were included 

in the noise analyses: (a) the submerged combustion LNG vaporizer inlet fans would be totally 
 4-186 4.0 – Environmental Impact Analysis 

enclosed in an insulated acoustical enclosure and (b) The combustion air inlet would enter the 

acoustical enclosure through a suitable parallel baffle silencer. 

The modeling analyses for the Terminal Expansion facility incorporated noise reduction 

measures to achieve the levels presented herein. Based on the estimates presented in the 

acoustical analyses, noise levels due to operation of the Terminal Expansion facility would be 

below an Ldn of 55 dBA at the NSAs. Further, for NSA locations where the existing ambient Ldn

levels exceed 55 dBA, no increases in operational noise levels are expected, and we conclude 

that there would be no significant adverse noise impacts due to operation of the Terminal 

Expansion facility. However, to ensure that the Terminal Expansion Project operates in 

compliance with our guidelines, we recommend that Southern LNG file a noise survey with 

the Secretary for the Terminal Expansion no later than 60 days after placing the expansion 

facilities into service. If the noise attributable to the operation of the terminal exceeds an 

Ldn of 55 dBA at any nearby NSAs, Southern LNG should file a report on what changes are 

needed and should install additional noise controls to meet that level within 1 year of the 

in-service date. Southern LNG should confirm compliance with this requirement by filing 

a second noise survey no later than 60 days after it installs the additional noise controls.

Elba Express Compressor Station

The calculated Elba Express Compressor Station noise levels under full load conditions, as well 

as the existing ambient sound level, and future sound level for each NSA, are presented in table 

4.11.2-7. The noise analysis included specific mitigation measures to reduce impacts. 

TABLE 4.11.2-7 

Elba Express Compressor Station Existing and Future Noise Impacts at NSAs (dBA) 

Location Existing Measured 

Ambient Ldn

Calculated 

Project Ldn

Cumulative Future Ldn

Noise Level a/ Increase Over Existing 

NSA 1 46.9 52.0 53.2 6.3 

NSA 2 47.7 40.8 48.5 0.8 

______________________________________________________ 

a/ Ambient plus proposed compressor station at full load. 

The analysis indicated that increases in noise at the nearest NSA (church) would be on the order 

of 6 dBA. Increases in noise at the nearest residence would be less than 1 dBA, an essentially 

imperceptible increase, and noise levels at this location would be well below our criterion. 

Compliance with Applicable Noise Standards

Calculated operational noise levels for the Elba Express Compressor Station were shown to be 

below the FERC criterion of 55 dBA Ldn for both nearby NSA locations. Based on the analyses 

conducted, and the data presented above, we conclude that no significant noise impacts would 

occur with compressor station operations. 
 4-187 4.0 – Environmental Impact Analysis 

Proposed Mitigation

The modeling analyses for the Elba Express Compressor Station incorporated site-specific noise 

mitigation measures to achieve the levels presented herein. Based on the estimates presented in 

the acoustical analyses, noise levels due to operation of the station would be below an Ldn of 55 

dBA at the NSAs. We conclude that there would be no significant adverse noise impacts due to 

operation of the Elba Express Compressor Station. However, to ensure that the Elba Express 

Compressor Station operates in compliance with our guidelines, we recommend that EEC file a 

noise survey with the Secretary for the Elba Express Compressor Station no later than 60 

days after placing the station into service. If the noise attributable to the operation of the 

station under full load conditions exceeds an Ldn of 55 dBA at any nearby NSAs, EEC 

should file a report on what changes are needed and should install additional noise controls 

to meet that level within 1 year of the in-service date. EEC should confirm compliance 

with this requirement by filing a second noise survey no later than 60 days after it installs 

the additional noise controls. 

4.12 RELIABILITY AND SAFETY 

Three federal agencies share in the oversight of the safety and security of LNG import terminals: 

the FERC, the Coast Guard, and the DOT. The FERC authorizes the siting and construction of 

LNG import terminals and is the lead federal agency under NEPA to analyze the environmental, 

safety, security, and cryogenic design of proposed facilities. The Coast Guard has authority over 

safety of the LNG marine traffic and the marine transfer area. The Coast Guard also has 

authority over security of the LNG vessels and the entire LNG facility. In conjunction with this, 

the Coast Guard determines the suitability of waterways for LNG marine traffic by issuing an 

LOR. The DOT has exclusive authority to promulgate and enforce safety regulations and 

standards over the onshore LNG facilities beginning at the last valve immediately before the 

LNG storage tank. 

In February 2004, the three participating agencies entered into an Interagency Agreement to 

assure that they work in a coordinated manner to address the full range of issues regarding safety 

and security at LNG import terminals, including the terminal facilities and vessel operations, and 

to maximize the exchange of information related to the safety and security aspects of the LNG 

facilities and related marine operations. The FERC closely coordinates its pre-authorization 

review of the proposal with the Coast Guard and the DOT to ensure a seamless safety and 

security review. 

The operation of the proposed Elba III Terminal Expansion poses a potential hazard that could 

affect the public safety without strict design and operational measures to control potential 

accidents. The primary concerns are those events that could lead to an LNG spill of sufficient 

magnitude to create an offsite hazard, including events occurring during the course of but not 

limited to LNG vessel transits. However, it is also important to recognize the stringent 

requirements for the design, construction, operation and maintenance of the facility as well as the 

extensive safety systems to detect and control potential hazards. 
 4-188 4.0 – Environmental Impact Analysis 

With the exception of the October 20, 1944 fire at the LNG facility in Cleveland, Ohio, the 

operating history of U.S. LNG facilities has been free of LNG safety-related incidents resulting 

in adverse effects to the public or the environment. The 1944 Cleveland incident was attributed 

to the use of materials inadequately suited for cryogenic temperatures and the lack of spill 

impoundments at the site.27 More recently, an operational accident occurred in 1979 at the Cove 

Point LNG facility in Lusby, Maryland, when a pump seal failed, resulting in gas vapors entering 

an electrical conduit and settling in a confined space. When a worker switched off a circuit 

breaker, the gas ignited, resulting in heavy damage to the building and a worker fatality. Lessons 

learned from this accident resulted in changing the national fire codes, with the participation of 

the FERC, to ensure that the situation would not occur again. The proposed facilities would be 

designed, constructed, and operated in compliance with these codes. 

On January 19, 2004, a blast occurred at Sonatrach’s Skikda, Algeria LNG liquefaction facility 

that killed 27 and injured 56 workers. No members of the public were injured. Preliminary 

findings of the accident investigation suggest that a cold hydrocarbon leak occurred at 

Liquefaction Train 40 and was introduced to the high-pressure steam boiler by the combustion 

air fan. An explosion developed inside the boiler firebox which subsequently triggered a larger 

explosion of the hydrocarbon vapors in the immediate vicinity. The resulting fire damaged the 

adjacent liquefaction process and liquefied petroleum gas separation equipment of Train 40, and 

spread to Trains 20 and 30. Although Trains 10, 20, and 30 had been modernized in 1998-1999, 

Train 40 had been operating with its original equipment since start-up in 1981. 

Although there are major differences between the equipment involved in the accident at Skikda 

and that proposed by Southern LNG (i.e., high-pressure steam boilers that power refrigerant 

compressors would not be used here nor are they used at any LNG facility under FERC 

jurisdiction), the sequence of cascading events identifies potential failure modes that warrant 

further evaluation. As a result, we have provided a recommendation in section 4.12.2, Cryogenic 

Design and Technical Review, to address this issue. 

A discussion of the principal properties and hazards associated with LNG is presented in section 

4.12.1. A summary of our preliminary design and technical review of the cryogenic aspects of 

the LNG terminal is presented in section 4.12.2. An analysis of the thermal radiation and 

flammable vapor cloud hazards resulting from a credible land-based LNG spill is presented in 

section 4.12.3, while the safety aspects of LNG transportation by vessel is discussed and 

summarized in section 4.12.4. The emergency response and evacuation plan is discussed in 

section 4.12.5. Conclusions on marine traffic safety are provided in section 4.12.6. Security 

awareness related to terrorism is discussed in section 4.12.7. And finally, pipeline safety 

standards, pipeline accident data, and pipeline impacts on public safety are presented in sections 

4.12.8 through 4.12.10. 

 

27 For a description of the incident and the findings of the investigation, see “U.S. Bureau of Mines, Report on the 

Investigation of the Fire at the Liquefaction, Storage, and Regasification Plant of the East Ohio Gas Co., Cleveland, 

Ohio, October 20, 1944, February 1946.” 
 4-189 4.0 – Environmental Impact Analysis 

4.12.1 LNG Hazards 

LNG’s principal hazards result from its cryogenic temperature (-260° F), flammability, and 

vapor dispersion characteristics. As a liquid, LNG will neither burn nor explode. Although it 

can cause freeze burns and, depending on the length of exposure, more serious injury or death, 

its extremely cold state does not present a significant hazard to the public, which rarely, if ever, 

comes in contact with it as a liquid. As a cryogenic liquid, LNG will quickly cool materials it 

contacts, causing extreme thermal stress in materials not specifically designed for ultra-cold 

conditions. Such thermal stresses could subsequently subject the material to brittleness, fracture, 

or other loss of tensile strength. These hazards, however, are not substantially different from the 

hazards associated with the storage and transportation of liquid oxygen (-296° F) or several other 

cryogenic gases that have been routinely produced and transported in the United States. 

LNG vaporizes rapidly when exposed to ambient heat sources such as water or soil. When 

released from its containment vessel and/or transfer system, LNG will generally produce 620 to 

630 standard cubic feet of natural gas for each cubic foot of liquid. A large quantity of LNG 

spilled without ignition would form a vapor cloud that would travel with the prevailing wind 

until it either dispersed below the flammable limits or encountered an ignition source. If a large 

quantity of LNG is spilled in the presence of an ignition source, the resulting pool fire would 

produce high levels of radiant heat in the area surrounding the LNG pool. 

A rapid phase transition (RPT) can occur when a portion of LNG spilled onto water changes 

from liquid to gas, virtually instantaneously. Unlike an explosion that releases energy and 

combustion products from a chemical reaction, an RPT is the result of heat transferred to the 

liquid inducing a change to the vapor state. The rapid expansion from the liquid to vapor state 

can cause locally large overpressures. RPTs have been observed during LNG test spills onto 

water. In some test cases, the events were strong enough to damage test equipment in the 

immediate vicinity of the LNG release point. The sizes of the overpressure events have been 

generally small and are estimated to be equivalent to several pounds of trinitrotoluene (TNT). 

Although such a small overpressure is not expected to cause significant damage to an LNG 

vessel, the RPT may increase the rate of LNG pool spreading and the LNG vaporization rate for 

a spill on water. 

Methane vapors, the primary component of natural gas, are colorless, odorless and tasteless, and 

are classified as a simple asphyxiant. Methane vapors may cause extreme health hazards, 

including death, if inhaled in significant quantities within a limited time. Although very cold 

methane vapors may cause freeze burns, any cloud resulting from an LNG spill would be 

continuously mixing with the warmer air surrounding the spill site. Dispersion modeling 

indicates the majority of the cloud would generally be within 25° F of the surrounding 

atmospheric temperature, with colder temperatures closest to the spill source. In addition, this 

modeling estimates that most of the cloud would be below concentrations resulting in oxygen 

deprivation effects, including asphyxiation, with the highest methane concentrations closest to 

the spill source. Therefore, asphyxiation and freezing normally represent a negligible risk to the 

public from LNG facilities. 
 4-190 4.0 – Environmental Impact Analysis 

Although LNG will not burn, methane vapors in a 5 to 15 percent mixture by volume with air are 

flammable. Once a flammable vapor-air mixture from an LNG spill has been ignited, the flame 

front will propagate back to the spill site if the vapor concentration along this path is sufficiently 

high to support the combustion process. Combustible materials within the flammable portion of 

the cloud may be within the flame and could be ignited. However, any events leading to a 

containment failure would most likely be accompanied by a number of ignition sources. The 

result would be an LNG pool fire, and subsequent radiant heat hazards, rather than the formation 

of a large unconfined vapor cloud. 

Although, LNG is not explosive as it is normally transported and stored, natural gas vapors 

(primarily methane) can explode if contained within a confined space, such as a building or 

structure, and ignited. Occasionally, various parties have expressed the energy content of an 

LNG storage tank or LNG vessel in equivalent tons of TNT, as an implied measure of explosive 

potential. However, such a simplistic analogy fails to consider that explosive forces are not just 

a function of the total energy content but also of the rate of energy release. For a detonation to 

occur, the rate of energy release must be nearly instantaneous, such as with a TNT charge 

initiated by a blasting cap. Unlike TNT or other explosives which inherently contain an oxidizer, 

an unconfined vapor cloud must be mixed with oxygen within the flammability range of the fuel 

for combustion to occur. For a large unconfined vapor cloud, the flammability range tends to 

exist at the mixing zone at the edges of the cloud. When ignited, flame speeds about 20 to 25 

meters per second (66 to 82 feet per second) and local over pressures up to 0.2 psig have been 

estimated for unconfined methane-rich vapor clouds, well below the flame speeds and over 

pressures associated with detonation. 

The potential for unconfined LNG vapor cloud detonations was investigated by the U.S. Coast 

Guard in the late 1970s at the Naval Weapons Center at China Lake, California. These 

experiments, as well as other subsequent tests, are mentioned in Appendix C of the Sandia 

National Laboratories report entitled, Guidance on Risk Analysis and Safety Implications of a 

Large Liquefied Natural Gas (LNG) Spill Over Water, December 2004 (Sandia Report). Using 

methane, the primary component of natural gas, several experiments were conducted to 

determine if unconfined vapor clouds would detonate. The tests indicated unconfined methaneair mixtures could be ignited, but no test produced unconfined detonation. There is no evidence 

suggesting that methane-air mixtures will detonate in unconfined open areas. 

Further tests were conducted in the late 1970s to examine the level of sensitivity of an 

unconfined cloud to the presence of heavier hydrocarbons such as ethane and propane. As stated 

in Section 5 of Appendix C of the Sandia Report, detonation sensitivity is affected by the level of 

refinement of natural gas stored as LNG. The series of tests on ambient-temperature fuel 

mixtures of methane-ethane and methane-propane indicated that the addition of heavier 

hydrocarbons influenced the tendency of an unconfined vapor cloud to detonate. Less processed 

product with greater amounts of heavier hydrocarbons is more sensitive to detonation. During 

these experiments, all successful detonations were initiated with an explosive charge in wellmixed vapor clouds at correct stoichiometric proportions. These are not representative of 

conditions which would be expected during a large scale LNG spill. The precise timing, 

necessary mixing, and required amount of initiating explosives render the possibility for 

detonation of a large unconfined vapor cloud as unrealistic. Detonation of the unconfined 
 4-191 4.0 – Environmental Impact Analysis 

natural gas cloud is extremely difficult to achieve and is generally considered by scientists and 

researchers to be very unlikely to occur during an LNG spill. 

Consequently, the primary hazards to the public from an LNG spill either on land or water would 

be from dispersion of the flammable vapors or from radiant heat generated by a pool fire. 

4.12.2 Cryogenic Design and Technical Review 

As part of its application and in response to FERC staff’s data requests, Southern LNG provided 

a front-end engineering design for the proposed project. The front-end engineering design and 

technical review emphasizes the engineering design and safety concepts as well as the projected 

operational reliability of the proposed facilities. The principle areas of coverage include: 

materials in cryogenic environments; insulation systems; cryogenic safety; thermodynamics; heat 

transfer; instrumentation; cryogenic processes; and other relevant safety systems. 

Study and evaluation of information for the proposed design and installation of the Elba III 

Terminal Expansion facilities has been performed by the FERC staff. The front-end engineering 

design and specifications submitted for the proposed facilities to date are considered to be 

preliminary but would be the basis for any detailed design to follow. A significant amount of the 

design involving final selection of equipment manufacturers, process conditions, and resolution 

of some safety related issues would be completed in the next phase of the project development if 

authorization is granted by the Commission. This information would need to be filed with 

FERC staff for review and approval. 

As a result of the technical review of the information provided by Southern LNG in the submittal 

documents, a number of concerns were identified by staff relating to the reliability, operability, 

and safety of the proposed design. Southern LNG provided responses to staff’s questions at the 

technical conference held on January 24, 2007. However, several areas of concern are noted that 

require additional consideration and/or action on behalf of the company. Follow up on those 

items requiring additional action should be documented in reports to be filed with the FERC. As 

a result, we recommend that the following measures apply to Southern LNG’s Terminal 

Expansion. Information pertaining to these specific recommendations should be filed for 

review and approval by the Director of OEP either: prior to initial site preparation; prior 

to construction of final design; prior to commissioning; or prior to commencement of 

service, as indicated by each specific condition. Specific engineering, vulnerability, or 

detailed design information meeting the criteria specified in Order No. 683 (Docket No. 

RM06-24-000), including security information, should be submitted as critical energy 

infrastructure information (CEII) pursuant to 18 CFR 388.112. See Critical Energy 

Infrastructure Information, Order No. 683, 71 Fed. Reg. 58,273 (October 3, 2006), FERC 

Stats. & Regs. ¶ 31,228 (2006). Information pertaining to items such as: offsite emergency 

response; procedures for public notification and evacuation; and construction and 

operating reporting requirements would be subject to public disclosure. This information 

should be submitted a minimum of 30 days before approval to proceed is required. 

• Complete plan drawings and a list of the hazard detection equipment should be filed 

prior to initial site preparation. The list should include the instrument tag number, 
 4-192 4.0 – Environmental Impact Analysis 

type and location, alarm locations, and shutdown functions of the proposed hazard 

detection equipment. Plan drawings should clearly show the location of all detection 

equipment. 

• Southern LNG should provide a technical review of its proposed facility design that: 

a. Identifies all combustion/ventilation air intake equipment and the 

distances to any possible hydrocarbon release (LNG, flammable 

refrigerants, flammable liquids and flammable gases); and 

b. Demonstrates that these areas are adequately covered by hazard 

detection devices and indicate how these devices would isolate or 

shutdown any combustion equipment whose continued operation 

could add to or sustain an emergency. 

Southern LNG should file this review prior to initial site preparation. 

• Complete plan drawings and a list of the fixed and wheeled dry-chemical, fire 

extinguishing, and other hazard control equipment should be filed prior to initial 

site preparation. The list should include the equipment tag number, type, size, 

equipment covered, and automatic and manual remote signals initiating discharge 

of the units. Plan drawings should clearly show the planned location of all fixed and 

wheeled extinguishers. 

• Facility plans showing the proposed location of, and area covered by, each monitor, 

hydrant, deluge system, hose, and sprinkler, as well as piping and instrumentation 

diagrams, of the fire water system should be filed prior to initial site preparation. 

• A copy of the hazard design review and list of recommendations that are to be 

incorporated in the final facility design should be filed prior to initial site 

preparation. 

• The final design of the fixed and wheeled dry-chemical, fire extinguishing hazard 

control equipment should identify manufacturer and model. 

• The final design should include an updated fire protection evaluation carried out in 

accordance with the requirements of NFPA 59A 2001, chapter 9.1.2. 

• The final design should include a shutoff valve at the suction and discharge of each 

high pressure LNG pump. 

• The final design of the vaporizers should include double block isolation on the 

suction and double block isolation and check valve on the discharge of each 

vaporizer. One of the valves on the suction and one valve on the discharge should 

be automatically actuated. 
 4-193 4.0 – Environmental Impact Analysis 

• The final design of the minimum flow recycle line from the secondary pumps to 

downstream of the isolation valve to the LNG storage tanks should specify pipe with 

the same pressure and temperature rating as the discharge piping for the secondary 

pumps. 

• The final design should include details of the shut down logic, including cause and 

effect matrices for alarms and shutdowns. 

• The final design should include emergency shutdown of equipment and systems 

activated by hazard detection devices for flammable gas, fire, and cryogenic spills, 

when applicable. 

• The final design should specify that the hazardous area classification of the LNG 

pump area and vaporizer LNG inlet and outlet piping areas are classified as Class 1 

Group D, Division 1. 

• The final design should include details of the air gaps to be installed downstream of 

all seals or isolations installed at the interface between a flammable fluid system and 

an electrical conduit or wiring system. Each air gap should vent to a safe location 

and be equipped with a leak detection device that should continuously monitor for 

the presence of a flammable fluid, should alarm the hazardous condition, and 

should shutdown the appropriate systems. 

• The final design should include a hazard and operability review of the completed 

design. A copy of the review and a list of the recommendations should be filed. 

• The final design of the sendout piping from the vaporizers to the shut-off valve 

upstream of the meter station should specify the same pressure rating as the 

vaporizer discharge piping. 

• All valves including drain, vent, main, and car sealed, or locked valves should be 

tagged in the field during construction and prior to commissioning. 

• The design details and procedures to record and to prevent the tank fill rate from 

exceeding the maximum fill rate specified by the tank designer should be filed prior 

to commissioning. 

• A tabulated list of the proposed hand-held fire extinguishers should be filed prior to 

commissioning. The information should include a list with the equipment number, 

type, size, number, and location. Plan drawings should include the type, size, and 

number of all hand-held fire extinguishers. 

• Operation and Maintenance procedures and manuals, as well as safety procedure 

manuals, should be filed prior to commissioning. 

• The FERC staff should be notified of any proposed revisions to the security plan 

and physical security of the facility prior to commencement of service. 
 4-194 4.0 – Environmental Impact Analysis 

• Progress on construction of the Expansion Project should be reported in filed 

monthly reports. Details should include a summary of activities, projected schedule 

for completion, problems encountered and remedial actions taken. Problems of 

significant magnitude should be reported to the FERC within 24 hours. 

In addition, we recommend that the following measures should apply throughout the life of 

the facility:

• The facility should be subject to regular FERC staff technical reviews and site 

inspections on at least an annual basis or more frequently as circumstances indicate. 

Prior to each FERC staff technical review and site inspection, Southern LNG should 

respond to a specific data request including information relating to possible design 

and operating conditions that may have been imposed by other agencies or 

organizations. Up-to-date detailed piping and instrumentation diagrams reflecting 

facility modifications and provision of other pertinent information not included in 

the semi-annual reports described below, including facility events that have taken 

place since the previously submitted semi-annual report, should be submitted. 

• Semi-annual operational reports should be filed with the Secretary to identify 

changes in facility design and operating conditions, abnormal operating experiences, 

activities (including vessel arrivals, quantity and composition of imported LNG, 

vaporization quantities, boil-off/flash gas, etc.), plant modifications including future 

plans and progress thereof. Abnormalities should include, but not be limited to: 

unloading/shipping problems, potential hazardous conditions from offsite vessels, 

storage tank stratification or rollover, geysering, storage tank pressure excursions, 

cold spots on the storage tanks, storage tank vibrations and/or vibrations in 

associated cryogenic piping, storage tank settlement, significant equipment or 

instrumentation malfunctions or failures, non-scheduled maintenance or repair 

(and reasons therefore), relative movement of storage tank inner vessels, vapor or 

liquid releases, fires involving natural gas and/or from other sources, negative 

pressure (vacuum) within a storage tank and higher than predicted boiloff rates. 

Adverse weather conditions and the effect on the facility also should be reported. 

Reports should be submitted within 45 days after each period ending June 30 and 

December 31. In addition to the above items, a section entitled "Significant plant 

modifications proposed for the next 12 months (dates)" also should be included in 

the semi-annual operational reports. Such information would provide the FERC 

staff with early notice of anticipated future construction/maintenance projects at the 

LNG facility. 

• In the event the temperature of any region of any secondary containment, becomes 

less than the minimum specified operating temperature for the material, the 

Commission should be notified within 24 hours and procedures for corrective action 

should be specified. 

