PROPOSED ACTION

SECTION 2

2-1 Proposed Action

2.0 PROPOSED ACTION

The Cameron Liquefaction Project consists of two main components: (a) expansion of 

the existing Cameron LNG Terminal in Cameron and Calcasieu Parishes near Hackberry, 

Louisiana, and (b) expansion of the Cameron Interstate Pipeline through construction of about 

20.9 miles of new 42-inch-diameter natural gas pipeline and appurtenant facilities in Cameron,

Calcasieu, and Beauregard Parishes. Figure 2.0-1 depicts the general location of the Project. 

Figure 2.0-2 depicts the locations of the key components of the proposed Terminal Expansion. 

Maps of the proposed pipeline facilities are provided in figure 2.0-3 and in Appendix B–Pipeline 

Expansion Route Maps.

2.1 EXISTING FACILITIES

2.1.1 Cameron LNG Terminal

The existing Cameron LNG Terminal encompasses 118.6 acres and is about 2 miles north 

of the City of Hackberry on the west side of the Calcasieu Ship Channel. Cameron LNG 

constructed the existing terminal to regasify and transport natural gas imported to the United 

States from foreign markets. In 2003, the terminal was authorized9 by the Commission to send 

out 1.5 billion cubic feet per day (Bcfd) of natural gas, and in 2007 Cameron LNG received 

authorization10 to increase sendout to 1.8 Bcfd. The environmental reviews for the existing 

Cameron LNG Terminal and for the increased sendout capacity were provided in the FERC final 

EIS issued in August 2003 and in the FERC Environmental Assessment (EA) issued in 

November 2006, respectively.

The LNG terminal was placed into service in July 2009. In 2011, the Commission 

authorized Cameron LNG to export previously imported (foreign-sourced) LNG on behalf of its 

customers.

11 The FERC issued