• Significant non-scheduled events, including safety-related incidents (i.e., LNG or 

natural gas releases, fires, explosions, mechanical failures, unusual over 

pressurization, and major injuries) and security related incidents (i.e., attempts to 
 4-195 4.0 – Environmental Impact Analysis 

enter site, suspicious activities) shall be reported to FERC staff. In the event an 

abnormality is of significant magnitude to threaten public or employee safety, cause 

significant property damage, or interrupt service, notification shall be made 

immediately, without unduly interfering with any necessary or appropriate 

emergency repair, alarm, or other emergency procedure. In all instances, 

notification shall be made to Commission staff within 24 hours. This notification 

practice should be incorporated into the LNG facility's emergency plan. Examples 

of reportable LNG-related incidents include: 

a. fire; 

b. explosion; 

c. estimated property damage of $50,000 or more; 

d. death or personal injury necessitating in-patient hospitalization; 

e. free flow of LNG that results in pooling; 

f. unintended movement or abnormal loading by environmental causes, 

such as an earthquake, landslide, or flood, that impairs the 

serviceability, structural integrity, or reliability of an LNG facility that 

contains, controls, or processes gas or LNG; 

g. any crack or other material defect that impairs the structural integrity 

or reliability of an LNG facility that contains, controls, or processes 

gas or LNG; 

h. any malfunction or operating error that causes the pressure of a 

pipeline or LNG facility that contains or processes gas or LNG to rise 

above its maximum allowable operating pressure (or working pressure 

for LNG facilities) plus the build-up allowed for operation of pressure 

limiting or control devices; 

i. a leak in an LNG facility that contains or processes gas or LNG that 

constitutes an emergency; 

j. inner tank leakage, ineffective insulation, or frost heave that impairs 

the structural integrity of an LNG storage tank; 

k. any condition that could lead to a hazard and cause a 20 percent 

reduction in operating pressure or shutdown of operation of a pipeline 

or an LNG facility; 

l. safety-related incidents to LNG vessels occurring at or en route to and 

from the LNG facility; or 

m. an event that is significant in the judgment of the operator and/or 

management even though it did not meet the above criteria or the 

guidelines set forth in an LNG facility’s incident management plan. 

In the event of an incident, the Director of OEP has delegated authority to take 

whatever steps are necessary to ensure operational reliability and to protect human 

life, health, property or the environment, including authority to direct the LNG 

facility to cease operations. Following the initial company notification, Commission 

staff would determine the need for an on-site inspection by Commission staff, and 

the timing of an initial incident report (normally within 10 days) and follow-up 

reports. 
 4-196 4.0 – Environmental Impact Analysis 

The Southern LNG terminal has been designed to withstand the effects of hurricane force winds, 

storm surges, and flooding. All critical structures and facilities for the Elba III Terminal 

Expansion Project would be designed to withstand 150 mph sustained winds per 49 CFR 

193.2067. Non-critical facilities or structures would be designed in accordance with the wind 

design criteria in American Society of Civil Engineers standard, ASCE 7-98 “Minimum Design 

Loads for Buildings and Other Structures.” 

The terminal site elevations were established based on storm surge and flooding effects data 

available for Elba Island in Chatham County, Georgia. Southern LNG researched data from the 

Federal Emergency Management Agency and the Chatham Emergency Management Agency. 

The predicted storm surge elevation at high tide due to a Category 3 hurricane would be nearly 

equivalent to the 100-year flood elevation of 22 feet Mean Low Water (MLW). To provide 

protection from these events, the top of the dike elevation for the new LNG storage tanks would 

be at least 26 feet above MLW, and critical process equipment, such as the boiloff gas 

condensers, would be elevated above 22 feet MLW. 

4.12.3 Siting Requirements – Thermal and Dispersion Exclusion Zones 

Regulatory Requirements

The LNG facilities proposed in this project must comply with the siting requirements of 49 CFR 

193, Subpart B. On March 30, 2000, the DOT revised 49 CFR 193 to incorporate the 1996 

edition of NFPA 59A into the LNG regulations. On April 9, 2004, the DOT further revised 49 

CFR 193 to incorporate the 2001 edition of NFPA 59A. The following sections specifically 

address siting requirements: 

• Part 193.2001, Scope of part, excludes any matter other than siting provisions

pertaining to marine cargo transfer systems between the marine vessel and the last 

manifold or valve immediately before a storage tank. 

• Part 193.2051, Scope, states that each LNG facility designed, replaced, relocated or 

significantly altered after March 31, 2000, must be provided with siting requirements in 

accordance with subpart B and NFPA 59A, 2001 edition. In the event of a conflict with 

NFPA 59A, then Part 193 prevails. 

• Part 193.2057, Thermal radiation protection, requires that each LNG container and 

LNG transfer system have thermal exclusion zones based on three radiation flux levels in 

accordance with Section 2.2.3.2 of NFPA 59A, 2001 edition. 

• Part 193.2059, Flammable vapor-gas dispersion protection, requires that each LNG 

container and LNG transfer system have a dispersion exclusion zone in accordance with 

sections 2.2.3.3 and 2.2.3.4 of NFPA 59A, 2001 edition. 

• Part 193.2155(b), Structural requirements, requires that an LNG storage tank must be 

at least 1 mile from the ends of an airport runway and 1⁄4 mile from the nearest point on a 

runway. 
 4-197 4.0 – Environmental Impact Analysis 

For the following LNG facilities that are proposed in this project, we have identified the 

applicable siting requirements from Part 193 and NFPA 59A, 2001 edition: 

• Two 1,257,000-barrel LNG storage tanks - Parts 193.2057 and 2059 require the 

establishment of thermal and flammable vapor exclusion zones for LNG tanks. NFPA 

59A, 2001 edition, Section 2.2.3.2 specifies four thermal exclusion zones based on the 

design spill and the impounding area. Sections 2.2.3.3 and 2.2.3.4 specify a flammable 

vapor exclusion zone for the design spill which is determined in Section 2.2.3.5. Part 

193.2155(b) specifies that the LNG storage tanks must be at least 1 mile from the ends of 

an airport runway and 1⁄4 mile from the nearest point on a runway. The proposed site 

would comply with 49 CFR 193.2155(b). 

• Modifications to the cargo transfer system consisting of one additional 16-inch-diameter 

unloading arm and an increase in the size of the unloading line from 30-inch to 36-inchdiameter - Parts 193.2001, 2057, and 2059 require thermal and flammable vapor 

exclusion zones for the transfer system. NFPA 59A, 2001 edition, does not address LNG 

transfer systems. 

• Four 3,100 gpm first-stage pumps and six 1,600 gpm secondary pumps - Parts 193.2057 

and 2059 require thermal radiation and flammable vapor exclusion zones. NFPA 59A, 

2001 edition, Section 2.2.3.2 specifies the thermal exclusion zone and Sections 2.2.3.3 

and 2.2.3.4 specify the flammable vapor exclusion zone based on the design spill in a 

process area. 

• Six 180 MMscfd submerged combustion vaporizers - Same requirements as for LNG 

pumps. 

The incorporation of the NFPA 59A requirements into Part 193 has resulted in some confusion 

and possible misinterpretation in applying the siting requirements. Parts 193.2057 and 2059 

require exclusion zones for LNG transfer systems, which are defined to include transfer piping. 

However, NFPA 59A only requires exclusion zones for “transfer areas” which are defined as the 

part of the plant where liquids are introduced or removed from the facility such as truck loading 

or vessel unloading areas. The definition of transfer area in NFPA 59A specifically excludes 

permanent plant piping such as cargo transfer lines. Additionally, NFPA 59A Section 2.2.3.1 

specifically excludes transfer area at the water edge of marine terminals. When the DOT 

originally incorporated NFPA 59A into its regulations, it removed the requirement for 

impounding systems around transfer piping (old Part 193.2149). In the preamble to the final 

rule, the DOT determined that the most likely sources of leaks within an LNG plant are LNG 

storage tanks, cargo transfer areas, and vaporizers and process equipment, which are all 

addressed in NFPA 59A Section 2.2.1.2. The result is that while Part 193 retains exclusion 

zones for LNG transfer systems, neither Part 193 nor NFPA 59A requires the impoundment from 

which to base the calculations. We do not believe that this was the intent, nor do we believe that 

omitting containment for transfer piping is a sound engineering practice. The FERC staff will 

continue to require containment for all LNG transfer piping within a plant site. 

The incorporation of NFPA 59A also changed the way in which design spills and impoundment 

capacities may be determined. Under Section 2.2.2.2, the capacity of impounding areas for 

vaporization, process, or LNG transfer areas must equal the greatest volume during a 10-minute 
 4-198 4.0 – Environmental Impact Analysis 

period from any single accidental leakage source or during a shorter time period based upon 

demonstrable surveillance and shutdown provisions acceptable to the authority having 

jurisdiction. Similar criteria appear in Section 2.2.3.5 for determining the design spill used in 

thermal and flammable vapor exclusion zone calculations. Prior to the incorporation of NFPA 

59A the design spill in Part 193 assumed the rupture of a single transfer pipe with the greatest 

overall flow capacity, for not less than 10 minutes (old Part 193.2059(d)). As a result, the spill 

rate for vaporization, process, or LNG transfer areas may be assumed to be a "leakage source" 

rather than a full pipe rupture; however, the spill duration must be 10 minutes unless the 

authority having jurisdiction (i.e., DOT’s OPS), determines that a shorter time is acceptable. 

Again, given the confusion in applying the two requirements, the FERC staff will continue to 

utilize the 10-minute spill criteria at the maximum flow possible for containment sizing. This 

will ensure that impoundments are sized for a catastrophic failure, while recognizing that less 

conservative spill scenarios may be appropriate to calculate exclusion zones. In giving 

recognition to the integrity of all-welded transfer piping, the determination of the single 

accidental leakage source should be based on an evaluation of all small diameter attachments to 

the transfer piping for instrumentation, pressure relief, recirculation, etc., and any flanges that 

may be used at valves or other equipment, in order to determine the largest spill rate. This 

approach is the result of discussion with DOT’s OPS concerning the basis for design spills and 

application to exclusion zone determinations for proposals before the Commission. 

Impoundment Systems and Design Spills

Part 193.2181 specifies that the impoundment system serving a single LNG storage tank must 

have a volumetric capacity of 110 percent of the LNG tank’s maximum liquid capacity. 

Southern LNG proposes to install an earthen dike around each storage tank, which would have a 

surface area of 550,050 ft2 and an average height of 15.5 ft. Both tank D-5 and D-6 would have a 

maximum design liquid capacity of approximately 52,834,410 gallons each. After accounting 

for the estimated space occupied by features inside each dike, the available dike volume would 

be 60,787,610 gallons. This would provide impoundment for approximately 115 percent of each 

inner tank’s maximum design liquid volume. The proposed earthen dikes for both Tank D-5 and 

D-6 would comply with part 193.2181. 

Potential LNG spills occurring from each storage tank withdrawal header would be directed 

through an earthen trough to a sump located within the dike surrounding each tank. In 

accordance with Section 2.2.3.5 of NFPA 59A, 2001 edition, the design spill for an LNG storage 

tank with penetrations below the liquid level with internal shut off valves is defined as the flow 

through an assumed opening at, and equal in area to, that penetration below the liquid level that 

could result in the largest flow from an initially full container for a 1 hour period. The 24-inchdiameter bottom fill line on both Tank D-5 and D-6 would represent the opening with the largest 

potential flow. Using the formula specified in Section 2.2.3.5 of NFPA 59A, 2001 edition, the 

maximum flow rate from this opening would be 58,572 gallons per minute, which would result 

in a total 1-hour spill volume of approximately 3,514,348 gallons. Each tank area sump would 

have overall dimensions of approximately 400-foot square with two sloped walls and a 3-foot 

depth and would provide a containment capacity of approximately 3,519,270 gallons. The tank 

area sumps for both Tank D-5 and D-6 would each be adequate to contain the total 1-hour spill 

volume specified in Section 2.2.3.5 of NFPA, 2001 edition. Rainwater collected in the sumps 
 4-199 4.0 – Environmental Impact Analysis 

would be pumped out by permanently installed sump pumps that would be automatically 

activated by a level switch and would also be interlocked with a temperature switch to prevent 

operation in the event of an LNG spill. 

Any potential spills from the sendout line piping between the new LNG storage tanks and the 

new vaporizer/pump area would be captured either by Retention Area 2, an existing sump 

located just north of the existing tank dikes that is proposed to be expanded, or by Retention 

Area 3, a new sump that would be located approximately 110 feet west of Retention Area 2. The 

maximum flow rate in this sendout line piping would be 7,530 gallons per minute, corresponding 

to a 10-minute spill volume of 75,300 gallons. Retention Area 3 would be 70 feet square with 

sloping walls to provide containment for about 84,385 gallons. Retention Area 2 would be 

deepened and extended to have overall dimensions of 87 feet by 60 feet by 3 feet deep. This 

revised sump would create an impoundment capacity of approximately 93,873 gallons. Both 

Retention Area 2 and Retention Area 3 would be capable of containing a full rupture of the 

sendout line piping for 10-minutes. 

The new secondary LNG pumps and the new vaporizers would be located within curbed areas 

which would be sloped to drain into existing spillways leading to Retention Area 2. The 

maximum flow rate in this sendout line piping would be 8,209 gallons per minute, corresponding 

to a 10-minute spill volume of 82,095 gallons. The expanded Retention Area 2 would be capable 

of containing this spill. 

Rainwater collected in both Retention Area 2 and Retention Area 3 would be pumped out by 

permanently installed sump pumps that would be automatically activated by a level switch and 

would also be interlocked with a temperature switch to prevent operation in the event of an LNG 

spill.

Southern LNG selected the failure of a 4-inch-diameter pump recycle line connection on the 

discharge piping of a secondary LNG pump as the accidental leakage source for the process area, 

which is a curbed area containing process equipment such as the pumps and vaporizers. 

However, an evaluation of all small diameter attachments to piping in the process area 

determined that a failure of the 6-inch diameter recirculation line connection on the secondary 

pump discharge header would be a more appropriate single accidental leakage source. Due to 

the high pressure in the header, the highest design flow rate from this source would result in a 

10-minute design spill of 82,095 gallons. Both Retention Area 2 and Retention Area 3 would be 

capable of containing a spill of this size. However, this spill would not be able to reach 

Retention Area 3, and no other flanges or fittings exist as a source of a design spill for Retention 

Area 3. 

The new LNG unloading line would be located within earthen impoundments. A full rupture of 

the unloading line flowing for 10 minutes would equal a total spill of approximately 500,272 

gallons. Depending on the location of the potential leak, this spill would be contained by either 

the existing North Loading Dock Sump, the existing D-2 LNG tank dike, the existing Retention 

Area 1, or one of the tank area sumps for the proposed LNG tanks. All of these impoundments 

would have the capacity to contain this 500,272 gallon spill. 
 4-200 4.0 – Environmental Impact Analysis 

Southern LNG selected a full break of the unloading line as the accidental leakage source for this 

line. An evaluation of all small diameter attachments to the transfer piping for instrumentation, 

pressure relief, recirculation, etc., and any flanges that may be used at valves or other equipment, 

determined that a failure of the 6-inch-diameter attachment to the unloading line would be an 

appropriate single accidental leakage source. Depending on the location of the potential leak, 

this design spill of 136,050 gallons would be contained by either the existing North Loading 

Dock Sump, the existing D-2 LNG tank dike, the existing Retention Area 1, or one of the tank 

area sumps for the proposed LNG tanks. Each of the existing impoundments was previously 

analyzed and approved to contain a larger design spill. Therefore, only the tank area sumps need 

to be considered in the current exclusion zone analysis. 

 

Table 4.12.3-1 presents the impounding area and spill size volume for the various spill scenarios. 

Where applicable, Southern LNG oversized each impoundment to accommodate the drainage 

from affected piping and the potential increase in pump flow due to pressure loss in the system. 

The largest design spill collected by a given sump would be used to calculate exclusion zones for 

that sump. 

TABLE 4.12.3-1 

Impoundment Areas 

Source Spill Size 

(gallons) Impoundment System Impoundment Size 

(gallons) 

Impoundment sizing spills: 

LNG storage tank 52,834,410 Tank Dike 60,787,610 

LNG tank bottom penetration 3,514,348 Tank Dike Sump 3,519,270 

Primary pump discharge 75,302 

 75,302 

 75,302 

Tank Dike Sump 

Retention Area 3 

Retention Area 2 

3,519,270 

84,385 

93,873 

Secondary pump discharge header 82,095 Retention Area 2 93,873 

Vessel unloading line 500,272 

 500,272 

 500,272 

 500,272 

Existing North Loading Dock Sump 

Existing Retention Area 1 

Existing Dike for Tank D-2

Tank Dike Sump 

1,224,000 

1,122,078 

16,801,247 

3,519,270 

Design spills: 

LNG tank bottom penetration 3,514,348 Tank Dike Sump 3,519,270 

Secondary pump discharge header 

– 6” connection 

82,095 Retention Area 2 93,873 

Vessel unloading line - 6" connection 136,050 Tank Dike Sump 3,519,270 

Thermal Exclusion Zone

If a large quantity of LNG is spilled in the presence of an ignition source, the resulting pool fire 

would produce high levels of radiant heat in the area surrounding the impoundment. Exclusion 

distances for various flux levels were calculated according to 49 CFR 193.2057 and Section 

2.2.3.2 of NFPA 59A, 2001 edition, using the "LNGFIRE III" computer program model 

developed by the Gas Research Institute. NFPA 59A, 2001 edition, establishes certain 
 4-201 4.0 – Environmental Impact Analysis 

atmospheric conditions (0 mph wind speed, 70°F, and 50 percent relative humidity) which are to 

be used in calculating the distances. However, Part 193.2057 supercedes these requirements and 

stipulates that the wind speed, ambient temperature, and relative humidity which produce the 

maximum exclusion distances must be used, except for conditions that occur less than 5 percent 

of the time based on recorded data for the area. For its analysis, Southern LNG selected the 

following ambient conditions to produce the maximum distances: wind speed of 15 mph; 

ambient temperature of 45°F; and 50 percent relative humidity. These conditions yield longer 

distances than the 0 mph wind speed, 70°F ambient temperature, and 50 percent relative 

humidity specified in NFPA 59A, 2001 edition. FERC staff agrees with Southern LNG’s 

selection of atmospheric conditions. 

Using these ambient criteria, FERC staff calculated thermal radiation distances for incident flux 

levels ranging from 1,600 to 10,000 Btu/ft2

-hr for a pool fire in each LNG storage tank dike. 

The tank D-5 dike would not be perfectly rectangular as would the proposed shape of the tank D6 dike. Since LNGFIRE III is capable of modeling only rectangles or circles, staff modeled the 

irregularly-shaped tank D-5 dike as a rectangle, keeping the greatest width of the dike constant 

and adjusting the dike length to maintain the actual surface area. This method produced the 

longest thermal radiation distances beyond the western property line. The full surface area at the 

top of the dike was used in the calculations while the flame base was set to the average height of 

the dike wall, 15.5 feet. Target height was set at ground level (0 feet). 

Thermal radiation distances were also determined for 1,600 Btu/ft2

-hr incident flux levels 

centered on each tank dike sump and the expanded Retention Area 2. These were found to be in 

compliance with thermal radiation protection regulations in 193.2057. In addition, all other 

existing impoundments used for containment in the Elba III Terminal Expansion project have 

been previously analyzed for thermal radiation, have not changed in surface area, and have been 

found to be acceptable. 

Although no flanges or fittings exist as a source of a design spill for Retention Area 3, its 

capacity and surface area would be similar to that of the adjacent Retention Area 2, indicating 

that the thermal radiation exclusion zones calculated for Retention Area 2 would also represent 

the potential hazards associated with Retention Area 3. Since Retention Area 3 would be located 

between Retention Area 2 and the larger tank D-6 sump, which are both closer to off-site 

property, any potential exclusion zone from Retention Area 3 would not be expected to extend 

beyond the exclusion zones for those impoundments. 

Table 4.12.3-2 presents the calculated maximum distances for incident flux levels ranging from 

1,600 to 10,000 Btu/ft2

-hr as calculated by FERC staff. 

The exclusion zones in table 4.12.3-2 are measured from the center of each impoundment. The 

centers of the tank dikes and tank dike sumps would be located approximately 800 and 600 feet, 

respectively, from the South Channel. Therefore, portions of the thermal exclusion zones for 

each of those incident flux levels listed in table 4.12.3-2 would extend over the South Channel. 

The 1,600 Btu/ft2

-hr exclusion zone for the tank dikes would also extend approximately 150 feet 

over the Savannah River on the north side of the site. For these reasons, a recommendation has 

been added in section 4.12.5, Emergency Response and Evacuation Plan, to ensure that 
 4-202 4.0 – Environmental Impact Analysis 

recreational boaters would be warned in the unlikely event that a potential exists for fire in any 

of these impoundments. 

TABLE 4.12.3-2 

Thermal Exclusion Zones 

Source 

Exclusion Area NFPA 59A 

Section 2.2.3.2(a) 

Incident Flux 

(Btu/ft2 hr) a/ 

Exclusion 

Zone (feet) b/ 

Retention Area 2 Property line that can be built upon. 1,600 362 

LNG tank dike sump Property line that can be built upon. 1,600 1,406 

LNG storage tank D-5 dike Outdoor assembly area occupied by 50 or more people. 1,600 2,314* 

LNG storage tank D-5 dike Offsite structures used for occupancies or residences. 3,000 1,825 

LNG storage tank D-5 dike Property line that can be built upon. 10,000 1,155 

LNG storage tank D-6 dike Outdoor assembly area occupied by 50 or more people. 1,600 2,270 

LNG storage tank D-6 dike Offsite structures used for occupancies or residences. 3,000 1,778 

LNG storage tank D-6 dike Property line that can be built upon. 10,000 1,112 

______________________________________________________ 

a/ The 1,600 Btu/ft2-hr flux level is associated with an exposed person experiencing burns within about 30 seconds. At 

3,000 Btu/ft2

-hr, an exposed person would experience burns within 10 seconds, however a wooden structure would not 

be expected to burn and affords protection to sheltered persons. At 10,000 Btu/ft2

-hr, clothing and wood can ignite 

spontaneously. 

b/ Exclusion zone distances are measured from the center of the impoundment. For rectangular sumps, the longest 

exclusion zone distance is listed. 

* The short side of the rectangular tank D-5 dike would be facing the nearest offsite property. The exclusion zone 

distance for this side of the tank D-5 dike would be 2,271 feet. 

As noted in Table 4.12.3-2, the 1,600 Btu/ft2

-hr exclusion zone from a tank dike may not extend 

over an existing outdoor assembly area occupied by 50 or more people. In addition, 49 CFR 

193.2007 specifies that the operator or a government agency must legally control all activities 

within an exclusion zone in accordance with 193.2057 and 193.2059 for as long as the facility is 

in operation. 

In the case of the tank D-5 and D-6 dikes, the 1,600 Btu/ft2

-hr zone would extend across the 

South Channel and over approximately 450 feet of coastal wetlands owned by the state of 

Georgia. Control of activities on this property rests with the US Army Corps of Engineers under 

Section 404 of the Clean Water Act, 33 USC 1344, and the State of Georgia under the Coastal 

Marshlands Protection Act, Georgia Code Ann. 12-5-280 et seq. Southern LNG states that under 

the terms of section 12-5-288(a) of the Georgia Code, a permit for any development in this area 

could only be granted in highly unusual circumstances, and section 12-5-288(b) of the Georgia 

Code indicates that the filling of marshlands for residential, commercial, and industrial uses is 

considered to be contrary to the public interest. Southern LNG also owns and controls the only 

access road to this remote area. 

On July 10 and July 11, 2007, Southern LNG filed information provided to the Georgia 

Department of Natural Resources which identified the coastal marshlands contained within the 
 4-203 4.0 – Environmental Impact Analysis 

exclusion zones and indicated that Southern LNG would oppose any permit application for 

development activities in those areas in order to comply with its exclusion zone requirements. 

We believe the thermal radiation exclusion zones for the Elba III Expansion project would 

comply with the regulations in 49 CFR 193.2007 and 193.2057.

Vapor Dispersion Zone

A large quantity of LNG spilled without ignition would form a flammable vapor cloud that 

would travel with the prevailing wind until it either dispersed below the flammable limits or 

encountered an ignition source. Sections 2.2.3.3 and 2.2.3.4 of NFPA 59A, 2001 edition, and 

Part 193.2059 require that provisions be made to minimize the possibility of flammable vapors 

from reaching a property line that can be built upon and that would result in a distinct hazard. 

Part 193.2059 requires that dispersion distances be calculated for a 2.5 percent average gas 

concentration (1⁄2 the lower flammability limit [LFL] of LNG vapor) under meteorological 

conditions which result in the longest downwind distances at least 90 percent of the time. 

Alternatively, maximum downwind distances may be estimated for stability Class F, a wind 

speed of 4.5 mph, 50 percent relative humidity, and the average regional temperature. The 

section allows the use of the DEGADIS Dense Gas Dispersion Model, or the FEM3A model, to 

compute dispersion distances. Design spills into impounding areas serving LNG containers, 

transfer systems and piping are to be determined in accordance with Section 2.2.3.5 of NFPA 

59A, 2001 edition. 

Southern LNG’s application contained a vapor dispersion analysis for the D-5 and D-6 tank dike 

sumps and Retention Area 2. An average regional temperature of 66.2° F, 50 percent relative 

humidity, and 4.5 miles per hour wind speed were used as input conditions. We agree with 

Southern LNG’s selection of atmospheric conditions. 

The largest design spill that would be directed to Retention Area 2 would come from a 6-inchdiameter connection to the new secondary pump discharge header. The design spill rate from a 

6-inch-diameter attachment to this header would be 8,209 gallons per minute. Using this spill 

rate and the specifications provided for the impoundment, staff calculated a distance of 

approximately 984 feet to the 2.5 percent average gas concentration isopleth for the expanded 

Retention Area 2. Based on this distance, the flammable vapor exclusion zone associated with 

this sump would not cross any property line that could be built upon and would therefore comply 

with the regulations in part 193.2059. 

Although no flanges or fittings exist as a source of a design spill for Retention Area 3, its 

capacity and surface area would be similar to that of the adjacent Retention Area 2, indicating 

that the vapor dispersion exclusion zones calculated for Retention Area 2 would also represent 

the potential hazards associated with Retention Area 3. Since Retention Area 3 would be located 

between Retention Area 2 and the larger tank D6 sump, which are both closer to off-site 

property, any potential exclusion zone from Retention Area 3 would not be expected to extend 

beyond the exclusion zones for those impoundments. 
 4-204 4.0 – Environmental Impact Analysis 

As shown in Table 4.12.3-1, the largest design spill that would be directed to each of the 

proposed tank dike sumps would come from the LNG storage tank bottom fill piping. Using the 

formula specified in Section 2.2.3.5 of NFPA 59A, the maximum flow rate from this opening 

would be approximately 58,572 gallons per minute. Using this spill rate and the specifications 

provided by Southern LNG for the D-5 and D-6 tank dike sumps, staff calculated a distance of 

approximately 2,218 feet from the center of each dike to the 2.5 percent average gas 

concentration isopleth. 

Flammable vapor dispersion modeling is intended to be performed for spill scenarios in which 

the vapor generated from a spill overflows the impoundment during the time that the spill is 

occurring. In this case, vapor is calculated to overflow the dike 34 minutes after the start of the 

60 minute spill, which is consistent with accepted practice. 

Because the exclusion zone would extend over the South Channel, a recommendation has been 

added in section 4.12.5, Emergency Response and Evacuation Plan, to ensure that recreational 

boaters would be warned in the unlikely event that LNG vapor may disperse over the waterway. 

In accordance with federal regulations, the flammable vapor exclusion zone from either tank 

impoundment may not extend over a property that can be built upon. In addition, 49 CFR 

193.2007 specifies that the operator or a government agency must legally control all activities 

within an exclusion zone in accordance with 193.2057 and 193.2059 for as long as the facility is 

in operation. 

In the case of the tank D-5 and D-6 dikes, the flammable vapor exclusion zone would extend 

across the South Channel and over approximately 400 feet of coastal wetlands owned by the 

state of Georgia. Control of activities on this property rests with the US Army Corps of 

Engineers and the State of Georgia. Under the terms of the Georgia Code, permits for any 

development in this area could only be granted in highly unusual circumstances, and as discussed 

in the previous section, Thermal Exclusion Zones, Southern LNG has communicated to the 

Georgia Department of Natural Resources that it would oppose any permit applications for 

development activities in this area in order to comply with its exclusion zone requirements. We 

believe the vapor dispersion exclusion zones for the Elba III Expansion project would comply 

with the regulations in 49 CFR 193.2007 and 193.2059. 

4.12.4 LNG Vessel Safety 

Since 1959, LNG has been transported by vessel without a major release of cargo or a major 

accident involving an LNG vessel. Over the last 45 years, LNG vessels have made over 44,000 

voyages worldwide. Starting in 1971, LNG began arriving at the Distrigas facility in Everett, 

Massachusetts. To date, more than 680 cargoes, with volumes ranging from 60,000 to 125,000 

m3, have been delivered into the Port of Boston without incident. During 2005, a total of 241 

cargoes of LNG were imported into the United States. For 35 years, LNG shipping operations 

have been safely conducted in the United States. 
 4-205 4.0 – Environmental Impact Analysis 

LNG imports to Elba Island have steadily increased since operations recommenced. Between the 

end of 2001 through the end of 2006, the Terminal has received 177 cargoes delivering over 446 

Bcf of natural gas. 

4.12.4.1 History 

During the 44,000 voyages that have been completed since the inception of LNG maritime 

transportation, there has not been a serious accident at sea or in a port which resulted in a spill 

due to rupturing of the cargo tanks. However, insurance records, industry sources, and public 

websites identify a number of incidents involving LNG vessels, including minor collisions with 

other vessels of all sizes, groundings, minor LNG releases during cargo unloading operations, 

and mechanical/equipment failures typical of large vessels. Some of the more significant LNG 

vessel incidents are described below: 

• Pollenger had an LNG spill onto the steel cover of cargo tank number one during 

unloading at Everett, Massachusetts in April 1979. The spill caused cracking of the steel 

plate. 

• El Paso Paul Kayser grounded on a rock in June 1979 in the Straits of Gibraltar during a 

loaded voyage from Algeria to the United States. Extensive bottom damage to the ballast 

tanks resulted; however, the cargo tanks were not damaged, and no cargo was released. 

The complete cargo of LNG was subsequently transferred to another LNG vessel and 

delivered to its United States destination. 

• LNG Taurus grounded in December 1980 near the entrance to Taboata Harbor, Japan. 

The grounding resulted in extensive bottom damage, but the cargo tanks were not 

affected. The vessel was refloated and the cargo unloaded. 

• Isabella had LNG spill onto its deck due to a cargo tank overflow in June 1985, causing 

severe cracking of the steelwork. The spill had been attributed to a cargo valve failure 

during discharging of cargo. 

• Tellier was blown by severe winds from its docking berth at Skikda, Algeria in February 

1989 causing damage to the loading arms and the vessel and shore piping. The cargo 

loading had been secured just before the wind struck, but the loading arms had not been 

drained. Consequently, the LNG remaining in the loading arms spilled onto the deck 

causing fracture of some plating. 

• Mostefa Ben Boulaid had LNG spill onto its deck during loading operations in Algeria 

in 2002. The spill, which is believed to have been caused by overflow rather than a 

mechanical failure, caused significant brittle fracturing of the steelwork. The vessel was 

required to discharge its cargo, after which it proceeded to dock for repair. 

• Khannur had a cargo tank overfill into the vessel’s vapor handling system on September 

10, 2001, during unloading at Everett, Massachusetts. Approximately 100 gallons of 

LNG were vented and sprayed onto the protective decking over the cargo tank dome, 

resulting in several cracks. After re-inspection by the Coast Guard, the Khannur was 

allowed to discharge its LNG cargo. 

• Norman Lady was struck by the USS Oklahoma City nuclear submarine while the 

submarine was rising to periscope depth near the Strait of Gibraltar in November 2002. 

The 87,000-m3 LNG vessel, which had just unloaded its cargo at Barcelona, Spain, 
 4-206 4.0 – Environmental Impact Analysis 

sustained only minor damage to the outer layer of its double hull but no damage to its 

cargo tanks. 

• Tenaga Lima grounded on rocks while proceeding to open sea east of Mopko, South 

Korea due to strong current in November 2004. The shell plating was torn open and 

fractured over an approximate area of 20 feet by 80 feet, and internal breaches allowed 

water to enter the insulation space between the primary and secondary membranes. The 

vessel was refloated, repaired, and returned to service. 

• Golar Freeze moved away from its docking berth during unloading on March 14, 2006, 

in Savannah, Georgia. The powered emergency release couplings on the unloading arms 

activated as designed, and transfer operations were shut down. 

As noted above, an incident occurred at the Terminal in March 2006 during the unloading of the 

LNG vessel, the Golar Freeze. The Golar Freeze was pulled 15 feet from the South Dock by 

surge from a vessel passing well in excess of the minimum safe speed limit imposed by the Coast 

Guard. The automated “proximity indicator” switches actuated as designed and initiated the 

berth’s ESD system and closed the powered emergency release coupler valves, which prevented 

release of the LNG. Although four of the mooring lines parted, the remaining twelve lines held 

the vessel until the two standby tractor tugs returned it to the dock. Following an investigation 

into the matter, the Coast Guard filed an administrative action against the Federal Pilot on board 

the passing vessel. 

Since the Golar Freeze incident occurred at the Terminal, the Coast Guard and Southern LNG 

have examined ways to prevent the potential for a similar incident to occur again, particularly 

with the proposed use of larger LNG vessels. On January 19, 2007, the Coast Guard published 

an Interim Rule in the Federal Register to modify the Regulated Navigation Area (RNA) for the 

Savannah River (33 CFR Part 165.756). The Coast Guard modified the language in the RNA to 

eliminate any confusion that passing vessels must make every effort to minimize their surge as 

they pass the LNG facility slip where an LNG tankkship is moored. The Coast Guard would 

continue to require two standby tugs while an LNG vessel is moored to assist either the passing 

vessel or the moored LNG vessel. This Interim Rule went into effect on February 20, 2007 and 

the Coast Guard received comments until March 20, 2007. 

4.12.4.2 LNG Vessel Construction 

LNG vessels with cargo capacities of 145,000 m3

 are typical of the current LNG vessels the Elba 

Island Terminal receives. At the completion of the Project it is proposed that Q-Max vessels 

with a LNG cargo capacity of 266,000 m3 will be offloaded at the terminal. The relative 

dimensions of two LNG vessels that could be used to transport LNG to the Terminal are shown 

in table 4.12.4-1. Typical membrane and spherical LNG vessels are shown in figure 4 12-1. 
Non-Internet Public 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED ELBA III PROJECT 

Docket Nos. CP06-470-000, CP06-471-000, CP06-472-000, 

CP06-473-000, and CP06-474-000 

Page 4-207 

Figure 4.12-1 

Typical Designs for an LNG Vessel 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 
 4-208 4.0 – Environmental Impact Analysis 

TABLE 4.12.4-1 

Typical LNG Vessel Characteristics 

 Existing Vessels Future Vessels 

Specifications 145,000 m3 266,000 m3

Length (m) 277.2 303.0 

Breadth (m) 43.4 50.0 

Loaded Draft (m) 12.3 12.5 

Hull Depth (m) 26 27 

Loaded Displacement (Tonnes) 116,941 151,599 

In 1980, at the initial peak of LNG import activity in the United States, the Coast Guard 

published the report Liquefied Natural Gas and Liquefied Petroleum Gas – Views and Practices 

– Policy and Safety. The report summarized the Coast Guard’s extensive research into the safety 

hazards of LNG and its view that “...the nature of both LNG and LPG presents an acceptable risk 

for transportation in maritime commerce.” This is due to the fact that LNG vessels are well 

constructed, robust vessels designed to withstand low-energy-type incidents that are prevalent in 

harbors and during docking operations. Moreover, safety measures, both equipment and training, 

are planned and designed into these LNG vessels to prevent or control all types of potential 

incidents. The Sandia National laboratory reached a similar conclusion in 2005 in its report. 

The world’s LNG vessel fleet currently exceeds 173 vessels. Currently, all of the vessels in the 

LNG fleet operate under a foreign flag with foreign crews. The LNG vessels used to import 

LNG to the United States would be constructed and operated in accordance with the International 

Maritime Organization’s (IMO) Code for the Construction and Equipment of Ships Carrying 

Liquefied Gases in Bulk, the International Convention for the Safety of Life at Sea (SOLAS), and 

46 CFR Part 154, which contain the United States safety standards for vessels carrying bulk 

liquefied natural gas. Foreign flag LNG vessels are required to possess a valid IMO Certificate of 

Fitness and a Coast Guard Certificate of Compliance. 

As required by the IMO conventions and design standards, hold spaces and insulation areas on 

an LNG vessel are equipped with gas detection and low temperature alarms. These devices 

monitor for leaks of LNG into the insulation between primary and secondary LNG cargo tank 

barriers. In addition, hazard detection systems are also provided to monitor the hull structure 

adjacent to the cargo tank, compressor rooms, motor rooms, cargo control rooms, enclosed 

spaces in the cargo area, specific ventilation hoods and gas ducts, and air locks. 

LNG vessels are equipped with a firewater system with the ability to supply at least two jets of 

water to any part of the deck in the cargo area and parts of the cargo containment and tank covers 

above-deck. A water spray system is also available for cooling, fire prevention, and crew 

protection in specific areas. In addition, certain areas of LNG vessels are fitted with dry chemical 

powder-type extinguishing systems and carbon dioxide (CO2) smothering systems for fighting 

fires. 
 4-209 4.0 – Environmental Impact Analysis 

In 1993, amendments to the IMO’s Code for the Construction and Equipment of Ships Carrying 

Dangerous Chemicals in Bulk require all vessels to have monitoring equipment with an alarm 

facility which is activated by detection of over-pressure or under-pressure conditions within a 

cargo tank. In addition, the cargo tanks are heavily instrumented, with gas detection equipment 

in the hold and inter-barrier spaces, temperature sensors, and pressure gauges. Fire protection 

must include the following systems: 

• a water spray (deluge) system that covers the accommodation house control room and all 

main cargo valves; 

• a traditional firewater system that provides water to fire monitors on deck and to fire 

stations found throughout the vessel; 

• a dry chemical fire extinguishing system for hydrocarbon fires; and 

• a CO2 system for protecting machinery including the ballast pump room, emergency 

generators, and compressors. 

As a result of the terrorist attacks that occurred on September 11, 2001, the IMO agreed to new 

amendments to the 1974 SOLAS addressing port facility and vessel security. The International 

Ship and Port Facility Security (ISPS) Code was adopted in 2003 by the IMO. This code requires 

both vessels and ports to conduct vulnerability assessments and to develop security plans. The 

purpose of the code is to prevent and suppress terrorism against vessels; improve security aboard 

vessels and ashore; and reduce the risk of passengers, crew, and port personnel on board vessels 

and in port areas, for vessels and cargoes. All LNG vessels as well as other cargo vessels 300 

gross tons and larger, and ports servicing those regulated vessels, must adhere to these IMO and 

SOLAS standards. Some of the IMO requirements are as follows: 

For Vessels:

• Vessels must develop security plans and have a Vessel Security Officer (VSO); 

• Vessels must be provided with a vessel security alert system. These alarms transmit shipto-shore security alerts to a competent authority designated by the Administration, which 

may include the company, identifying the vessel, its location, and indication that the 

security of the vessel is under threat or has been compromised; 

• Vessels must have a comprehensive security plan for international port facilities, focusing 

on areas having direct contact with vessels; and 

• Vessels may have certain equipment onboard to help maintain or enhance the physical 

security of the vessel. 

For port facilities:

• Port facility security plan; 

• Facility Security Officer (FSO); and 

• Certain security equipment may be required to maintain or enhance the physical security 

of the facility. 

For both vessels and ports:

• Monitoring and controlling access; 

• Monitoring activities of people and cargo; 

• Ensuring security communications and that they are readily available; and 

• Completion of a Declaration of Security that is signed by the FSO and VSO.
 4-210 4.0 – Environmental Impact Analysis 

4.12.4.3 Hazards 

The history of LNG shipping has been free of major incidents, and none have resulted in 

significant quantities of cargo being released (see section 4.12.4.1). No incidents have occurred 

at existing LNG terminals during the 50 years of operation that resulted in any significant 

quantities of cargoes being released. However, the possibility of an LNG spill from a vessel over 

the duration of the proposed project must be considered. Historically, the events most likely to 

cause a substantial release of LNG were a vessel casualty such as: 

• A grounding sufficiently severe to puncture an LNG cargo tank; 

• A vessel colliding with an LNG vessel in transit; 

• An LNG vessel alliding28 with the terminal or a structure in the waterway; or 

• A vessel alliding with an LNG vessel while moored at the terminal. 

However, the attacks on September 11, 2001, have made the public keenly aware of an 

additional risk that must be considered in the evaluation of marine safety and security: 

• A deliberate attack on an LNG vessel by a terrorist group. 

To result in a spill of LNG, any of the above events would need to occur with sufficient impact 

to breach an LNG vessel’s double hull and cargo tanks. All LNG vessels used to deliver LNG to 

the proposed Project would have double-hull construction, with the inner and outer hulls 

separated by about 10 feet. Furthermore, the cargo tanks are normally separated from the inner 

hull by a layer of insulation approximately 1-foot thick. 

As a result, many grounding incidents severe enough to cause a cargo spill on a single-bottom oil 

vessels would be unable to penetrate both inner and outer hulls of an LNG vessel. An earlier 

Federal Power Commission (FPC) (predecessor to the FERC) study estimated that the doublebottom of an LNG vessel would be sufficient to prevent cargo tank penetration in about 85 

percent of the cases that penetrated a single-bottom oil vessel. Previous incidents with LNG 

vessels have primarily involved grounding, and none of these have resulted in the breach of the 

double hull and subsequent release of LNG cargo. 

The likelihood of an LNG vessel sustaining cargo tank damage in a collision would depend on 

several factors – the displacement and construction of both the struck and striking vessels, the 

velocity of the striking vessel and its angle of impact with the struck vessel, and the location of 

the point of impact. The previous FPC study estimated that the additional protection afforded by 

the double hull would be effective in low-energy collisions; overall, it would prevent cargo tank 

penetration in about 25 percent of the cases that penetrated a single-hull oil vessel. 

 

28 “Alliding” is the action of dashing against or striking upon a stationary object (for example, the running of one 

ship upon another ship that is docked) – distinguished from “collision,” which is used to refer to two moving ships 

striking one another. 
 4-211 4.0 – Environmental Impact Analysis 

In 1995, to assist the Coast Guard in San Juan, Puerto Rico, EcoEléctrica L.P. prepared an 

analysis of the damage that could result from an oil vessel striking an LNG vessel at berth 

(FERC, 1996). The analysis assumed a 125,000 m3 LNG vessel and an 82,000-dead-weight-ton 

vessel carrying number 6 fuel oil without tug assistance. The analysis determined the minimum 

striking speed to penetrate the cargo tanks of an LNG vessel for a range of potential collision 

angles. The resulting minimum striking speeds are presented in table 4.12.4-2 for the two 

principal cargo systems. 

TABLE 4.12.4-2

Minimum Striking Speed to Penetrate LNG Cargo Tanks 

Minimum Striking Speed (knots) Angle of Impact Spherical Tanks Membrane Tanks 

Greater than 60 degrees 4.5 3.0 

45 degrees 6.3 4.0 

30 degrees 9.0 6.0 

15 degrees 18.0 12.0 

For membrane tanks, the critical beam-on striking speed is 3.0 knots; for spherical tanks, the 

critical beam-on speed is 4.5 knots. For both containment types, lower angles of impact result in 

much greater minimum striking speeds to penetrate LNG cargo tanks. In the July/August 2002 

issue of the “LNG Journal,” the SIGTTO General Manager provides a table that indicates the 

critical speed necessary for a 20,000-ton vessel to puncture the outer hull of an LNG vessel is 7.3 

knots. For a 93,000-ton vessel, the impact speed is 3.2 knots. In neither case does such an impact 

result in damage to the LNG cargo containment system, nor does it result in release of LNG. 

The DOE has released a study by Sandia National Laboratories entitled, Guidance on Risk 

Analysis and Safety Implications of a Large Liquefied Natural Gas (LNG) Spill Over Water 

(Sandia Report) December 2004. The Sandia Report included an LNG cargo tank breach analysis 

using modern finite element modeling and explosive shock physics modeling to estimate a range 

of breach sizes for both credible accidental and intentional LNG spill events. The analysis of 

accidental events found that groundings, collisions with small vessels and low-speed (less than 7 

knots) collisions with large vessels striking at 90 degrees could cause minor vessel damage but 

would not result in a cargo spill. This is due to the protection provided by the double-hull 

structure, the insulation layer, and the primary cargo tank of an LNG vessel. High-speed (12 

knots) collisions with large vessels striking at 90 degrees were found to potentially cause cargo 

tank breach areas of 0.5 to 1.5 m2

. 

In the event of a collision or allision of sufficient magnitude to rupture an LNG cargo tank, it is 

likely that sparks or flames would ignite the flammable vapors at the spill site. In a grounding of 

sufficient magnitude to rupture an LNG cargo tank, the damage would occur underwater, and the 

potential for ignition would be less than for collisions or allisions. In this case, an LNG spill 

would rapidly vaporize on water and form a potentially flammable cloud. If not ignited, the 

flammable vapor cloud would drift downwind until the effects of dispersion would dilute the 

vapors below the LFL for methane. The maximum range of potentially flammable vapors, or the 

distance to the LFL, is a function of the volume of LNG spilled, the rate of the spill, and the 
 4-212 4.0 – Environmental Impact Analysis 

prevailing meteorological conditions. If the flammable vapor cloud encountered an ignition 

source, the cloud would burn back to the spill site. 

The final EIS for the Calcasieu LNG Project (FERC, 1976) analyzed the maximum range of a 

flammable vapor cloud and hazardous radiation levels from an instantaneous one-tank spill. As 

was consistent with risk analyses at that time and for nearly 25 years thereafter, the instantaneous 

spillage of one cargo tank was considered to be the “worst-case” scenario. Physical constraints 

on maximum vessel speeds and maximum depths of penetration required to rupture one LNG 

cargo tank render the possibility of an instantaneous release of more than one cargo tank to be 

implausible. This is not to imply that the loss of multiple cargo tanks could never occur, but that 

the extent of the hazard would not exceed that of the instantaneous spillage of one tank. 

For an instantaneous one-tank spill with ignition, the final EIS for the Calcasieu LNG Project 

estimated that a hazardous thermal radiation level of 5,300 Btu/ft2

-hr would extend 3,595 feet 

from the center of the spill. For an instantaneous one-tank spill without ignition, the final EIS for 

the Yukon Pacific LNG Project (FERC, 1995) estimated that potentially flammable vapors could 

travel up to 3.3 miles, with a 10-mph wind and typical atmospheric stability. 

In October 2001, the use of a one-tank instantaneous release as the worst-case scenario was 

reexamined by Quest Consultants, Inc (Quest) as part of an effort by the DOE to determine the 

hazards associated with reopening the Distrigas LNG import terminal following the terrorist 

attacks of September 11, 2001. It was determined that time-release spills through 1-meter and 5-

meter diameter holes would more accurately simulate credible worst-case damage scenarios. 

The maximum flammable vapor cloud and radiation hazards were calculated for the two spill 

scenarios. For a spill on water with ignition, the maximum distance to a radiant flux level of 

1,500 Btu/ft2

-hr was estimated to be 1,770 feet. For a spill on water without ignition, a 

flammable vapor cloud of 2.5 miles was estimated. In November 2003, in response to comments 

concerning its October 2001 study, Quest clarified that its study applied only to LNG spills 

resulting from a collision with a large vessel in Boston’s Outer Harbor, where waves would 

restrict the spreading of LNG on water. 

Since the Quest study, there has been an emergence of studies by various parties to define the 

worst-case scenario that would result from a deliberate terrorist attack on an LNG vessel and the 

subsequent release of cargo. Distances have been estimated to range from 1,770 to 4,200 feet for 

a thermal radiation level of 1,500 Btu/ft2

-hr. Part of the reason for the apparent discrepancies is 

the lack of large-scale historical incidents, and the need to extrapolate small-scale field test data 

to a worst-case event. This inevitably leads to differing conservative assumptions among the 

various parties. For example, some models calculate a time-release cargo discharge through 1-

meter or 5-meter diameter holes, while others assume that the cargo tank empties 

instantaneously. 

As a result, the FERC commissioned a study by ABSG Consulting Inc. (ABSG) to search and 

review the literature on experimental LNG spills and on consequence methodologies that are 

applicable to modeling incidents of LNG spills on water. Further, the goal of the study was to 

identify appropriate methods for estimating flammable vapor and thermal radiation hazard 

distances for potential LNG vessel cargo releases during transit and while at berth. The resulting 
 4-213 4.0 – Environmental Impact Analysis 

study, Consequence Assessment Methods for Incidents Involving Releases from Liquefied 

Natural Gas Carriers, was released for public comment on May 14, 2004. On June 18, 2004, 

staff’s responses to comments on the consequence assessment methods were issued. In addition, 

the model was updated to include a lower limit on the characteristic wind speed. As discussed in 

greater detail in staff’s responses, various components of the consequence assessment 

methodologies were revised based on comments received. The revised methodology provides 

procedures for calculating: (1) the rate of release of LNG from a cargo tank penetration for 

various-sized holes; (2) the spreading of an unconfined LNG pool on water for both continuous 

spills and rapid (nearly instantaneous) releases; (3) the rate of vapor generation from an 

unconfined spill on water; (4) thermal radiation distances for LNG pool fires on water; and (5) 

flammable vapor dispersion distances. 

A detailed evaluation of the consequences of a terrorist attack on a modern membrane LNG 

vessel was prepared by Lloyds Register North America for the Weaver’s Cove LNG Project. The 

study evaluated the consequences of attacks on an LNG vessel by missiles and explosives. Finite 

element analysis was used to evaluate the effect of various-sized charges on both the outer and 

inner hulls. A 1-meter diameter hole of the inner hull at the waterline was found to be the worstcase scenario for hazard consequence assessments. This finding is consistent with the attack on 

the double-hull oil vessel Limberg which caused greater than a 5-meter diameter hole on the 

outer hull, but only minor damage to the inner hull. A failure modes and effects analysis was 

used to understand internal LNG release characteristics, and a residual strength analysis was used 

to investigate damage scenarios for a loaded LNG vessel. 

As discussed above, the Sandia Report included an LNG cargo tank breach analysis, using 

modern finite element modeling and explosive shock physics modeling to estimate a range of 

breach sizes for credible accidental and intentional LNG spill events. For intentional scenarios, 

the size of the cargo tank hole depends on the location of the vessel and source of threat. 

Intentional breach areas were estimated to range from 2 to 12 m2

. In most cases, an intentional 

breaching scenario would not result in a nominal hole of more than 5 to 7 m2, which is a more 

appropriate range to use in calculating potential hazards from spills. These hole sizes are 

equivalent to circular hole diameters of 2.5 and 3 meters. 

The Sandia Report also included guidance on risk management for intentional spills, based on 

the findings that the most significant impacts to public safety and property exist within 

approximately 500 meters (1,640 feet) of a spill due to thermal hazards from a fire, with lower 

public health and safety impacts beyond 1,600 meters (approximately 1 mile). Large unignited 

LNG vapor releases were found to be unlikely, but could extend from nominally 2,500 meters 

(8,200 feet) to a conservative maximum distance of 3,500 meters (11,500 feet) for an intentional 

spill. As part of the waterway suitability review process, the Coast Guard uses these criteria 

developed by Sandia to define the outer limits of the hazard zones for assessing potential risks 

associated with the proposal. Cascading damage due to brittle fracture from exposure to 

cryogenic liquid or fire-induced damage to foam insulation was evaluated and, while possible 

under certain conditions, is not likely to involve more than two or three cargo tanks. Cascading 

events are not expected to increase the overall fire hazard by more than 20 to 30 percent (1,920 

to 2,080 meters [6,300 to 6,825 feet]) but would increase the expected fire duration. RPTs are 
 4-214 4.0 – Environmental Impact Analysis 

possible for large spills, but the effects would be localized near the spill source and should not 

cause extensive structural damage. 

The methodology described in the ABSG study and revised in staff’s responses to comments was 

also used by FERC staff to calculate the thermal radiation and flammable vapor dispersion 

distances for several holes ranging in diameter from 1 meter to 3.9 meters. Based on the 

penetration of the largest cargo tank of a 140,000-m3

 LNG vessel, a potential spill of 23,000 m3

is estimated for the volume of LNG above the waterline. The estimated pool spread results and 

thermal radiation hazard distances are identified in table 4.12.4-3. Thermal radiation calculations 

are based on an ambient temperature of 45°F, a relative humidity of 50 percent, and a 15-mph 

wind speed. 

TABLE 4.12.4-3 

LNG Spills on Water from a 140,000 m3

 LNG Vessel (using the ABSG model) 

LNG Release and Spread 

Hole area 0.8 m2 1.5 m2 5.0 m2 7.0 m2 12.0 m2

Hole Diameter 1.0 m 1.4 m 2.5 m 3.0 m 3.9 m 

Spill Time 92.3 min 49.2 min 14.8 min 10.5 min 6.1 min 

Pool Fire Calculations 

Maximum Pool Radius 343 ft 471 ft 822 ft 936 ft 1,104 ft 

Fire Duration 92.4 min 49.3 min 15.0 min 10.8 min 6.5 min 

Distance to: 

1,600 Btu/ft2-hr 2,154 ft 2,729 ft 4,149 ft 4,576 ft 5,181 ft 

3,000 Btu/ft2-hr 1,664 ft 2,100 ft 3,175 ft 3,499 ft 3,957 ft 

10,000 Btu/ft2-hr 975 ft 1,236 ft 1,854 ft 2,039 ft 2,303 ft 

Flammable vapor dispersion calculations were based on an ambient temperature of 66.2 oF, 

50 percent relative humidity, a 4.5-mph wind speed and atmospheric stability Class F. Based on 

a 1-meter diameter cargo tank breach in a 140,000 m3 LNG vessel, an unignited release would 

result in an estimated pool radius of 421 feet. The unignited vapor cloud would extend to 11,340 

feet to the LFL and 15,688 feet to one-half the LFL. It is important to identify certain key 

assumptions of conditions that must exist in order to achieve these vapor cloud distances. First it 

would be necessary for an event to create a 1-meter diameter hole by penetrating the outer hull, 

the inner hull, and cargo containment without ignition. Far more credible is that the event 

creating a 1-meter diameter hole would also result in a number of ignition sources which would 

lead to an LNG pool fire and subsequent thermal radiation hazards. It is also unlikely that a 

flammable vapor cloud could achieve these distances over land surfaces without encountering an 

ignition source, and subsequently burning back to the source. 

For the Project, Southern LNG proposes to receive LNG vessels with capacities up to 266,000 

m3. Because the Sandia Report is based on smaller LNG vessels with a capacity of 125,000 m3, 

and may not sufficiently address potential risks associated with the future generation LNG 

vessels, the Coast Guard COTP Savannah required that Southern LNG conduct a site-specific 

analysis of these future generation LNG vessels. With Coast Guard involvement, Southern LNG 

contracted Det Norske Veritas to perform a vulnerability evaluation and consequence analysis 

(DNV Report) for the larger LNG vessel. The DNV Report used multiple pool fire and vapor 
 4-215 4.0 – Environmental Impact Analysis 

cloud scenarios with variable hole sizes (intentional and accidental), number of tanks breached, 

LNG discharge rates, atmospheric conditions, and the distances to Lower Flammable Limits. On 

September 6, 2006, Southern LNG submitted the DNV Report entitled Elba Island: Approach to 

LNG Consequence Modeling to the Coast Guard Headquarters Office of Vessel and Facility 

Operating Standards for evaluation and official acceptance. On September 25, 2006, Coast 

Guard Headquarters responded via letter that the DNV Report is “acceptable for addressing the 

modeling gaps that exist between the quantities of LNG carried on vessels included in the Sandia 

Report of December 2004 and those of future LNG vessels currently being designed and 

considered for use in conjunction with the expansion project at Elba Island.” 

The results of the DNV Report are summarized below. Based on the penetration of the largest 

cargo tank of a 266,000 m3

 LNG vessel, a potential spill of 39,500 m3 is estimated for the volume 

of LNG above the waterline. For a scenario producing a 5 m2 hole in a single cargo tank at 0.5 

meter above the waterline, the largest distance to thermal hazards of 5 kW/m2

 (approximately 

1,600 Btu/ft2

-hr) was calculated to be 1,200 meters (3,937 feet). The largest distance to thermal 

hazards of 37.5 kW/m2

 (approximately 12,000 Btu/ft2-hr) was calculated to be 500 meters (1,640 

feet). The largest flammable vapor dispersion distance due to an intentional breach (5 m2 hole) 

was calculated to be 3,300 meters (10,827 feet). The DNV Report, like the Sandia Report, 

considered a large vapor dispersion scenario highly unlikely due to the high probability of the 

presence of an immediate ignition source for the intentional breach scenarios. Additional vapor 

cloud and pool fire scenarios were modeled as requested by the Coast Guard Vessel & Facility 

Operating Standards Division, based on recommendations from DOE’s Sandia National 

Laboratories. 

As identified in Southern LNG’s Waterway Suitability Report (see section 4.12.4.5), the Zones 

of Concern for the larger 266,000 m3

 LNG vessels were established using the guidance provided 

in the Sandia Report and the results of the DNV Report. The Zones of Conern were determined 

to be: 

• Zone 1 – impacts on structures and organisms are expected to be significant within 798 

meters (2,620 feet). The outer perimeter of Zone 1 is the distance to thermal hazards of 

37.5 kW/m2

 from a pool fire. 

• Zone 2 – impacts would be significant but reduced, and damage from radiant heat levels 

are expected to transition from severe to minimal between 798 and 2,019 meters (2,620 

and 6,625 feet). The outer perimeter of Zone 2 is the distance to thermal hazards of 5 

kW/m2

 from a pool fire. 

• Zone 3 – impacts on people and property from a pool fire or an unignited LNG spill that 

does not ignite are expected to be minimal between 2,019 meters (6,625 feet) and a 

conservative maximum distance of 3,500 meters (11,500 feet). The outer perimeter of 

Zone 3 should be considered the vapor cloud dispersion distance to the LFL from a worst 

case unignited release. Impacts to people and property could be significant if the vapor 

cloud reaches an ignition source and burns back to the source. 

The severity of impacts within Zones 1 through 3 would depend on the location of the incident 

relative to a specific area, the scope of the incident, and whether the released LNG ignited or 

dispersed. This could be a significant impact, being most severe in Zone 1 and decreasing 
 4-216 4.0 – Environmental Impact Analysis 

outward through Zones 2 and 3. However, because of the implementation of safety and security 

measures during marine transit, the likelihood of a marine LNG spill is extremely remote. 

LNG vessels would traverse primarily offshore waters with the exception of approximately 7.1 

miles of the Savannah River navigation channel. The LNG vessel would transit the channel at a 

speed of 9 to 11 knots, resulting in areas within the Zones of Concern being exposed to a 

potential transient thermal hazard for up to 15 minutes (see figures 4.12-2 and 4.12-3). In 

addition, a temporary hazard would exist around the slip during part of the 12 to 14-hour period 

while the LNG vessel is at the dock and unloading cargo. 

An accidental spill from an LNG vessel is unlikely due to the channel characteristics and the 

operational controls that would be imposed by the Coast Guard. Along the transit route the 

Savannah River bottom is composed of mud and sand with no known natural hazards. The 

possibility of collisions and allisions would be minimized since the LNG vessel would be under 

pilot control and have a tug escort about 5 miles from the entrance to the Savannah River. The 

potential for other vessels to collide with an LNG vessel would be further reduced due to the 

Coast Guard’s moving safety zone around LNG vessels. In addition, the potential for an LNG 

vessel to allide with other moored vessels or structures is very low, since the only berth areas 

along the transit route are an abandoned lash facility, the bar pilots dock, and Coast Guard 

Station Tybee. All other Port facilities are upstream of the LNG terminal. 

As stated previously, the analysis of accidental events in the Sandia Report found that 

groundings, collisions with small vessels and low-speed (less than 7 knots) collisions with large 

vessels striking at 90 degrees could cause minor vessel damage but would not result in a cargo 

spill. High-speed (12 knots) collisions with large vessels striking at 90 degrees were found to 

potentially cause cargo tank breach areas of 0.5 to 1.5 m2

. Based on the smaller hole sizes from 

an accidental marine LNG spill, the transient hazard area from and ignited or unignited 

accidental spill would be within the Zones of Concern described above. 

As stated in the Coast Guard’s Waterway Suitability Report to FERC (see section 4.12.4.5), 2000 

census data was used to identify population areas potentially affected by the Zones of Concern 

along each transit route segment. Other than Tybee Island, both sides of the river from its mouth 

to Elba Island are generally undeveloped and consist of marsh, dredged material disposal sites, 

and other uninhabited waterfront areas. Tybee Island has a medium population density (1,000 to 

9,000 persons per square mile) for both permanent residences and its recreational use during the 

summer months. Numerous residences, commercial business, and outside use areas on the 

northern half of Tybee Island would be located within both Zones 2 and 3. There are no schools 

or hospitals located within Zones 2 or 3 on Tybee Island. 

Taalahi and Wilmington Islands also have medium population densities; however, the population 

centers for both of these tracts are located outside the Zones of Concern. A small number of 

residences in these areas are located within Zone 3. 

The transit for any vessel entering the Savannah River requires passage by Tybee National 

Wildlife Refuge and Fort Pulaski National Monument. A portion of Cockspur Island (adjacent 
Non-Internet Public 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED ELBA III PROJECT 

Docket Nos. CP06-470-000, CP06-471-000, CP06-472-000, 

CP06-473-000, and CP06-474-000 

Page 4-217 

Figure 4.12-2 

Environmental Resources Along LNG Transit Route – 

Onshore Portion 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 
Non-Internet Public 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED ELBA III PROJECT 

Docket Nos. CP06-470-000, CP06-471-000, CP06-472-000, 

CP06-473-000, and CP06-474-000 

Page 4-218 

Figure 4.12-3 

Environmental Resources Along LNG Transit Route – 

Offshore Portion 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 
 4-219 4.0 – Environmental Impact Analysis 

to the shipping channel) would be within Zone 1, where the remainder would be with Zone 2. 

Fort Pulaski (open to the public), the Savannah River Pilot’s boat dock facility, and Coast Guard 

Station Tybee are located on Cockspur Island. 

The potential impact on the infrastructure and industrial development in Zone 1 was also 

evaluated. A thermal radiation level of 10,000 Btu/ft2-hr is associated with potential damage to 

equipment and infrastructure. A fire associated with a potential spill resulting from a nominal 

cargo tank hole of an intentional event could expose the LNG storage tanks at the Terminal to a 

thermal radiation level of 10,000 Btu/ft2

-hr for up to 20 minutes. Depending on the duration of 

the incident, damage to the LNG storage tanks at the Terminal could compound the event. 

However the thermal exclusion zones for the LNG storage tank impoundments (see section 

4.12.3) would be well within Zone 2 from the initial ignited marine spill. 

These intentional breach scenarios provide guidance to the Coast Guard in developing the 

operating restrictions for LNG vessel movements in the waterway, as well as in establishing 

potential impact areas for emergency response and evacuation planning. By focusing on the 

“worst-case” scenario for LNG transportation, there is a tendency to dismiss the potential 

hazards for other fuels and products commonly transported on our waterways. Some of the 

previously identified studies that calculate long hazard distances for LNG cargo fires also 

estimate similarly long distances for gasoline, propane, and jet fuel cargo fires. Also, it should 

not be assumed that the hazard distances identified are the assured outcome of an LNG vessel 

accident or attack, given the conservatisms in the models and the level of damage required to 

yield such large scale releases. Further, these “worst-case” intentional breach scenarios should 

not be misconstrued as defining an exclusionary zone. Rather the average most probable “worstcase” scenarios provide guidance in developing the operating restrictions for LNG vessel 

movements in the Savannah River navigation channel, as well as in establishing potential impact 

areas for emergency response and evacuation planning. The Coast Guard currently authorizes 

and would continue to authorize the inbound and outbound transit of each LNG vessel calling on 

the Terminal. 

The operational restrictions to be imposed by the Coast Guard and local pilots, as well as the 

requirements of the RNA and the Coast Guard’s Savannah Area LNG Vessel Management and 

Emergency Plan, on LNG vessel movements through the Savannah River navigation channel, 

would minimize the possibility of a hazardous event occurring along the vessel transit. Based on 

the extensive operational experience of LNG shipping and the structural design of an LNG 

vessel, the likelihood of a cargo containment failure and subsequent LNG spill from a vessel 

casualty – collision, grounding, or allision – is highly unlikely. In addition, given the navigation 

controls and safety and security procedures in place to specifically prevent such accidents and 

intentional spill scenarios, the likelihood of these scenarios occuring is extremely remote and 

therefore, are not likely to result in significant impacts. 

4.12.4.4 LNG Vessel Transit to the Elba Island Terminal 

Imported LNG could be obtained from exporting terminals throughout the world and delivered 

by LNG vessels to the proposed Project. Exporting countries include Algeria, Australia, Brunei, 

Indonesia, Malaysia, Nigeria, Oman, Qatar, Trinidad, and United Arab Emirates. In 2003, LNG 
 4-220 4.0 – Environmental Impact Analysis 

imports to the United States included: 72 percent from Trinidad, 12 percent from Nigeria, 10 

percent from Algeria, 3 percent from Qatar, 2 percent from Oman, and 1 percent from Malaysia. 

Southern LNG expects to source LNG supplies from the Middle East for the proposed 

expansion. 

The Port of Savannah includes all waters and adjacent waterfront from the entrance of the 

Savannah River upstream to the US Route 17 (Houlihan) Highway Bridge located at river mile 

21.3 including the cities of Savannah, Garden City, and Port Wentworth. The Savannah River is 

navigable for deep-draft vessels to the upper end of Savannah Harbor, 19 miles above the outer 

ends of the entrance jetties, and for barges to the city of Augusta, 172 miles above the entrance. 

The waterway for LNG marine traffic and access to the Terminal berthing slip on the Savannah 

River are free of natural hazards, including reefs, rocks, and sandbars. 

The Port of Savannah is currently the nation’s fourth largest container port and second largest on 

the east coast. The largest terminal operator in the Savannah Harbor is the Georgia Ports 

Authority, which operates the Ocean Terminal for breakbulk cargo and the Garden City Terminal 

for containerized cargo. Other major products and industries of the port include petroleum 

products, roll on-roll off (RO-RO) shipments, kaolin clay, wood products, and various 

chemicals. The port is also 1 of 13 strategic ports in the United States and is regularly used to 

assist in the mobilization of the Army’s 3rd Infantry Division. The Savannah Riverfront is a 

downtown historic area with considerable tourist and entertainment activity. 

As discussed in section 4.9.7, the largest development located within the Terminal Expansion 

Zones of Concern is located in the western end of Zone 3 and consists of two existing industrial 

facilities with over 300 employees combined. No other major critical infrastructure, including 

nuclear power plants, refineries, major bridges and tunnels, or major industrial areas of 

importance are located within the Zones of Concern (see figure 4.9-1). 

From the territorial sea, LNG vessels would transit the Port of Savannah, as they currently do, 

through the Savannah River to the Terminal. LNG vessels transit from the Savannah River Sea 

Buoy (Tybee Lighted Buoy T) to the Elba Island LNG terminal is 18 miles, with Elba Island 

being the first facility deep-draft vessels encounter during inbound transit. The entrance to the 

Savannah River (Gated Buoys 1 and 2) is 600 feet wide and dredged and maintained to a depth 

of -44 feet MLW. These waterway dimensions remain in place until Tybee Knoll Range (Buoys 

17 and 18), where the width of the channel decreases to 500 feet and the depth is dredged and 

maintained to -42 feet MLW. These dimensions remain in place from Tybee Knoll Range to the 

Elba Island LNG terminal. 

The COE is responsible for the operation and maintenance of the Federal Savannah Harbor 

Navigation Project. In 1994, the Savannah District completed the Savannah Harbor deepening 

project, deepening the main navigation channel from –38 to –40 feet MLW. In 1999, the U.S. 

Congress, in the 1999 Water Resources Development Act, conditionally authorized further 

deepening the channel to a maximum depth of 48 feet, contingent upon the completion of a Tier 

II EIS, a final mitigation plan, and an incremental analysis of the channel depths from 42 to 48 

feet. This deepening would aid in the transit of deep-draft container vessels, which must 

presently transit the river only at high tide or enter the harbor less than fully laden. The COE is 
 4-221 4.0 – Environmental Impact Analysis 

the lead agency for this effort, and the Georgia Ports Authority is a cooperating agency. 

Presently, work is ongoing on the scientific studies and modeling efforts necessary to produce 

the Tier II EIS and General Reevaluation Report. 

Southern LNG has constructed a new turning basin across from the Terminal, pursuant to the 

Coast Guard and FERC requirements. The turning basin would continue providing greater depth 

and clearance past the Terminal and facilitate maneuvers into and out of the slip. 

The distance from the mouth of the harbor to the Terminal is about 7 miles. The Atlantic 

Intracoastal Waterway crosses the Savannah River approximately 1.5 miles below the Terminal 

and 9 miles below the primary Port area. There are no bridges during the transit to Elba Island. 

There is no anchorage in the Savannah River except in an emergency. Most vessels anchor to 

the north or northwest of the sea buoy, where depths range from 19 to 45 feet. Waterfront 

facilities along the portion of the Savannah River from the Atlantic Ocean to the Terminal 

include: 

• Bar Pilots Dock located 0.5 mile upriver from the mouth of the Savannah River on the 

south side of the channel; 

• Georgia Ports Authority Lash Facility (abandoned) located 0.5 miles upriver from the 

mouth of the Savannah River on the north side of the channel; and 

• Coast Guard Station Tybee Island Dock located 1 mile upriver from the mouth of the 

Savannah River on the south side of the channel. 

Numerous factors affect the ability of any commercial vessel (including LNG vessels) to get 

underway. These factors include tide restrictions; the availability of river pilots, docking pilots 

and tugs; weather; visibility; shore crews; and berth space. The Savannah River is influenced by 

oceanic tides, which have an effect on the depth of the river channel and also the speed and 

direction of the river current. Deep-hulled cargo vessels cannot navigate the Savannah River 

satisfactorily at low tide. LNG vessels need a minimal current to safely and efficiently dock off 

river in the Elba Island berthing slip. Fog from time to time prevents all commercial traffic from 

moving up or down the Savannah River, and winds (exceeding about 25 knots for LNG vessels 

and 35 knots for other commercial traffic) may also impede or temporarily stop the movement of 

commercial vessels. Large vessels require the aid of tugs to perform certain maneuvers in the 

harbor area, such as docking at Elba Island or in commercial cargo unloading berths. The above 

factors are considered and the management of vessel movements within the port is coordinated 

between the shipping interests, the pilots, and the Coast Guard. 

A maneuverability simulation study was commissioned by Shell Trading (U.S.) Company (Shell) 

and conducted at Marine Safety Institute in Rhode Island, November 9-11, 2005. This study was 

performed using a 264,000 m3

 LNG vessel with an overall length of 1,132 feet. These values are 

consistent with those presently being considered for construction. The Shell study was 

conducted using a full mission simulator, and 22 simulations were conducted over a 3.5-day 

period. Significant conclusions of the evaluation team were: 

• It is feasible to navigate the simulated 264,000 m3 membrane LNG vessel to and from the 

Terminal mooring basin; 
 4-222 4.0 – Environmental Impact Analysis 

• The Terminal mooring basin would accommodate the simulated 264,000 m3

 membrane 

LNG vessel at either berth with a similar sized LNG vessel at the opposite berth; 

• The turning basin, adjacent to the Terminal mooring basin, is adequate for turning the 

simulated 264,000 m3

 membrane LNG vessel for entry into, or departure from, the 

mooring basin; and 

• The turning basin is adequate for either bow-in or bow-out approaches to either berth. 

There are also a number of safeguards in place for current LNG marine traffic on the Savannah 

River that will remain in place following the proposed expansion. As port-wide experience with 

LNG deliveries has increased, these safeguards have been evaluated through discussions with 

port stakeholders and updated to maintain safety and security risk mitigation while minimizing 

impact to port mobility. When Southern LNG was recommissioned in 2001, COTP Savannah 

instituted a RNA (33 CFR Part 165.756) outlining the requirements for all vessels transiting the 

Savannah River when an LNG vessel is within the geographic limits of the RNA (the Savannah 

River between Fort Jackson and the Savannah River Channel Entrance Sea Buoy). Changes to 

the RNA are discussed further in section 4.12.4.5. In addition to the requirements of the RNA, 

the entire process for LNG vessel arrivals is outlined in the Coast Guard’s Savannah Area LNG 

Vessel Management and Emergency Plan. This plan is designed to ensure the safety of all 

operations associated with LNG vessel transit and unloading. The plan outlines the series of 

events that must occur when an LNG vessel calls on the Terminal and specify LNG waterfront 

facility requirements, cargo transfer operations, Coast Guard inspection and monitoring 

requirements, and emergency operations. These procedures would be applied to the additional 

LNG vessels that would be unloaded as part of the proposed Project. 

In summary, the sequence of events followed by LNG vessels per the Savannah Area LNG 

Vessel Management and Emergency Plan includes the following: 

• The vessel’s master, agent or authorized representative notifies the COTP 96 hours prior 

to entry into the Port. 

• As the LNG vessel arrives off the entrance to the Savannah River, any pre-arrival checks 

would be completed prior to beginning the vessel’s transit to the Terminal. At the 

discretion of the COTP, the LNG vessel may be boarded and inspected by Coast Guard 

MSU personnel. 

• At a point approximately 15 miles from the sea buoy, which is approximately 5 miles 

southeast of Tybee Island, the pilot and tug join the vessel. 

• After the vessel has completed all required pre-arrival inspections and has complied with 

the Port of Savannah Minimum Under-Keel Clearance Guidelines, the vessel transit 

would begin. 

• Southern LNG expects that its customer would continue to arrange for tug escorts for the 

LNG vessels during transit, unloading, and for berth maneuvers. 

• If indicated by weather conditions, additional tugs may be required to moor the LNG 

vessel during the docking maneuver, and the tugs would remain with the vessel until it is 

properly moored. 

The Terminal slip/dock arrangement allows the LNG vessels to unload LNG from either the port 

or starboard side mooring and moves the LNG vessels away from and nearly perpendicular to the 
 4-223 4.0 – Environmental Impact Analysis 

edge of the main vessel channel while they are unloading LNG. This slip orientation affords a 

greater level of safety and security for LNG vessels and for shipping in general within the Port of 

Savannah. 

After docking, if foreign flagships are being utilized, certain government formalities (i.e., 

Customs and Immigration) would be completed before any vessel operations can begin. When 

the LNG vessel is cleared, a series of pre-transfer conferences and inspections would be held, 

including the following: 

• Any required Coast Guard inspection of vessel, if not completed before transit. 

• Pre-transfer conference between the vessel and Southern LNG and completion of the 

vessel/shore safety checklist, completion of the Declaration of Security, verification of 

the vessel/shore ESD connection, and verification of the vessel/shore communication 

system. 

• Custody transfer of the LNG cargo. 

• Connecting the vessel to the shore piping. 

LNG cargo then would be pumped to the LNG storage tanks. The cargo discharge operation 

would take approximately 12 to 14 hours depending on the size of the vessel. During the cargo 

transfer, the vessel’s staff would stay in constant contact with the Terminal’s staff. When the 

cargo pumping operations are completed, the vessel/shore systems would be disconnected and 

final custody transfer procedures and cargo/vessel-related formalities would be completed. 

Upon arrival of the tugs and pilot, the vessel would undock and begin its transit to the sea buoy. 

Multiple tugs would be required to undock the vessels. The entire estimated average time to 

complete the process normally would range between 24 and 32 hours, depending on the cargo 

and offloading capacity of the vessel. This time includes transit from the sea buoy, unloading, 

and return to the sea buoy. 

The Savannah area is susceptible to hurricanes and tropical storms. During pre-hurricane 

conditions when the area is threatened by these storms, the COTP may restrict or limit the 

transfer of LNG and the movement of LNG vessels. In accordance with the COTPs Heavy 

Weather Plan, no transfer of LNG products or transits of LNG vessels would be allowed at least 

24-36 hours before gale force winds (34 mph) are expected offshore of Savannah. This control 

is applied to facilitate the closing of the Port to inbound marine traffic and to provide conditions 

which allow vessels to transit clear of offshore storms should it become necessary to evacuate 

the Port. 

4.12.4.5 Requirements for LNG Operations in the Savannah River 

The Coast Guard exercises regulatory authority over LNG facilities that affect the safety and 

security of port areas and navigable waterways under Executive Order 10173; the Magnuson Act 

(50 USC Section 191); the Ports and Waterways Safety Act of 1972, as amended (33 USC 

Section 1221, et seq.); and the Maritime Transportation Security Act of 2002 (46 USC Section 

701). The Coast Guard is responsible for matters related to navigation safety, vessel engineering 

and safety standards, and all matters pertaining to the safety of facilities or equipment located in 
 4-224 4.0 – Environmental Impact Analysis 

or adjacent to navigable waters up to the last valve immediately before the receiving tanks. The 

Coast Guard also has authority for LNG facility security plan review, approval and compliance 

verification as provided in Title 33 CFR Part 105, and siting as it pertains to the management of 

vessel traffic in and around the LNG facility. 

The Coast Guard regulations in 33 CFR 127 apply to the marine transfer area of waterfront 

facilities between the LNG vessel and the last manifold or valve located immediately before a 

storage tank. Title 33 CFR 127 regulates the design, construction, equipment, operations, 

inspections, maintenance, testing, personnel training, firefighting, and security of LNG 

waterfront facilities. The safety systems, including communications, ESD, gas detection, and fire 

protection, must comply with the regulations in 33 CFR 127. Under 33 CFR 127.019, Southern 

LNG would be required to submit two copies of its Operations and Emergency Manuals to the 

COTP for examination. 

Title 33 CFR 127 separates cargo transfer operations into three distinct phases: Preliminary 

Transfer Inspection (Section 127.315); Declaration of Inspection (Section 127.317); and LNG 

Transfer (Section 127.319). These different sections require specific actions to be completed 

prior to and during the transfer. Additionally, there are specific actions required in the case of a 

release of LNG (Section 127.321). 

As required by its regulations (Section 127.009), the Coast Guard is responsible for issuing a 

LOR as to the suitability of the waterway for LNG marine traffic with respect to the following 

items: 

• information submitted under Section 127.007: 

o the physical location of the facility; 

o a description of the facility; 

o the LNG vessels’ characteristics and the frequency of LNG shipments to or from 

the facility; and 

o charts showing waterway channels and identifying commercial, industrial, 

environmentally sensitive, and residential areas in and adjacent to the waterway 

used by the LNG vessels en route to the facility, within 25 kilometers (15.5 miles) 

of the facility. 

• density and character of marine traffic; 

• locks, bridges, or other manmade obstructions in the waterway; and 

• the following factors adjacent to the facility: 

o depth of water; 

o tidal range; 

o protection from high seas; 

o natural hazards, including reefs, rocks, and sandbars; 

o underwater pipes and cables; and 

o distance of berthed vessels from the channel and the width of the channel. 

On June 14, 2005, the Coast Guard published a Navigation and Vessel Inspection Circular – 

Guidance on Assessing the Suitability of a Waterway for Liquefied Natural Gas (LNG) Marine 

Traffic (NVIC 05-05). The purpose of NVIC 05-05 is to provide Coast Guard COTPs/Federal 
 4-225 4.0 – Environmental Impact Analysis 

MARSEC Coordinators (FMSC), members of the LNG industry, and port stakeholders with 

guidance on assessing the suitability of a waterway for LNG marine traffic that takes into 

account conventional navigation safety/waterway management issues contemplated by the 

existing LOI/LOR process, but in addition, would also take completely into account MARSEC 

implications. In accordance with this guidance, each LNG project applicant is to submit a WSA 

to the cognizant COTP. The WSA process addresses the transportation of LNG from an LNG 

vessel’s entrance into U.S. territorial waters, through its transit to and from the LNG receiving 

facility, including operations at the LNG vessel/facility interface. In addition, the WSA should 

address the navigational safety issues and port security issues introduced by the proposed LNG 

operations. The NVIC 05-05 also provides specific guidance on the timing and scope of the 

WSA. 

The process of preparing the LOR begins when an applicant submits a LOI to the COTP. In 

accordance with 33 CFR 127.007, Southern LNG submitted a LOI to the Coast Guard on 

January 12, 2006 (see appendix L). As is the case for current LNG marine traffic, the arrival, 

transit, cargo transfer, and departure of LNG vessels would be required to adhere to the 

procedures of the Savannah Area LNG Vessel Management and Emergency Plan developed by 

the Coast Guard COTP Savannah. In addition, Southern LNG uses existing Operations and 

Emergency Manuals developed in consultation with the Coast Guard. These procedures would 

be revised for the proposed expansion and would ensure the safety and security of all operations 

associated with LNG vessel transit and unloading. The Savannah Area LNG Vessel Management 

and Emergency Plan contains specific requirements for the LNG vessel, pre-arrival notification, 

transit through shipping channels, the waterfront facility, cargo transfer operations, Coast Guard 

inspection and monitoring activities, and emergency operations. The Coast Guard COTP 

Savannah would monitor each LNG vessel in accordance with the Savannah Area LNG Vessel 

Management and Emergency Plan. This plan would be updated as needed for the proposed 

operations. 

Regulated Navigation Area (RNA)

When Southern LNG was recommissioned in 2001, COTP Savannah instituted a RNA (33 CFR 

Part 165.756) outlining the requirements for all vessels transiting the Savannah River when an 

LNG vessel is within the geographic limits of the RNA (the Savannah River between Fort 

Jackson and the Savannah River Channel Entrance Sea Buoy). When originally enacted, COTP 

Savannah did not allow any vessels over 1,600 gross tons within the boundaries of the RNA 

when an LNG vessel was transiting. As the Coast Guard, Southern LNG, the Savannah River 

Pilots, and the local tug operators gained experience in the safety and security aspects of LNG 

vessel arrivals, the RNA was revised multiple times to improve port mobility during LNG 

operations while not increasing associated safety and security risks. 

When the new dual berthing facilities in the off-river slip at the Terminal was placed into 

service, the RNA was again revised to account for the different possible mooring configurations 

and to remove several requirements based on the additional level of safety the slip provides. A 

Notice of Proposed Rulemaking was published for public comment and additional changes were 

made after considering this feedback. 
 4-226 4.0 – Environmental Impact Analysis 

On January 19, 2007, the Coast Guard published an Interim Rule in the Federal Register to 

modify the RNA. Among the other proposed changes to the RNA, one significant change would 

allow outbound LNG vessels departing the port in heel (less than 5 percent of the LNG vessel’s 

carrying capacity) to travel the same as other commercial traffic, i.e., the 2-mile moving safety 

zone would no longer apply. This Interim Rule went into effect on February 20, 2007 and the 

Coast Guard received comments until March 20, 2007. 

LNG Mooring Slip Security Zone

In addition to the requirements of the RNA, the Coast Guard has established security zone for the 

Terminal slip (33 CFR Part 165.751). Entry into or movement within the zone is prohibited 

unless authorized by the COTP Savannah or if the vessels are engaged in the following 

operations: 

• Law enforcement, security, or search and rescue; 

• Servicing aids to navigation; 

• Surveying, maintenance, or improvement of waters in the security zone; or 

• Actively engaged in escort, maneuvering, or support duties for the LNG tankship. 

Southern LNG’s Waterway Suitability Assessment

The preliminary WSA for the Project was submitted with the LOI in January 2006. The 

preliminary WSA proposed to use the Sandia Report, as adopted in NVIC 05-05, as the basis for 

developing the Follow-On WSA. The Coast Guard accepted the proposed plan on January 20, 

2006. 

In June of 2006, the COTP advised Southern LNG of the need for a site-specific assessment of 

Zones of Concern for the larger LNG vessels being proposed, as these zones could potentially 

extend beyond those derived in the Sandia Report and adopted in NVIC 05-05. With Coast 

Guard involvement, Southern LNG developed a protocol for modeling spills from the larger 

LNG vessels and submitted the final results to the Coast Guard on September 6, 2006 and to the 

COTP as part of the Follow-On WSA. The Zones of Concern for the proposed Project are 

described in section 4.12.4.3. 

The Coast Guard, with input from various port stakeholders including the Savannah Pilots 

Association, the Savannah Maritirme Association, towing industry representatives, emergency 

service agencies, waterfront facilities, and select members of the Area Maritime Security 

Committee, has completed a review of Southern LNG’s WSA in accordance with the guidance in 

NVIC 05-05. The WSA participants included members of the port community from maritime 

industry and government agencies including the Coast Guard, U.S. Customs and Border 

Protection, local fire and police departments, the Georgia Ports Authority, the Savannah River 

Pilots Association, local towing companies, the Savannah Maritime Association, and a handful 

of other stakeholders. The WSA review focused on the navigation safety and maritime security 

risks posed by LNG marine traffic, and the measures needed to responsibly manage these 

security risks. 
 4-227 4.0 – Environmental Impact Analysis 

Coast Guard Waterway Suitability Report

On June 18, 2007, the Coast Guard sent a letter to the FERC, based on the above WSA review, 

providing input on the capability of the port community to implement the risk management 

measures necessary to responsibly manage the risks of LNG marine traffic in the Port of 

Savannah (see appendix L). As described in this document, the Coast Guard made a preliminary 

determination that the Savannah River, based on existing measures and additional conditions, is 

suitable for the larger LNG vessels and the increase in LNG marine traffic associated with this 

expansion. The Coast Guard letter also stated that, based on certain condition for suitability (see 

section 1.2.2), the Port of Savannah’s experience with LNG import and the cooperative 

relationship between government agencies and port stakeholders, there would be sufficient 

capability within the port community to responsibly manage the safety and security risks 

introduced by this expansion project. With the completion of this final EIS, the Coast Guard will 

complete its review and may issue an LOR with conditions to address the suitability of the 

waterways for LNG transport. 

If the Coast Guard issues an LOR finding the waterway suitable for additional LNG marine 

traffic with the conditions referenced in section 1.2.2, the necessary security measures would be 

incorporated into the detailed Savannah Area LNG Vessel Management and Emergency Plan, 

which would become the basis for appropriate security measures for each Maritime Security 

threat level. This plan would clearly spell out roles, responsibilities and specific procedures for 

an LNG vessel transiting the Savannah River navigation channel up to the Terminal, as well as 

for all agencies involved in implementing security and safety during the operation. It would be 

required that, prior to the LNG vessel being granted permission to enter the shipping channels, 

both the vessel and facility must be in full compliance with the appropriate requirements of the 

Maritime Transportation Security Act and International Ship and Port Facility Security Code, 

and the security protocols to be established by the COTP in the Savannah Area LNG Vessel 

Management and Emergency Plan. The plan may include security measures such as: Coast 

Guard and/ or other state/local law enforcement agency patrol boats to enforce safety and 

security zones around the LNG vessels while in transit and moored at the Terminal; shoreside 

surveillance and monitoring; and other prevention/mitigation strategies. 

We recognize that the Savannah Area LNG Vessel Management and Emergency Plan would be a 

dynamic document and that the port’s overall security picture may change over time. In 

addition, during the time period between the submission of the initial WSA and when the 

proposed facilities may commence operation, new port activities may commence, infrastructure 

may be added, or population density may change. Improvements in technology to detect, deter, 

and defend against intentional acts may also develop. Therefore, we recommend that until the 

commencement of service, Southern LNG should annually review its WSA relating to LNG 

marine traffic for the project; update the assessment to reflect changing conditions which 

may impact the suitability of the waterway for LNG marine traffic; provide the updated 

assessment to the cognizant COTP/FMSC for review and validation and, if appropriate, 

further action by the COTP/FMSC relating to LNG marine traffic; and provide a copy to 

FERC staff. 
 4-228 4.0 – Environmental Impact Analysis 

In addition, Southern LNG provides security for the Terminal according to a Facility Security 

Plan that must be prepared under 33 CFR 105. This plan and any modifications to this plan 

would need to be approved by the Coast Guard COTP. The requirements of this plan may 

include: 

• a Facility Security Assessment to identify site vulnerabilities, possible security threats, 

consequences of an attack, and facility protective measures; 

• a Facility Security Plan with procedures for responding to security incidents; 

• a designated FSO responsible for implementing and periodically updating the Facility 

Security Plan and Assessment; 

• scalable security measures to provide increasing levels of security at increasing Maritime 

Security (MARSEC) levels; 

• security exercises at least once each calendar year and drills at least every 3 months; and 

• mandatory reporting of all breaches of security and security incidents. 

Security at the facility is provided by both active and passive systems. The entire site is 

surrounded by a protective enclosure (i.e., a fence) with sufficient strength to deter unauthorized 

access. The enclosure is also illuminated with not less than 2.2 lux between sunset and sunrise. 

Intrusion detection systems and day/night camera coverage identify unauthorized access. A 

separate security staff conducts periodic patrols of the plant, and screen visitors and contractors. 

The security staff may also assist in maintaining security of the marine terminal during cargo 

unloading. Southern LNG would be required to submit any revisions to their Facility Security 

Plan to the COTP for approval 60 days before commencement of operations. In order to ensure 

that the responsibilities of Southern LNG’s security staff enhance overall security, we 

recommend that prior to commissioning, Southern LNG should coordinate, as needed, with 

the Coast Guard to define the responsibilities of Southern LNG’s security staff in 

supplementing other security personnel and in protecting the LNG vessels and terminal. 

Impact of Vessel Security Requirements

The potential impacts of the proposed LNG marine traffic for the proposed Project on other 

vessels can be addressed in relation to several general security requirements: 1) a moving safety 

zone for inbound LNG vessels; 2) a security zone around a moored LNG vessel; and 3) other 

measures as deemed appropriate. 

Current Coast Guard regulations place specific restrictions on marine traffic in portion of the 

Savannah River and the berth areas at the Terminal. These restrictions are outlined in the Coast 

Guard's RNA for the Port of Savannah (33 CFR Part 165.756) and a Security Zone for the LNG 

mooring slip (33 CFR Part 165.751). 

If the Coast Guard issues a LOR finding the waterway suitable for increased LNG marine traffic, 

the Coast Guard would continue to enforce the RNA and the required moving safety zone around 

LNG vessels in excess of heel (less than 5 percent of the LNG vessel’s carrying capacity). The 

moving safety zone would affect other commercial and recreational traffic using the channel. 

Except for a vessel that is moored at a marina, wharf, or pier, and remains moored, no vessel 

1,600 gross tons or greater may come with two nautical miles of a LNG vessel, carrying LNG in 

excess of heel, which is underway within the Savannah River shipping channel. All vessels less 
 4-229 4.0 – Environmental Impact Analysis 

than 1,600 gross tons must keep clear of transiting LNG vessels and may not approach within 70 

yards of LNG vessels, carrying LNG in excess of heel, without permission of the COTP. 

The moving safety zone affects other marine traffic using the channel. The magnitude of the 

effect is also influenced by other factors: the amount of time it takes to obtain a pilot and other 

competing vessel traffic in the federal navigation channel. The 2-mile moving safety zone 

around LNG vessels causes one-way marine traffic in the waterway for other transiting vessels 

over 1,600 gross tons. Commercial vessels less than 1,600 gross tons and the majority of 

recreational users would be able to pass or over take LNG vessels outside the 70-yard limit. It 

should be noted that the Coast Guard moving safety zone would not be treated as absolute 

exclusion zones that would preclude all other vessel movements. Rather, other vessels may be 

allowed to transit through the moving safety zone with the permission of the COTP. 

For the majority of this trip, an LNG vessel would travel at an average speed of 9 to 11 knots. 

Based on these assumed speeds, it would take about 2.5 hours for LNG vessels to complete the 

trip to the Terminal. Additional time (45 to 60 minutes) would be required to maneuver the LNG 

vessel into the berth. Minimum visibility conditions would have to be satisfied before the LNG 

vessel would be allowed to proceed inbound from the Atlantic Ocean, ensuring that the Coast 

Guard could adequately monitor the safety zone. The moving safety zone could cause impacts 

on other vessels but the impacts would be temporary while the LNG vessel is in transit. 

Waterway congestion is discussed further in section 4.9.6.1. 

The Coast Guard’s LNG mooring slip security zone would not have an impact on other marine 

traffic in the channel since the security zone applies only to the off-river slip at the Terminal. 

The Coast Guard routinely provides Notice to Mariners prior to the arrival and departure of LNG 

vessels. The notification system includes broadcasts on radio frequencies used by mariners. 

These practices and impacts currently occur during LNG vessel transits. If the Coast Guard 

issues a LOR finding the waterway suitable for LNG marine traffic, the Coast Guard would 

continue this practice to mitigate any adverse impacts of moving safety zone. 

4.12.5 Emergency Response and Evacuation Planning 

Southern LNG has an existing Elba Emergency Response Plan, which currently is in effect for 

the Terminal and on file with the FERC. As part of its application, Southern LNG filed a draft 

amendment to the existing Emergency Response Plan for the expansion Project. This draft plan 

outlines some of the operating philosophies necessary for the organization, training, and 

emergency procedures needed to comply with 49 CFR Part 193.2509. Prior to commencing 

service of the proposed facilities, Southern LNG would be required to prepare updated final 

emergency procedures manuals, as required by 49 CFR Part 193.2509, that provide for: (a) 

responding to controllable emergencies and recognizing an uncontrollable emergency; (b) taking 

action to minimize harm to the public including the possible need to evacuate the public; and (c) 

coordination and cooperation with appropriate local officials. Specifically, Section 

193.2509(b)(3) requires “Coordinating with appropriate local officials in preparation of an 

emergency evacuation plan...” 
 4-230 4.0 – Environmental Impact Analysis 

While the worst-case scenarios evaluated for the onshore facility in section 4.12.3 and for marine 

spills in section 4.12.4.3 provide guidance on the maximum extent of potential hazards, they 

should not be assumed to represent the evacuation zone for every potential incident. As with any 

other fuel or hazardous material, the actual severity of the incident would determine what area 

needs to be evacuated, if any, rather than a worst-case maximum zone. It is anticipated that the 

emergency evacuation plans would identify evacuation distances based upon increasing severity 

of events. 

On several LNG import terminal proposals, a number of organizations and individuals 

commented on the need to consider emergency response procedures. Subsequently, Section 

3A(e) of the Natural Gas Act, added by Section 311 of the Energy Policy Act of 2005, stipulated 

that in any Order authorizing an LNG terminal, the Commission shall require the LNG terminal 

operator to develop an Emergency Response Plan in consultation with the Coast Guard and state 

and local agencies. The FERC must approve the updated Emergency Response Plan prior to any 

final approval to begin construction. Therefore, we recommend that Southern LNG develop 

an updated Emergency Response Plan (including evacuation) and coordinate procedures 

with the Coast Guard; state, county, and local emergency planning groups; fire 

departments; state and local law enforcement; and appropriate federal agencies. This 

updated plan should include at a minimum: 

a. designated contacts with state and local emergency response agencies; 

b. scalable procedures for the prompt notification of appropriate local officials 

and emergency response agencies based on the level and severity of potential 

incidents; 

c. procedures for notifying residents and recreational users within areas of 

potential hazard along the transit route and in the South Channel; 

d. evacuation routes/methods for residents and other public use areas that are 

within any transient hazard areas along the route of the LNG marine transit; 

e. locations of permanent sirens and other warning devices; and 

f. an “emergency coordinator” on each LNG vessel to activate sirens and other 

warning devices. 

The Emergency Response Plan should be filed with the Secretary for review and 

written approval by the Director of OEP prior to initial site preparation. Southern 

LNG should notify FERC staff of all planning meetings in advance and should 

report progress on the development of its Emergency Response Plan at 3-month

intervals. 

FERC has also received comments on other LNG terminal proposals expressing concern that the 

local community would have to bear some of the cost of ensuring the security and emergency 

management of the LNG facility and the LNG vessels while in transit and unloading at the berth. 

In addition, Section 3A(e) specifies that the Emergency Response Plan shall include a CostSharing Plan that contains a description of any direct cost reimbursements the applicants agree to 

provide to any state and local agencies with responsibility for security and safety at the LNG 

terminal and in proximity to LNG vessels that serve the facility. To allow the FERC an 

opportunity to review the plan, we recommend that the Emergency Response Plan include a 
 4-231 4.0 – Environmental Impact Analysis 

Cost-Sharing Plan identifying the mechanisms for funding all project-specific 

security/emergency management costs that would be imposed on state and local agencies. 

In addition to the funding of direct transit-related security/emergency management costs, 

this comprehensive plan should include funding mechanisms for the capital costs associated 

with any necessary security/emergency management equipment and personnel base. The 

Cost-Sharing Plan should be filed with the Secretary for review and written approval by 

the Director of OEP prior to initial site preparation.

4.12.6 Conclusions on Marine Traffic Safety 

The operational safety of LNG marine traffic is under the jurisdiction of the Coast Guard. LNG 

vessels have safely transited the Savannah River and a Gulf Coast Waterway, the Calcasieu Ship 

Channel in Louisiana, for the past 20 years and worldwide for 50 years. If the Coast Guard 

issues an LOR finding the waterway suitable for additional LNG marine traffic with conditions, 

operational restrictions that may be imposed by the Coast Guard and the Savannah Pilots would 

minimize the potential for a hazardous event occurring along the waterway from the berthing 

area to the territorial sea and affecting the safety of the nearby public. 

The operation of LNG marine traffic should have a minimal impact on other vessel traffic in the 

Port channels. With the mitigation measures discussed above, the operation of additional LNG 

vessels should have a similar impact as other large vessels, and should cause no more disruption 

than the vessel traffic increases planned by other channel users. 

4.12.7 Terrorism and Security Issues 

The security requirements for the onshore component of the proposed project are governed by 

49 CFR Part 193, Subpart J - Security. This subpart includes requirements for conducting 

security inspections and patrols, liaison with local law enforcement officials, design and 

construction of protective enclosures, lighting, monitoring, alternative power sources, and 

warning signs. Requirements for maintaining safety of the marine terminal are in the Coast 

Guard’s regulations in 33 CFR Part 127. Requirements for maintaining security of the marine 

terminal are in 33 CFR Part 105. 

In the aftermath of the terrorist attacks that occurred on September 11, 2001, terrorism has 

become a very real issue for the facilities under the Commission's jurisdiction. The FERC, like 

other federal agencies, is faced with a dilemma in how much information can be offered to the 

public while still providing a significant level of protection to the facility. Consequently, the 

FERC has removed energy facility design plans and location information from its website to 

ensure that sensitive information filed under CEII is not readily available (RM02-4-000 and 

PL02-1-000 issued February 20, 2003). 

Since September 11, 2001, the FERC has been involved with other federal agencies in 

developing a coordinated approach to protecting the energy facilities of the United States. The 

FERC continues to coordinate with these agencies, specifically with the Coast Guard, to address 

this issue. The Coast Guard now requires arriving vessels to provide them with a 96-hour 

advance notice of arrival that includes key information about the vessel and its crew, which 
 4-232 4.0 – Environmental Impact Analysis 

allows the Coast Guard to conduct a terrorism risk assessment and put in place appropriate 

mitigation before the vessel reaches the vessel channel. In addition, interstate natural gas 

companies are actively involved with several industry groups to chart how best to address 

security measures in the current environment. A Security Task Force has been created and is 

addressing ways to improve pipeline security practices, strengthen communications within the 

industry and the interface with government, and extend public outreach efforts. 

On October 22, 2003, the Coast Guard issued a series of six final rules, which promulgated the 

maritime security requirements of the Marine Transportation Security Act of 2002: 

Implementation of National Maritime Security Initiatives; Area Maritime Security; Vessel 

Security; Facility Security; Outer Continental Shelf Facility Security; and the Automatic 

Identification System. The entire series of rulemakings establishes a new subchapter H in 33 

CFR. In support of the rulemakings, the Coast Guard applied a risk-based decision-making 

process to comprehensively evaluate the relative risks of various target and attack mode 

combinations and scenarios for those vessel types and port facilities that pose a risk of a security 

incident. This approach provides a more realistic estimation of risk than a simple worst-case 

outcome assessment. Risk management principles acknowledge that while risk generally cannot 

be eliminated, it can be reduced by adjusting operations to lower consequences, threats, or 

vulnerability - recognizing that it is easier to reduce vulnerabilities by adding security measures. 

On December 29, 2003, all terminal owners or operators subject to 33 CFR Part 105 were 

required to submit a Facility Security Assessment and Facility Security Plan to the Coast Guard 

COTP for review and approval. The Facility Security Plans were required to be implemented no 

later than July 1, 2004, or for facilities constructed after July 1, 2004, 60 days prior to operations. 

Some of the principal owner or operator responsibilities include: 

• designating a FSO with a general knowledge of current security threats and patterns, risk 

assessment methodology, and the responsibility for implementing the Facility Security 

Plan and Assessment and performing an annual audit for the life of the project; 

• conducting a Facility Security Assessment to identify site vulnerabilities, possible 

security threats and consequences of an attack, and facility protective measures; 

• developing a Facility Security Plan based on the Facility Security Assessment, with 

procedures for responding to transportation security incidents; notification and 

coordination with local, state, and federal authorities; prevention of unauthorized access; 

measures and equipment to prevent or deter dangerous substances and devices; training; 

and evacuation; 

• implementing scalable security measures to provide increasing levels of security at 

increasing MARSEC levels for facility access control, restricted areas, cargo handling, 

vessel stores and bunkers, and monitoring; 

• conducting security exercises at least once each calendar year and drills at least every 3 

months; and 

• reporting of all breaches of security and security incidents. 

Increased security awareness has occurred throughout the industry and the nation. President 

Bush established the Office of Homeland Security with the mission of coordinating the efforts of 

all executive departments and agencies to detect, prepare for, prevent, protect against, respond to, 
 4-233 4.0 – Environmental Impact Analysis 

and recover from terrorist attacks within the United States. The Commission, in cooperation 

with other federal agencies and industry trade groups, has joined in the efforts to protect the 

energy infrastructure, including the more than 300,000 miles of interstate natural gas 

transmission pipeline and associated LNG facilities. 

Safety and security are important considerations in any Commission action. The attacks of 

September 11, 2001 have changed the way pipeline operators as well as regulators must consider 

terrorism, both in approving new projects and in operating existing facilities. However, the 

likelihood of future acts of terrorism or sabotage occurring at the proposed Terminal expansion, 

or at any of the myriad of natural gas pipeline or energy facilities throughout the United States is 

unpredictable given the disparate motives and abilities of terrorist groups. However, existing 

and proposed security measures discussed in this section make significant impacts to human life 

and property from a terrorist attack unlikely. The continuing need to construct facilities to 

support the future natural gas pipeline infrastructure is not diminished from the threat of any 

such unpredictable acts. 

4.12.8 Pipeline Safety Standards 

The transportation of natural gas by pipeline involves some risk to the public in the event of an 

accident and subsequent release of gas. The greatest hazard is a fire or explosion following a 

major pipeline rupture. 

Methane, the primary component of natural gas, is colorless, odorless, and tasteless. It is not 

toxic, but is classified as a simple asphyxiate, possessing a slight inhalation hazard. If breathed 

in high concentration, oxygen deficiency can result in serious injury or death. 

Methane has an ignition temperature of 1,000 degrees Fahrenheit and is flammable at 

concentrations between 5.0 percent and 15.0 percent in air. Unconfined mixtures of methane in 

air are not explosive. However, a flammable concentration within an enclosed space in the 

presence of an ignition source can explode. It is buoyant at atmospheric temperatures and 

disperses rapidly in air. 

The DOT is mandated to provide pipeline safety under Title 49, U.S.C. Chapter 601. The 

Pipeline and Hazardous Materials Safety Administration (PHMSA), OPS, administers the 

national regulatory program to ensure the safe transportation of natural gas and other hazardous 

materials by pipeline. It develops safety regulations and other approaches to risk management 

that ensure safety in the design, construction, testing, operation, maintenance, and emergency 

response of pipeline facilities. Many of the regulations are written as performance standards 

which set the level of safety to be attained and allow the pipeline operator to use various 

technologies to achieve safety. PHMSA ensures that people and the environment are protected 

from the risk of pipeline incidents. This work is shared with state agency partners and others at 

the federal, state, and local level. Section 5(a) of the Natural Gas Pipeline Safety Act provides 

for a state agency to assume all aspects of the safety program for intrastate facilities by adopting 

and enforcing the federal standards, while Section 5(b) permits a state agency that does not 

qualify under Section 5(a) to perform certain inspection and monitoring functions. A state may 

also act as DOT’s agent to inspect interstate facilities within its boundaries; however, the DOT is 
 4-234 4.0 – Environmental Impact Analysis 

responsible for enforcement action. The majority of the states have either 5(a) certifications or 

5(b) agreements, while nine states act as interstate agents. 

The DOT pipeline standards are published in Parts 190-199 of Title 49 of the CFR. Part 192 of 

49 CFR specifically addresses natural gas pipeline safety issues. Under a Memorandum of 

Understanding on Natural Gas Transportation Facilities (Memorandum) dated January 15, 1993 

between the DOT and the FERC, the DOT has the exclusive authority to promulgate federal 

safety standards used in the transportation of natural gas. Section 157.14(a)(9)(vi) of the FERC’s 

regulations require that an applicant certify that it will design, install, inspect, test, construct, 

operate, replace, and maintain the facility for which a certificate is requested in accordance with 

federal safety standards and plans for maintenance and inspection, or shall certify that it has 

been granted a waiver of the requirements of the safety standards by the DOT in accordance with 

Section 3(e) of the Natural Gas Pipeline Safety Act. 

The FERC accepts this certification and does not impose additional safety standards other than 

the DOT standards. If the Commission becomes aware of an existing or potential safety problem, 

there is a provision in the Memorandum to promptly alert DOT. The Memorandum also provides 

for referring complaints and inquiries made by state and local governments and the general 

public involving safety matters related to pipeline under the Commission’s jurisdiction. The 

FERC also participates as a member of the DOT’s Technical Pipeline Safety Standards 

Committee which determines if proposed safety regulations are reasonable, feasible, and 

practicable. 

The pipeline and aboveground facilities associated with the Elba Express Pipeline Project must 

be designed, constructed, operated, and maintained in accordance with the DOT Minimum 

Federal Safety Standards in 49 CFR 192. The regulations are intended to ensure adequate 

protection for the public and to prevent natural gas facility accidents and failures. Part 192 

specifies material selection and qualification, minimum design requirements, and protection from 

internal, external, and atmospheric corrosion. 

Part 192 also defines area classifications, based on population density in the vicinity of the 

pipeline, and specifies more rigorous safety requirements for populated areas. The class location 

unit is an area that extends 220 yards on either side of the centerline of any continuous 1-mile 

length of pipeline. The four area classifications are defined as follows: 

• Class 1 Location with 10 or fewer buildings intended for human occupancy. 

• Class 2 Location with more than 10 but less than 46 buildings intended for human 

occupancy. 

• Class 3 Location with 46 or more buildings intended for human occupancy or 

where the pipeline lies within 100 yards of any building, or small well-defined 

outside area occupied by 20 or more people during normal use. 

• Class 4 Location where buildings with four or more stories aboveground are 

prevalent. 

Class locations representing more populated areas require higher safety factors in pipeline 

design, testing, and operation. Pipelines constructed on land in Class 1 locations must be 
 4-235 4.0 – Environmental Impact Analysis 

installed with a minimum depth of cover of 30 inches in normal soil and 18 inches in 

consolidated rock. Class 2, 3, and 4 locations, as well as drainage ditches of public roads and 

railroad crossings, require a minimum cover of 36 inches in normal soil and 24 inches in 

consolidated rock. All pipelines installed in navigable rivers, streams, and harbors must have a 

minimum cover of 48 inches in soil or 24 inches in consolidated rock. 

Class locations also specify the maximum distance to a sectionalizing block valve (e.g., 10.0 

miles in Class 1, 7.5 miles in Class 2, 4.0 miles in Class 3, and 2.5 miles in Class 4). Pipe wall 

thickness and pipeline design pressures, hydrostatic test pressures, MAOP, inspection and testing 

of welds, and frequency of pipeline patrols and leak surveys must also conform to higher 

standards in more populated areas. In addition, all pipeline interconnects, and pipeline facilities 

within the fenced enclosures of the meter stations, launcher and receiver, and MLVs would be 

designed and constructed to meet Class 3 requirements. 

If a subsequent increase in population density adjacent to the right-of-way indicates a change in 

class location above existing design for the pipeline, EEC would reduce the MAOP or replace 

the segment with pipe of sufficient grade and wall thickness, if required to comply with the DOT 

code of regulations for the new class location. 

In 2002, Congress recently passed an act to strengthen the Nation’s pipeline safety laws. The 

pipeline Safety Improvement Act of 2002 (HR 3609) was passed by Congress on November 15, 

2002, and signed into law by the President in December 2002. Since December 17, 2004, gas 

transmission operators are required to develop and follow a written integrity management 

program that contains all the elements described in Section 192.911 and addresses the risks on 

each covered transmission pipeline segment. Specifically, the law establishes an integrity 

management program which applies to all high consequence areas (HCAs). The DOT (68 FR 

69778, 69 FR 18228, and 69 FR 29903) defines HCAs as they relate to the different class zones, 

potential impact circles, or areas containing an identified site as defined in Section 192.903 of 

the DOT regulations. 

OPS published a series of rules from August 6, 2002 to May 26, 2004 (69 FR 29903), that 

defines HCAs where a gas pipeline accident could do considerable harm to people and their 

property and requires an integrity management program to minimize the potential for an 

accident. This definition satisfies, in part, the Congressional mandate in 49 USC 60109 for OPS 

to prescribe standards that establish criteria for identifying each gas pipeline facility in a high 

density population area. 

The HCA may be defined in one of two ways. In the first method an HCA includes: 

• current Class 3 and 4 locations; 

• any area in Class 1 or 2 where the potential impact radius10 is greater than 660 feet and 

there are 20 or more buildings intended for human occupancy within the potential impact 

circle; or 

• any area in Class 1 or 2 where the potential impact circle includes an identified site. 
 4-236 4.0 – Environmental Impact Analysis 

In the second method, an HCA includes any area within a potential impact circle which contains: 

• 20 or more buildings intended for human occupancy; or 

• an identified site. 

Once a pipeline operator has determined the HCAs on its pipeline, it must apply the elements of 

its integrity management program to those segments of the pipeline within the HCAs. The DOT 

regulations specify the requirements for the integrity management plan at Section 192.911. 

Table 4.12.8-1 identifies preliminary class locations for the Elba Express Pipeline Project, by 

milepost, as defined in Title 49 CFR Part 192. The majority of the proposed pipeline route would 

cross open land that is sparsely populated. About 171.0 miles of proposed pipeline route would 

be located in a Class 1 area, 4.8 miles would be in a Class 2 area, and 12.1 miles would be in 

Class 3 area. No portions of the proposed route would be located in a Class 4 area. Prior to 

construction of the pipeline, EEC will reassess the class locations along the pipeline route and 

will ensure that the pipeline is designed and constructed for the current class locations as well as 

for any anticipated future changes in class locations. EEC also will assess the pipeline route for 

HCAs in accordance with 49 CFR Part 192.761 prior to construction. The pipeline integrity 

management rule for HCAs requires inspection of the entire pipeline in HCAs every seven years. 

Part 192 prescribes the minimum standards for operating and maintaining pipeline facilities, 

including the requirement to establish a written plan governing these activities. The proposed 

pipeline would be continuously monitored and controlled via computer and local logic 

controllers at the manned control center at the LNG terminal site. A locally based, full-time staff 

would be assigned to operate and maintain the natural gas pipeline. The staff would be fully 

trained in pipeline operations, maintenance, and normal, abnormal, and emergency procedures. 

The pipeline would be patrolled and inspected on the ground on a periodic basis per DOT 

requirements or better. The frequency of these inspections would be affected by activity along 

the pipeline route such as construction or possible encroachment. These inspections would 

identify conditions indicative of pipeline leaks, evidence of pipeline damage or deterioration, 

damage to erosion controls, loss of cover, third-party activities or conditions which may 

presently or in the future affect pipeline integrity, safety, or operation of the pipeline. The 

pipeline system would participate in the state “One Call” system. 

Under Section 192.615, each pipeline operator must also establish an emergency plan that 

includes procedures to minimize the hazards in a natural gas pipeline emergency. Key elements 

of the plan include procedures for: 

• receiving, identifying, and classifying emergency events, gas leakage, fires, explosions, 

and natural disasters; 

• establishing and maintaining communications with local fire, police, and public officials, 

and coordinating emergency response; 

• emergency shutdown of system and safe restoration of service; 

• making personnel, equipment, tools, and materials available at the scene of an 

emergency; and 
 4-237 4.0 – Environmental Impact Analysis 

• protecting people first and then property, and making them safe from actual or potential 

hazards. 

TABLE 4.12.8-1

Preliminary Area Class Locations for the Elba Express Pipeline Project 

Milepost 

From 

Milepost 

To 

Length 

Miles 

Location 

Class 

Construction 

Design Factor 

Diameter 

(inches) 

Wall 

Thickness Grade 

42-inch Outside Diameter (OD) Pipeline 

0.0 9.5 9.5 3 a/ 42 a/ X80 

9.5 11.1 1.6 2 0.60 42 0.547 X80 

11.1 12.6 1.5 1 0.72 42 0.456 X80 

12.6 13.3 0.7 2 0.60 42 0.547 X80 

13.3 14.3 1.0 3 0.50 42 0.656 X80 

14.3 16.2 1.9 1 0.72 42 0.456 X80 

16.2 16.9 0.7 3 0.60 42 0.656 X80 

16.9 101.4 84.5 1 0.72 42 0.456 X80 

101.4 102.8 1.4 2 0.60 42 0.547 X80 

102.8 104.3 1.5 1 0.72 42 0.456 X80 

104.3 105.2 0.9 3 0.50 42 0.656 X80 

105.2 114.8 9.6 1 0.72 42 0.456 X80 

Miles Class 1 99.0 

Miles Class 2 3.7 

Miles Class 3 12.1 

Total Miles 114.8 

36-inch OD Pipeline 

114.8 184.9 70.1 1 0.72 36 0.391 X80 

184.9 186.0 1.1 2 0.60 36 0.469 X80 

186.0 187.9 1.9 1 0.72 36 0.391 X80 

Miles Class 1 72.0 

Miles Class 2 1.1 

Miles Class 3 0.0 

Total Miles 73.6 

________________________________ 

a/ To be determined. 

Note: All information included herein is preliminary. The final class location will be performed after the engineering surveys are 

complete.

Part 192 requires that each operator must establish and maintain liaison with appropriate fire, 

police, and public officials to learn the resources and responsibilities of each organization that 

may respond to a natural gas pipeline emergency, and to coordinate mutual assistance. The 

operator must also establish a continuing education program to enable customers, the public, 

government officials, and those engaged in excavation activities to recognize a gas pipeline 

emergency and report it to appropriate public officials. EEC would provide the appropriate 

training to local emergency service personnel before the pipeline is placed in service. No 
 4-238 4.0 – Environmental Impact Analysis 

additional specialized local fire protection equipment would be required to handle pipeline 

emergencies. 

4.12.9 Pipeline Accident Data 

Since February 9, 1970, 49 CFR 191 has required all operators of transmission and gathering 

systems to notify the DOT of any reportable incident and to submit a report on form F7100.2 

within 20 days. Reportable incidents are defined as any leaks that: 

• caused a death or personal injury requiring hospitalization; 

• required taking any segment of transmission line out of service; 

• resulted in gas ignition; 

• caused estimated damage to the property of the operator, or others, or both, of a total of 

$5,000 or more; 

• required immediate repair on a transmission line; 

• occurred while testing with gas or another medium; or 

• in the judgment of the operator was significant, even though it did not meet the above 

criteria. 

The DOT changed reporting requirements after June 1984 to reduce the amount of data 

collected. Since that date, operators must only report incidents that involve property damage of 

more than $50,000, injury, death, release of gas, or that are otherwise considered significant by 

the operator. Table 4.12.8-2 presents a summary of incident data for the 1970 to 1984 period, as 

well as more recent incident data for 1986 through 2005, recognizing the difference in reporting 

requirements. The 14.5-year period from 1970 through June 1984, which provides a larger 

universe of data and more basic report information than subsequent years, has been subject to 

detailed analysis, as discussed in the following sections. 

During the 14.5-year period, 5,862 service incidents were reported over the more than 300,000 

total miles of natural gas transmission and gathering systems nationwide. Service incidents, 

defined as failures that occur during pipeline operation, have remained fairly constant over this 

period with no clear upward or downward trend in annual totals. In addition, 2,013 test failures 

were reported. Correction of test failures removed defects from the pipeline before operation. 

Additional insight into the nature of service incidents may be found by examining the primary 

factors that caused the failures. Table 4.12.8-2 provides a percentage distribution of the causal 

factors as well as the annual frequency of each factor per 1,000 miles of pipeline in service. 

Table 4.12.8-3 summarizes transmission pipeline incidents reported in 2005 by cause. The 

leading causes of transmission line incidents resulted from heavy rains/flooding and third-party 

excavation damages. Using the annual average for incidents (114) and average miles of 

transmission pipelines (297,150) between 2001 and 2005, there were 0.00038 incidents per 

pipeline mile per year. 
 4-239 4.0 – Environmental Impact Analysis 

TABLE 4.12.8-2

Natural Gas Service Incidents by Cause 

Incidents per 1,000 Miles of Pipeline (percentage) Cause 

1970-1984 1986-2005 

Outside Force 0.70 (53.8) 0.10 (38.5)

Corrosion 0.22 (16.9) 0.06 (23.1) 

Construction or Material Defect 0.27 (20.8) 0.04 (15.4) 

Other 0.11 (8.5) 0.06 (23.1)

Total 1.30 0.26 

The dominant incident cause is outside forces, constituting 53.8 percent of all service incidents. 

Outside forces incidents result from the encroachment of mechanical equipment such as 

bulldozers and backhoes; earth movements due to soil settlement, washouts, or geologic hazards; 

weather effects such as winds, storms, and thermal strains; and willful damage. Table 4.12.8-3 

shows that human error in equipment usage was responsible for approximately 75 percent of 

outside forces incidents. Since April 1982, operators have been required to participate in “One 

Call” public utility programs in populated areas to minimize unauthorized excavation activities 

in the vicinity of pipelines. The “One Call” program is a service used by public utilities and 

some private sector companies (e.g., oil pipelines and cable television) to provide 

preconstruction information to contractors or other maintenance workers on the underground 

location of pipes, cables, and culverts. The 1986 through 2005 data (as shown on table 4.12.8-4) 

show that the portion of incidents caused by outside forces has decreased to 38.5 percent.

TABLE 4.12.8-3

Office of Pipeline Safety: Transmission Pipeline Incident Summary by Cause, 1/1/2005-12/31/2005 

Cause Incidents Property Damage Deaths Injuries 

Body of Pipe 4 $424,538 0 0 

Butt Weld 4 $1,898,032 0 0 

Car, Truck or Other Vehicle Not Related to 

Excavation Activity 11 $8,780,233 0 1 

Component 7 $3,409,521 0 0 

Corrosion, External 14 $89,936,893 0 0 

Corrosion, Internal 14 $6,058,934 0 0 

Earth Movement 8 $31,154,179 0 0 

Fillet Weld 0 0 0 0 

Fire/Explosion as Primary Cause 1 $100,000 0 0 

Heavy Rains/Flood 46 $60,496,959 0 0 

High Winds 8 $19,824,208 0 0 

Incorrect Operation 4 $791,887 0 3 

Joint 3 $430,800 0 0 

Lightning 0 0 0 0 

Malfunction of Control/Relief Equipment 11 $2,180,943 0 0 

Miscellaneous 12 $3,094,360 0 1 

No Data 0 0 0 0 

Operator Excavation Damage 2 $301,427 0 0 
 4-240 4.0 – Environmental Impact Analysis 

TABLE 4.12.8-3

Office of Pipeline Safety: Transmission Pipeline Incident Summary by Cause, 1/1/2005-12/31/2005 

Cause Incidents Property Damage Deaths Injuries 

Pipe Seam Weld 0 0 0 0 

Rupture of Previously Ruptured or Leaking 1 $1,600,000 0 0 

Rupture or Leaking Seal/Pump Packing 1 $50,001 0 0 

Temperature 2 $50,000 0 0 

Third-Party Excavation Damage 18 $2,412,046 0 1 

Thread Stripped Broken Pipe Coupling 2 $215,119 0 0 

Unknown 7 $18,852,506 0 1 

Vandalism 1 $55,000 0 0 

Total 181 $252,117,586 0 7 

Average $1,392,915 0 0 

______________________________________________________ 

Source: USDOT 2005 (http://ops.dot.gov/).

TABLE 4.12.8-4 

Outside Forces Incidents by Cause (1970-1984) 

Cause Percent 

Equipment Operated by Outside Party 67.1 

Equipment Operated by the Operator 7.3 

Earth Movement 13.3 

Weather 10.8 

Other 1.6 

The pipelines included in the data set in table 4.12.8-4 vary widely in terms of age, pipe 

diameter, and level of corrosion control. Each variable influences the incident frequency that 

may be expected for a specific segment of pipeline. 

The frequency of service incidents is strongly dependent on pipeline age. While pipelines 

installed since 1950 exhibit a fairly constant level of service incident frequency, pipelines 

installed before that time have a significantly higher rate, partially due to corrosion. Older 

pipelines have a higher frequency of corrosion incidents, since corrosion is a time-dependent 

process. Further, new pipe generally uses more advanced coatings and cathodic protection to 

reduce corrosion potential. 

Older pipelines have a higher frequency of outside forces incidents partly because their location 

may be less well known and less well marked than newer lines. In addition, the older pipelines 

contain a disproportionate number of smaller diameter pipelines, which have a greater rate of 

outside forces incidents. Small diameter pipelines are more easily crushed or broken by 

mechanical equipment or earth movements. 

Table 4.12.8-5 clearly demonstrates the effectiveness of corrosion control in reducing the 

incidence of failures caused by external corrosion. The use of both an external protective coating 

and a cathodic protection system, required on all pipelines installed after July 1971, significantly 
 4-241 4.0 – Environmental Impact Analysis 

reduces the rate of failure compared to unprotected or partially protected pipe. The data shows 

that bare, cathodically protected pipe actually has a higher corrosion rate than unprotected pipe. 

This anomaly reflects the retrofitting of cathodic protection to actively corroding spots on pipes. 

TABLE 4.12.8-5

External Corrosion by Level of Control (1970-1984) 

Corrosion Control Incidents per 1,000 miles per year 

None-bare Pipe 0.42 

Cathodic Protection Only 0.97 

Coated Only 0.40 

Coated and Cathodic Protection 0.11 

4.12.10 Impacts on Public Safety 

The service incident data summarized in table 4.12.8-1 include pipeline failures of all 

magnitudes with widely varying consequences. Approximately two-thirds of the incidents were 

classified as leaks, and the remaining third classified as ruptures, implying a more serious failure. 

Table 4.12.8-6 presents the average annual fatalities that occurred on natural gas transmission 

and gathering lines from 1970 to 2005. Fatalities between 1970 and June 1984 have been 

separated into employees and nonemployees, to better identify a fatality rate experienced by the 

general public. Of the total 5.0 nationwide average, fatalities among the public averaged 2.6 per 

year over this period. The simplified reporting requirements in effect after June 1984 do not 

differentiate between employees and nonemployees. However, the data show that the total 

annual average for the period 1984 through 2005 decreased to 3.6 fatalities per year. Subtracting 

two major offshore incidents in 1989, which do not reflect the risk to the onshore public, yields a 

total annual rate of 2.8 fatalities per year for this period. 

TABLE 4.12.8-6

Annual Average Fatalities - Natural Gas Transmission and Gathering Systems a/, b/

Year Employees Nonemployees Total 

1970-June 1984 2.4 2.6 5.0 

1984-2005 c/ -- -- 3.5 

1984-2005 c/ 2.8 d/ 

______________________________________________________ 

a/ 1970 through June 1984 - American Gas Association, 1986. 

b/ DOT Hazardous Materials Information System. 

c/ Employee/nonemployee breakdown not available after June 1984. 

d/ Without 18 offshore fatalities occurring in 1989 – 11 fatalities resulted from a fishing vessel striking an offshore pipeline and 

seven fatalities resulted from explosion on an offshore production platform. 

The nationwide totals of accidental fatalities from various manmade and natural hazards are 

listed in table 4.12.8-7 in order to provide a relative measure of the industry-wide safety of 

natural gas pipelines. Direct comparisons between accident categories should be made 

cautiously; however, because individual exposures to hazards are not uniform among all 
 4-242 4.0 – Environmental Impact Analysis 

categories. Nevertheless, the average 2.6 public fatalities per year is relatively small considering 

the more than 300,000 miles of transmission and gathering lines in service nationwide. 

Furthermore, the fatality rate is approximately two orders of magnitude (100 times) lower than 

the fatalities from natural hazards such as lightning, tornadoes, floods, earthquakes, etc. 

TABLE 4.12.8-7

Nationwide Accidental Deaths a/

Type of Accident Fatalities 

All Accidents 90,523 

Motor Vehicles 43,649 

Falls 14,985 

Poisoning 9,510 

Fires and Burns 3,791 

Drowning 3,488 

Suffocation by Ingested Object 3,206 

Tornado, Flood, Earthquake, etc. (1984-93 average) 181 

All Liquid and Gas Pipelines (1986-2003 average) b/ 22 

Gas Transmission and Gathering Lines, Nonemployees Only (1970-84 average) c/ 2.6 

______________________________________________________ 

a/ All data, unless otherwise noted, reflects 1996 statistics from the U.S. Department of Commerce, 

Bureau of the Census, “Statistical Abstract of the United States 118th Edition.” 

b/ U.S. Department of Transportation, Office of Pipeline Safety, www.ops.dot.gov/stats. 

c/ American Gas Association, 1986. 

The available data show that natural gas pipelines continue to be a safe, reliable means of energy 

transportation. Based on approximately 301,000 miles in service, the rate of public fatalities for 

the nationwide mix of transmission and gathering lines in service is 0.01 per year per 1,000 miles 

of pipeline. Using this rate, EEC’s Project might result in a public fatality every 532 plus years. 

This would represent a slight increase in risk to the nearby public. 

4.13 CUMULATIVE IMPACTS 

NEPA requires the lead federal agency to consider the potential cumulative impacts of proposals 

under their review. Cumulative impacts may result when the environmental effects associated 

with the proposed action are superimposed on or added to either temporary or permanent impacts 

associated with past, present, and reasonably foreseeable future projects. Cumulative impacts 

can result from individually minor, but collectively significant, actions taking place over a period 

of time. 

Generally, we believe that cumulative impact could result only from the construction of other 

projects in the same vicinity and time frame as the proposed facilities. In such a situation, 

although the impact associated with each project might be minor, the cumulative impact resulting 

from all projects being constructed in the same general area could be greater. 

Impacts subject to cumulative effects analysis for the Elba III Project were identified by 

determining the environmental impact issues associated with the proposed action, establishing 
 4-243 4.0 – Environmental Impact Analysis 

the geographic scope of the study area, establishing the timeframe of the analysis, and 

identifying other past, present, or future actions that have affected, or could affect, the resources 

of concern. 

Construction of the Terminal Expansion facilities would result in both short- and long-term, 

minor to moderate environmental impacts. Impacts associated with construction of the Elba 

Express Pipeline generally are short-term and minor because resources in the project area that 

would be affected during construction can generally be restored or allowed to return back to their 

original condition following pipeline installation. Some long-term impacts occur, however, 

when resources cannot be quickly restored to original conditions (e.g., cleared forest lands), or 

when resources are permanently affected due to operational and maintenance requirements (e.g., 

expansion of the LNG terminal facilities, aboveground facilities associated with the pipeline, and 

maintenance requirements along the proposed pipeline ROW). 

In addition to the Elba III Project, we considered ten activities and projects in our cumulative 

impact analysis (see table 4.13-1). These are known projects with potential impacts on the same 

resources for which some effect has been evaluated for the Elba III Project. Of these projects, 

four are pertinent to the Terminal Expansion Project and the remaining six are pertinent to the 

Elba Express Pipeline. 

Terminal Expansion

South Atlantic International Terminal

In its October 31, 2002 Memorandum for Commander South Atlantic Division (CESAD-CM-P)

regarding the SHEP, Georgia and South Carolina General Reevaluation and Scoping Meeting 

Project Guidance Memorandum, the COE reported that government officials for Jasper County, 

South Carolina, want to develop a container terminal (South Atlantic International Terminal 

[SAIT]), on the north side of the lower Savannah River to receive more of the economic benefits 

of a deep draft harbor. The proposed SAIT would be located directly across from the Terminal 

Expansion site along the shoreline of the Savannah River. 

The South Carolina side of the lower Savannah River consists of salt marshes and CDFs that are 

owned by the State of Georgia, controlled by the Georgia DOT, and used for operation and 

maintenance of the Savannah Harbor navigation channel. The original Jasper County plan was 

to use about 1,800 acres of land for development of four wharfs (marshalling areas), terminal 

storage, and associated appurtenances including a gate complex, administration building, 

equipment storage, maintenance complex, fueling area, and intermodal operation building. 

The SAIT has a long history of legal and political challenges. Ongoing litigation between the 

South Carolina State Ports Authority, Jasper County, and the Georgia Department of 

Transportation will likely delay any development in the immediate future. We also note that a 

new port on the Savannah River in Jasper County would require a tremendous investment in 

infrastructure as the area currently has no road or rail access. 
 4-244 4.0 – Environmental Impact Analysis 

TABLE 4.13-1

Existing, Approved, or Proposed Activities/Projects that Could Contribute to Cumulative Impacts 

Associated with Construction of the Elba III Project 

Activity/Project 

Counties and States Where 

Project Coincides with the 

Elba III Project 

Description Timeframe 

Terminal Expansion Project 

South Atlantic International 

Terminal (Jasper County Port) 

Jasper County, SC adjacent to 

Chatham County, GA 

Construct and operate a new deepwater terminal on the north side of 

the lower Savannah River. 

Undetermined 

Savannah Harbor Expansion 

Project 

Chatham County, GA Deepen about 20 miles of the 

Savannah Harbor navigation channel 

from 42 feet to 48 feet. 

2010 

Port of Savannah, Garden City 

Terminal Expansion 

Chatham County, GA Construct and operate a new 

container berth and development of 

additional open, paved storage areas. 

2006 

Port of Savannah, Ocean Terminal 

Expansion 

Chatham County, GA Develop additional open, paved 

storage for the productive handling of 

roll-on roll-off cargo. 

Undetermined 

Elba Express Pipeline 

Cypress Pipeline Project Chatham and Effingham 

Counties, GA 

Construct and operate 167 miles of 

mainline pipeline, 10 miles of pipeline 

loop, and appurtenances. 

2007, 2009, 

and 2010 

U.S. Route 1/State Route 4 

Widening and Reconstruction 

Project 

Jefferson County, GA Widen and reconstruct U.S. Route 

1/State Route 4 for about 21.8 miles. 

Undetermined 

State Route 17 Widening and 

Reconstruction Project 

McDuffie and Wilkes Counties, 

GA 

Widen, reconstruct, and relocate 

State Route 17 for 15.9 miles. 

Undetermined 

State Route 72 Widening, 

Reconstruction, and Relocation 

Project 

Elbert County, GA Widen, reconstruct, and relocate 

State Route 72 for 14.4 miles. 

Undetermined 

Planned Developments Effingham County, GA Research Forest Tract (“Tract B”), 

Braniger Estates, Parkway Place, 

and Stafford Shire Estates. 

Undetermined 

Thomas-McDuffie Regional Airport 

Runway Expansion Project 

McDuffie County, GA Runway extension and repaving, and 

construction of new corporate aircraft 

hangars. 

Undetermined 

Savannah Harbor Expansion Project

On January 22, 2002, the Savannah District of the COE issued an Intent to Prepare a Draft Tier 

II Environmental Impact Statement for the Savannah Harbor Expansion Project, Savannah, 

Georgia (SHEP). The EIS describes the potential impacts of deepening the navigation channel 

at Savannah, Georgia. The COE’s Savannah Harbor Expansion Project Formulation of 

Alternatives, General Re-evaluation Report and Environmental Impact Statement was released in 

March 2004 and revised in April 2005. 

The SHEP would include the following harbor improvements: 

• deepening the existing Savannah Harbor navigation channel, in increments, from an 

existing depth of 42 feet MLW to a potential depth of 48 feet MLW from the Savannah 

River entrance channel at Station 0+000 to the Georgia Port Authority’s Garden City 

Terminal at about Station 103+000; 
 4-245 4.0 – Environmental Impact Analysis 

• widening bends in the entrance channel at two locations and in the inner harbor channel 

at 10 locations; 

• enlarging the Kings Island Turning Basin (used by both the Garden City and Ocean 

Terminals, described below) to a width of 1,676 feet; and 

• raising the dikes from 2.6 feet to 5.5 feet in disposal areas 12A, 14B, and 

Jones/Oysterbed Island. 

The recommended plan of improvement for the SHEP would require dredging and subsequent 

placement of a maximum of 27 million cubic yards of sediment. Sediment excavated from the 

entrance channel would be deposited in the approved ocean CDF site. Sediment excavated from 

the inner harbor would be deposited in CDFs currently used by the existing federal navigation 

project. Dike raising would be performed to accommodate the sediment deposited in those 

CDFs to regain lost disposal capacity. Further consideration of near shore and/or beach 

placement of excavated sediment would be made during the engineering and design phase of the 

project. The Terminal Expansion site would be within the SHEP limits. 

Port of Savannah, Garden City Terminal Expansion

Owned and operated by the Georgia Port Authority, Garden City Terminal is a secured, 

dedicated container facility and is the largest of its kind on the East and Gulf Coasts. It is a 

1,200-acre single-terminal facility with 9,693 feet of continuous berthing, and more than 1.3 

million square feet of covered storage. The terminal is equipped with 15 high-speed container 

cranes and an extensive inventory of yard handling equipment. Garden City Terminal is within 

6.3 miles of I-16 and 5.6 miles of I-95. CSX Transportation and Norfolk Southern Railroad 

provide Class I rail service to the facility. 

The Georgia Port Authority is in the advanced planning stages of developing the terminal’s 

eighth container berth (CB-8) which would expand the facility by 83-acres and add 2,100 feet of 

new berthing. CB-8 would be equipped with state-of-the-art cargo handling equipment and 

technology. The Garden City Terminal is about 11.0 miles north-northwest of Elba Island. 

Port of Savannah, Ocean Terminal Expansion

Owned and operated by the Georgia Port Authority, Ocean Terminal is a secured, dedicated 

break-bulk facility that specializes in the rapid and efficient handling of a vast array of forest and 

solid wood products, steel, RO-RO project shipments and heavy-lift cargoes. It is a 208-acre 

facility with 6,688 feet of deepwater berthing, about 1.5 million square feet of covered storage, 

and 96 acres of open, versatile storage. Ocean Terminal is within 1.2 miles of I-16 and 10 miles 

of I-95. CSX Transportation and Norfolk Southern Railroad provide Class I rail service to the 

facility. 

The Georgia Port Authority identified a large tract of land along the southwest side of the Ocean 

Terminal for the development of additional open, paved storage to accommodate the productive 

handling of RO-RO cargo. The Ocean Terminal is about 8.0 miles north-northwest of Elba 

Island. 
 4-246 4.0 – Environmental Impact Analysis 

Elba Express Pipeline

Southern’s Proposed Cypress Pipeline Project

On June 15, 2006, Southern was authorized to construct and operate its Cypress Pipeline Project 

(Docket No. CP05-388-000). These natural gas pipeline facilities consist of: 

• about 167 miles of new 24-inch-diameter mainline pipeline extending from Southern’s 

existing Rincon Gate Meter Station in Effingham County, Georgia to Florida Gas 

Company’s (FGT’s) existing pipeline system in Clay County, Florida; 

• about 9.8 miles of 30-inch-diameter pipeline loop adjacent to Southern’s three WrensSavannah pipelines between Southern’s existing Port Wentworth Meter Station in 

Chatham County, Georgia and the Rincon Gate Meter Station in Effingham County, 

Georgia; and 

• about 0.1 mile of 12-inch-diameter lateral pipeline in Florida; and 

• various aboveground facilities including three new compressor stations (Liberty and 

Glynn Counties, Georgia and Nassau County, Florida), four new meter stations in 

Florida, modification/expansion of to three existing meter station (Chatham, Effingham, 

and Cobb Counties, Georgia), and various new block valves and pig launcher/receivers. 

Of particular relevance to the Elba III Project cumulative impacts discussion are the 9.8 miles of 

loop pipeline between Port Wentworth and Rincon, modification of the existing Port Wentworth 

Meter Station (Chatham County), and expansion of the Rincon Gate Meter Station (Effingham 

County). 

Southern will construct its Cypress Pipeline Project in three phases with planned in-service dates 

of May 2007 (Phase I), May 2009 (Phase II), and May 2010 (Phase III). The 9.8-mile-long 

pipeline loop between the Port Wentworth and Rincon Gate Meter Stations and the meter station 

modification and expansions in Chatham and Effingham Counties would be constructed as Phase 

III. As previously discussed, the gas authorized to be transported by Southern’s Cypress Phase 

III pipeline loop is now proposed to be transported by the Elba Express Pipeline between Port 

Wentworth and Rincon. This would substantially reduce cumulative construction impacts on 

landowners and environmental resources along Southern’s existing three-pipeline corridor 

between MP 0.0 to about MP 9.8 in Chatham and Effingham Counties. At Rincon Gate, the 

Cypress 24-inch-diameter mainline would begin at an interconnection with the Elba Express 

Pipeline at the proposed EEC/Cypress Meter Station and head south to Florida. 

U.S. Route 1/State Route 4 Widening and Reconstruction Project

On March 7, 2006, the Georgia DOT held a public information open house for the US Route 

1/State Route 4 Widening and Reconstruction Project (US 1/SR 4 Project) in Jefferson County, 

Georgia. The US 1/SR 4 Project includes four separate projects that begin near Louisville and 

end in Wrens. Wrens is about 3.0 miles south of the Elba Express route at MP 104.7. The US 

1/SR 4 Project includes a total of 21.8 miles of widening and reconstruction of the roadway from 

two to four lanes with a grassed median. 
 4-247 4.0 – Environmental Impact Analysis 

State Route 17 Widening and Reconstruction Project

On September 22, 2005, the Georgia DOT held a public information open house for the State 

Route 17 Widening and Reconstruction Project (SR 17 Project) McDuffie and Wilkes Counties. 

The SR 17 Project includes two separate projects that begin near the intersection of SR 43 in 

McDuffie County and continue north to its terminus at the Washington Bypass in Wilkes 

County. The US 1/SR 4 Project includes a total of 15.9 miles of widening and reconstruction of 

the roadway from two to four lanes with a grassed median. The SR 17 Project is about 5.5 miles 

west of the Elba Express route between about MPs 130.0 and 135.0 and intersects the Elba 

Express Pipeline at about MP 140.5. 

State Route 72 Widening, Reconstruction, and Relocation Project

On January 10, 2006, the Georgia DOT held a public information open house for the State Route 

72 Widening, Reconstruction, and Relocation Project (SR 72 Project) in Elbert County. The SR 

72 Project includes a total of 14.4 miles of widening and reconstruction of existing two and four 

12-foot-wide lanes with 10-foot shoulders to four 12-foot lanes with flush median. The SR 72 

Project intersects the Elba Express route at about MP 169.3 and is about 0.2 mile north of 

Construction Yard CEL-001. 

Planned Developments in Effingham County, Georgia

Research Forest Tract (“Tract B”) is owned by the Effingham County Industrial Development 

Authority and consists of 1,752 acres of land that is slated for industrial development within the 

next 5 to 10 years. Tract B is located near approximate MP 7.4 of the Elba Express Pipeline. 

Proposed residential developments along the Elba Express Pipeline include the Braniger and 

Stafford Shire Estates also near approximate MP 7.4 and Parkway Place near approximate MP 

14. 

Thomas-McDuffie Regional Airport Runway Expansion Project

The Thomas-McDuffie Regional Airport is about 6 miles east of the Elba Express Pipeline route 

at MP 128.5. The airport has a 5,200-foot-long runway, and the expansion project includes an 

expanded 5,500-foot-long runway and new corporate aircraft hangars. 

4.13.1 Geology 

The Elba III Project would have minimal impacts on geologic resources because blasting would 

not be required on the Terminal Expansion site; however, blasting may be required along the 

Elba Express Pipeline route. Blasting could be required along the along widening and 

reconstruction projects in Jefferson, McDuffie, Wilkes, and Elbert Counties, Georgia, should 

Georgia DOT encounter bedrock at or near the surface. If required, we expect that Georgia DOT 

would conduct blasting in accordance with all federal, state, and local regulations as EEC would. 

If topographic contours and drainage conditions for each of the projects would be restored to the 

extent practicable, cumulative impact on regional drainage patterns would be avoided or 

minimized. 
 4-248 4.0 – Environmental Impact Analysis 

In Elbert County, Georgia, the Elba Express Pipeline route would be within 2,500 feet of six 

mining operations. Although the SR 72 Project in Elbert County would involve the widening 

and reconstruction of 14.4 miles of roadway, we have not identified any mining operations that 

this project would affect. Although mineral resources within or near the pipeline ROW would be 

precluded from the extraction of gravel and other minerals, we do not expect a cumulative 

impact on these resources because the Georgia DOT roadway project would be located adjacent 

to existing roadways that already preclude mining. 

4.13.2 Soils 

Clearing and grading associated with construction of the Terminal Expansion Project, SAIT, and 

the Garden City and Ocean Terminals could accelerate the soil erosion process and, without 

adequate protection, could result in discharge of sediment to adjacent waterbodies and wetlands. 

Soil loss due to erosion could also reduce soil fertility and impair revegetation. Southern LNG 

would implement its Plan to establish a baseline for minimizing the potential for erosion as a 

result of water or wind action and to aid in reestablishing vegetation after construction. In 

addition, Southern LNG would implement the project-wide Spill Plan that provide guidance 

erosion control and stormwater management. None of the land within the Terminal Expansion 

site is currently under active cultivation, and no prime farmland would be permanently converted 

as a result of the Terminal Expansion Project. The SAIT and Garden City and Ocean Terminals 

would also comply with regulations that pertain to construction disturbances to soils and 

mitigation. Therefore, we do not expect the Terminal Expansion Project to significantly 

contribute to the cumulative impact on soils. 

The Elba Express Pipeline would be located within Southern’s existing multi-pipeline easement 

for about 106 miles between MPs 0.0 to MP 106.1. Because a 125-foot-wide construction ROW 

would be used to construct the pipeline, soil disturbance within the first 106.1 miles would be 

1,607.6 acres, including a portion of Southern’s existing ROW. In addition to this amount, 

Southern’s existing pipeline ROWs previously disturbed about 524.0 acres of soils. Cumulative 

soil disturbance along this portion of Southern’s existing pipeline ROW is 2,131.6 acres. In 

addition, the Georgia DOT widening and reconstruction projects in Jefferson, McDuffie, Wilkes, 

and Elbert Counties could disturb between 922.7 and 1,937.0 acres of soils. 

Potential cumulative erosion could occur where construction disturbance areas overlap between 

MPs 0.0 and 106.1. However, Southern’s existing pipelines have been installed for a number of 

years and the construction ROWs have been partially or completely restored to pre-existing 

conditions. EEC would implement its Plan and BMPs for soil management and protection would 

be applied across all ownerships for each pipeline project. Revegetation mixtures would be 

applied that are appropriate to soil conditions and expected future uses. As a consequence, the 

potential for cumulative erosion caused by one or more of these pipeline projects is low because 

consistent erosion control practices would be applied, and structural erosion control measures 

would be integrated between adjacent pipeline projects. We expect that Georgia DOT would 

also be required to implement BMPs for soil management and protection. Therefore, we do not 

expect the Elba Express Pipeline to significantly contribute to a cumulative impact on soils. 
 4-249 4.0 – Environmental Impact Analysis 

4.13.3 Water Resources 

As noted in table 4.13-1, the SAIT and SHEP would involve dredging activities. Although the 

volume of dredged material that would be generated to develop the SAIT is unknown, up to 27 

million cubic yards of sediment would be dredged as a result of the SHEP. About 72,000 cubic 

yards of material would be dredged for the proposed Terminal Expansion Project, which would 

account for only about 0.2 percent of the dredge material to be produced for these future projects. 

Maintenance dredging of the Savannah Harbor navigation channel is performed annually by the 

COE. The Terminal Expansion Project would only marginally increase the volume of material 

generated by maintenance dredging required for the existing berthing slip at Elba Island, which 

is currently about 230,000 cubic yards each year. The dredged sediments for the SHEP would be 

deposited at existing CDFs along the Savannah River whereas the sediments generated for the 

Terminal Expansion Project would be piped into one of two upland CDFs owned and operated 

by Southern LNG on the northwest end of Elba Island. Increased turbidity and sedimentation 

from initial dredging during the deepening of the navigation channel and modification of 

Southern LNG’s existing berthing area, in addition to future maintenance dredging, would 

temporarily decrease water quality in the immediate vicinity of each project. If dredging 

associated with the Terminal Expansion Project were to occur concurrently with the SHEP, the 

reduction in water quality could be exacerbated. However, the negative effects of dredging in 

and adjacent to the existing Savannah River navigation channel would be temporary, and water 

quality would be expected to return to ambient conditions soon after completion of activities. 

We do not expect the Terminal Expansion Project to significantly contribute to the cumulative 

impact on water resources or the disposal of dredged material in the project area. 

The proposed Elba Express Pipeline would require the crossing of 353 waterbodies, of which 

161 would be perennial waterbodies. Cumulative effects on surface water resources affected by 

the Elba Express Pipeline would be limited primarily to waterbodies that are affected by other 

projects located within the same major watersheds. Direct in-stream effects associated with 

open-cut crossings would result in the greatest impact on water resources. Runoff from 

construction activities near waterbodies could also result in cumulative impacts, although this 

effect would be relatively minor. Most of the projects listed in table 4.13-1 are within the same 

major watersheds crossed by the Elba Express Pipeline, and some of these projects (e.g., Georgia 

DOT widening and reconstruction projects) would likely involve direct in-stream impacts. 

To minimize impacts on surface water resources, we expect that each project proponent would 

implement BMPs for crossing waterbodies as EEC has proposed in its Procedures. In addition, 

each proponent would comply with applicable local, state, and federal permit requirements for 

each waterbody crossing. Waterbodies that were crossed as part of Southern’s existing pipeline 

system (between MPs 0 and 106.1) have been mitigated to an acceptable level. In general, 

impacts from pipeline construction across surface waters are short-term, and no long-term or 

cumulative effects on the waterbodies crossed by the proposed, past, and foreseeable future 

projects would be expected following mitigation and restoration. 
 4-250 4.0 – Environmental Impact Analysis 

4.13.4 Wetlands 

The projects listed in table 4.13-1 would likely permanently impact tidal flats, salt marsh, and/or 

freshwater wetlands. Each proponent would be required by the terms and conditions its 

respective Section 404 permits to provide compensatory mitigation for unavoidable wetland 

impacts. The construction and operation of the proposed Elba III Project, along with the other 

potential projects and activities, could result in a cumulative reduction in the amount of wetlands 

in the vicinity of the project. However, proposed and required mitigation for wetlands affected 

by the proposed Elba III Project and the other projects listed could result in a net increase and/or 

improvement in the regional coastal marsh resource. Dredged material placement for the 

Terminal Expansion Project, SAIT, and SHEP could result in the creation of shallow emergent 

wetlands along the Savannah Harbor navigation channel area. 

The locations where cumulative impacts on wetlands would occur are where the Elba Express 

Pipeline route and Southern’s existing pipeline system would be collocated between MPs 0.0 and 

106.1. However, wetlands along Southern’s existing pipeline system ROWs (between MPs 0 

and 106.1) have been mitigated to an acceptable level. Cumulative impacts on forested wetlands 

could occur along the ROWs since both EEC and Southern would remove trees within 15 feet of 

the pipeline centerline as part of their vegetative maintenance programs. EEC would apply its 

Procedures, and would be subject to conditions contained in the COE’s Section 404 permits and 

state water quality permits. As discussed in section 4.4.2, impacts from the pipeline on wetlands 

would generally be temporary, and none of the wetlands would be permanently drained or filled 

for operation of the Elba Express Pipeline. 

4.13.5 Vegetation and Wildlife 

When projects are constructed at or near the same time, the combination of construction 

activities could have a cumulative impact on vegetation and wildlife living in the immediate 

area. Clearing and grading and other construction activities associated with the Elba III Project, 

along with other area construction projects, would result in the removal of vegetation, alteration 

of wildlife habitat, displacement of wildlife, and other secondary effects such as increased 

population stress, predation, forest fragmentation, and establishment of invasive plant species. 

The construction of multiple large industrial projects at or near the same time can result in a 

significant amount of land clearing activities that could have a cumulative impact on forest 

resources in the immediate area of the projects. However, the Terminal Expansion site is devoid 

of trees. The total amount of vegetation that may be affected by the Elba Express Pipeline 

project, Georgia DOT widening and reconstruction projects, and planned developments could 

appear large but still relatively minor compared to the abundance of similar vegetation cover 

types and wildlife habitats in the project area. Impacts resulting from construction of the 

pipelines and roadways would result in the long-term and permanent loss of woody vegetation 

and would cause a small incremental increase in fragmentation of forested areas. 

During construction activities, mobile species would be able to relocate to adjacent habitat and 

then reoccupy open project lands after they have been restored. We believe that all of the 

projects would make use of mitigation measures designed to minimize the potential for erosion, 
 4-251 4.0 – Environmental Impact Analysis 

revegetate disturbed areas, increase the stabilization of site conditions, and in many cases control 

the spread of noxious weeds, thereby minimizing the degree and duration of the cumulative 

impact on vegetation and terrestrial wildlife from these projects. 

4.13.6 Aquatic Resources 

No brackish marsh or intertidal mud flat habitat would be impacted by the Terminal Expansion 

Project; however, minor temporary effects on subtidal soft sediments and the water column 

would occur during modifications to the existing berthing slip. Deepening the Savannah Harbor 

navigation channel as part of the SAIT and/or SHEP would impact aquatic habitats including 

brackish and salt marshes and unconsolidated bottom habitats. As a result of this dredging, these 

habitats would be converted to deeper water, and maintained as such through periodic 

maintenance dredging. Most other impacts associated with dredging would be short-term, such 

as localized increased turbidity during dredging operations. Impact on submerged aquatic 

vegetation would be addressed through compensatory mitigation. 

Cumulative impacts to egg and larval species from ballast and cooling water withdrawal would 

be expected to be minimal. The proposed project could add up to 95 additional vessels per year 

(a 3 percent increase in current commercial shipping on the Savannah River). Vessel water 

intakes have bars spaced 0.5 inch apart and flow control measures to lessen the likelihood of 

entrainment of juvenile and adult fish species. As stated in section 4.6.2.3, egg and larvae 

species generally occur in shallow, nearshore areas, while ballast and cooling water intakes are 

located near the bottom of the vessels (about 30 feet in depth), thereby lessening the impacts. 

While current impacts associated with ballast water withdrawal are unknown, the incremental 

increase in shipping would not appreciably add to the current impacts. 

As with surface water resources, cumulative impacts on fisheries resources would be limited 

primarily to waterbodies that are affected by other projects located within the same major 

watersheds. Potential impacts on fisheries resources resulting from pipeline construction and 

other types of project construction activities (i.e., Georgia DOT widening and reconstruction 

projects) can include sedimentation and turbidity, alteration or removal of instream and stream 

bank fish cover, and introduction of water pollutants. To minimize impacts on fisheries, EEC 

would implement its Procedures, and other project proponents would comply with local, state, 

and federal permit requirements. In general, impacts from pipeline construction across surface 

waters are short-term, and no long-term or cumulative effects on fisheries would be expected 

following mitigation and restoration. 

4.13.7 Special Status Species 

Because about 106.1 miles (56 percent) of the Elba Express Pipeline would be collocated with 

Southern’s existing pipeline system, we believe that this configuration has the potential to affect 

special status species suitable habitat discussed in section 4.7.1 and 4.7.2 of this EIS. EEC 

would be required to consult with federal, state, and local agencies to determine which species 

may occur within its project area, evaluate potential impacts on those species as a result of 

construction and operation, and implement measures to avoid, minimize, or mitigate impacts on 

special status species and their habitats. As part of Southern’s installation of its existing pipeline 
 4-252 4.0 – Environmental Impact Analysis 

system, it was required to do the same. Thus, we believe that the cumulative impacts on special 

status species and their habitats would not be significant. 

4.13.8 Land Use and Visual Resources 

The Elba III Project would incrementally add to the cumulative impact of changes in on land 

uses in the project area. The majority of this additional impact would be permanent; however, 

the proposed Terminal Expansion site is currently dedicated to industrial use. The Garden City 

Terminal expansion would be adjacent to industrial lands and near a residential area, and the 

Ocean Terminal expansion would be within an existing area of industrial use. 

Although the Terminal Expansion would have some visual impact on the immediate 

surroundings, this element of the proposed action would be consistent with ongoing industrial 

activities and existing facilities along the Savannah Harbor navigation channel, and would not 

significantly alter the visual landscape of the area. Along the Elba Express Pipeline, construction 

work areas would be restored, as near as possible, to pre-construction contours and revegetated. 

Once revegetation is complete, there would be no significant cumulative alteration of the 

landscape in the region. 

Fishing, boating, and other recreational activities take place in and adjacent to the Savannah 

River. The potential increase of 95 LNG vessels per year associated with the Terminal 

Expansion, the potential for increased vessels traffic associated with the expansions of the 

Garden City and Ocean terminals, and the possible construction of the SAIT could have 

cumulative impact on recreational boating. 

Where the Elba Express Pipeline would be collocated with Southern’s existing pipeline system 

(Port Wentworth to Wrens, MPs 0-104.8), most land uses, except forest and planted pine, would 

be allowed to revert to pre-construction uses following construction. Some land uses would be 

restricted or prohibited on the new permanent pipeline ROW, such as construction of 

aboveground structures. The construction work areas would be restored, as near as possible, to 

pre-construction contours and revegetated. Once revegetation is complete, there would be no 

significant cumulative alteration of the landscape in the region. Most of the Northern Segment, 

however, would be “greenfield” pipeline, establishing a new ROW. While the new ROW would 

be noticeable (after revegetation) only where forested areas are crossed, the impact would be 

noticeable where it crosses areas of high public use (roads and highways). The proposed 

compressor station, meter stations, block valves, and other aboveground facilities would have 

more visual impact than the buried pipeline. Of the projects listed in table 4.13-1, the proposed 

planned developments would have the most impact on visual resources in the area, resulting 

from the loss of vegetation and construction of permanent aboveground structures. Although 

EEC’s 106.1-mile-long collocation of its proposed pipeline with Southern’s existing pipeline 

system would incrementally reduce the area available for future development, use of established 

utility corridors minimizes cumulative land use impacts. 
 4-253 4.0 – Environmental Impact Analysis 

4.13.9 Socioeconomics 

The Elba III Project and the projects listed on table 4.13-1 would generate temporary 

construction jobs. Many of these workers would reside locally. The influx of non-local laborers 

could represent an increase in the percent of the total population in the project area (assuming 

half the construction workers are non-local). The potentially vacant or rental units available in 

the project area would offer enough housing for non-local workers. Likewise, the counties have 

the necessary infrastructure to provide public services and utilities to support the projects. No 

identified minority or low-income populations would be disproportionately impacted by the 

projects. 

There would be positive cumulative economic benefits from these projects. Taxes generated 

from operation of the Terminal Expansion Project, Garden City and Ocean terminals, the SAIT, 

and planned developments would result in an annual tax revenue increase. Permanent 

employment would also increase as a result of the operation of these projects, with the 

cumulative benefit of potentially lowering local unemployment rates. 

4.13.10 Marine Transportation 

Vessel traffic on the Savannah River has increased by about 15 percent over the last decade. The 

Georgia Port Authority indicated that rapid growth rates are expected for future operations. In 

2002, the Georgia Port Authority served 2,180 vessels carrying 1.137 million TEUs. In 2005, 

total TEUs increased to 1.76 million. By 2015, the Georgia Port Authority estimates that the 

Port of Savannah would have the capacity to handle 4.37 million TEUs, an almost 11 percent 

annual increase in the number of containers over the 2002 level. When fully operational, the 

Terminal Expansion would result in about 95 additional shipments of LNG per year. Assuming 

full utilization of the Elba Island LNG Terminal it would receive a total of 142 to 299 shipments 

of LNG per year (number varies depending on the size of the LNG vessel). This would be a 

modest addition in terms of the overall increase in vessel traffic entering the Savannah River 

entrance channel. While an LNG vessel is docked at the Terminal, the channel would remain 

available for vessels and boats to pass the facility. Consequently, unloading operations at the 

Terminal should not impede or otherwise adversely affect vessel traffic in the river. 

4.13.11 Land Transportation 

The Terminal Expansion Project, Garden City and Ocean terminals, Elba Express Pipeline, 

Georgia DOT widening and reconstruction projects, and planned developments in the Elba III 

Project area would increase daily vehicle trips during peak construction periods. If all these 

projects were to be constructed at the same time, traffic would increase on the major 

thoroughfares near each of the project sites. However, given the spatial distribution of the 

projects and the limited amount of time pipeline construction would remain in any one area, 

significant cumulative impact is not expected. It is also unlikely that all of the projects would be 

under construction at the same time. Operation of these projects would result in an increase in 

daily vehicle trips entering and exiting the Terminal and development sites; however, potential 

cumulative impact is expected to be minor. 
 4-254 4.0 – Environmental Impact Analysis 

4.13.12 Cultural Resources 

Past disturbances to cultural resources in the project area have resulted from agricultural and 

mining practices, intentional destruction or vandalism, and construction and maintenance 

operations associated with existing roads, railroads, utility lines, and electrical transmission line 

ROWs. The projects listed in table 4.13-1 that are defined as federally regulated projects would 

include mitigation measures designed to avoid or minimize additional direct impacts on cultural 

resources. Where direct impacts on significant cultural resources are unavoidable, mitigation 

(e.g., recovery and curation of materials) would occur before construction. Non-federal actions 

would need to comply with any identification procedures and mitigation measures required by 

the State of Georgia. Additionally, EEC has developed project-specific plans to address 

unanticipated discoveries of cultural resources and human remains in the event they are 

discovered during construction. The proposed Elba Express Pipeline project would only 

incrementally add to the effects of other projects on cultural resources in the area. 

4.13.13 Air Quality and Noise 

Construction of the proposed Elba III Project and some of the reasonably foreseeable projects 

and activities listed in table 4.13-1 would involve the use of heavy equipment that produces 

noise, air contaminants, and dust. Operation of the proposed Elba III Project (including the 

Terminal and vessels delivering LNG to the Terminal) and some of the reasonably foreseeable 

projects would also contribute cumulatively to ongoing air emissions and noise. 

Although the region is currently in attainment with air quality standards, increases in point 

industrial sources could have a deleterious effect on local and regional air quality. If all of the 

proposed projects are built, there could be an increase in emissions during construction and 

operation. Each of the individual projects would need to apply to the GADNR for an air quality 

permit, which may require controls to limit the emission of certain criteria pollutants or HAPs. 

During operation of the LNG terminals listed in table 4-13-1, air emissions from LNG marine 

traffic and other project related vessels would occur along the entire waterway from the 

boundary of territorial waters to the vessel berths. Due to the transitory nature of these mobile 

sources and the large area covered, the associated emissions would not have a significant 

cumulative impact on air quality along the waterway. 

As discussed in section 4.11.1, detailed modeling was performed to quantitatively evaluate the 

impacts from operation of the expanded Elba Terminal and significant regional sources by its 

self against the NAAQS. The analysis indicated that the expanded terminal and would not cause 

the NAAQS to be exceeded. Further, analysis of potential impacts to Class I areas within 300 

km of the facility indicated that neither the allowable PSD increment nor the AQRV would be 

exceeded. Therefore, the project is not considered to be significant and no further Class I area 

analysis is required. 

The Elba III Project and those listed in table 4.13-1 may affect ambient noise levels during 

construction. Noise produced during construction of the projects could create short-term 

annoyances to some residences, and could have short-term impacts on some marine mammals. 
 4-255 4.0 – Environmental Impact Analysis 

Noise impacts during the construction phase would be localized and would attenuate quickly as 

the distance from the noise source increases. However, because construction proceeds as a 

moving assembly line along the pipelines, the duration of construction activities, and therefore 

noise impacts, at any one location would be limited and short-term. Therefore, cumulative noise 

impacts associated with construction of all of the projects are not anticipated to be significant, 

even in the unlikely event that multiple projects occur at the same time and in the same location. 

The closest NSAs to the Elba Express Compressor Station are located 1,400 feet west (NSA 1) 

and 3,500 feet east-southeast (NSA 2) of the compressor station. As discussed in section 4.11.2, 

the noise analysis indicated that increases in noise at NSA 1 would be on the order of 6 dBA; 

however, project noise levels would remain below our noise criterion. Increases in noise at NSA 

2 would be less than 1 dBA and project noise levels at this location would be well below our 

criterion. Based on the noise analyses conducted, we conclude that no significant noise impacts 

would occur with operation of the compressor station. 

4.13.14 Reliability and Safety 

Impacts on reliability and public safety would be mitigated through the implementation of 

applicable federal, state, and local rules and regulations for each individual project. The specific 

rules and regulations that apply to each individual project would ensure that the applicable 

design standards are implemented to protect the public and to prevent accidents and failures. 

The Terminal Expansion Project would be sited, designed, constructed, operated, and maintained 

in compliance with the federal safety standards summarized in table 2.7-1. 

Several of the present or reasonably foreseeable future projects, including the proposed Elba III 

Project, would involve cargo terminals that could be expected to vessel hazardous materials. 

Accidents involving such materials represent a potential impact on public safety. Continued 

growth in international commerce is likely to result in increased quantities of hazardous 

materials being shipped to and from the region. 

It is difficult to evaluate the cumulative risk that such growth represents or has represented. The 

Terminal Expansion and associated increase in LNG vessel traffic would not significantly 

change the risk of an intentional attack in the Savannah Harbor navigation channel. It is 

reasonable to assume that the rate of vessel accidents (including those involving the release of 

hazardous materials) is likely to rise with more vessel traffic, which could cumulatively increase 

the risk of an accident having an impact on public safety. As discussed in section 4.9.6.1, the 

Savannah River Pilots manage vessel traffic to ensure safe transit in the Savannah Harbor 

navigation channel. The Coast Guard would also enforce a moving safety zone and moored 

vessel security zone around LNG vessels. These and other operational controls by the Coast 

Guard and Savannah River Pilots would minimize the risk of accidents involving LNG vessels. 

Furthermore, the implementation of federal, state, and local rules and regulations concerning 

security and the results of the WSA with its associated operations and Emergency Response Plan 

would minimize the risk to the LNG vessels and Terminal. 

Emergency response time is a key aspect of public health and safety. No significant cumulative 

impacts on emergency services are expected during construction or operation of the proposed 
 4-256 4.0 – Environmental Impact Analysis 

project because sufficient emergency services and facilities exist in the area to accommodate the 

cumulative projects. Section 4.12.5 includes our recommendation that Southern LNG prepare a 

modified Emergency Response Plan and coordinate procedures with local emergency planning 

groups, fire departments, state and local law enforcement, the Coast Guard, and other appropriate 

federal agencies to be used in the event of an incident. Southern LNG would be required to 

prepare a comprehensive plan that identifies the cost sharing mechanisms for funding these 

emergency response costs. With the implementation of the coordination procedures in the 

Emergency Response Plan and the funding of additional emergency management equipment and 

personnel, no cumulative impacts would be expected on emergency response services during 

operation of the proposed Project. 

The pipelines and aboveground facilities associated with the Elba Express Pipeline would be 

designed, constructed, operated, and maintained in accordance with DOT Minimum Federal 

Safety Standards in Title 49 CFR Part 192. We believe that no cumulative operational safety 

impacts are expected for the portions of the proposed Elba Express Pipeline or existing Southern 

pipeline system located in the same general utility corridor because of the spacing between 

pipelines, the depth of soil cover, and requirements to meet DOT Minimum Federal Safety 

Standards, which are intended to protect the public and to prevent natural gas facility accidents 

and failures. 

4.13.15 Conclusion 

A determination of significance for the cumulative impacts for a specific resource is problematic 

because well-defined threshold values are typically undetermined. However, the majority of 

impacts we have identified for the proposed Elba III Project would be temporary and minor. 

Consequently, their addition to other reasonably foreseeable impacts in the region does not result 

in an overall significant cumulative impact.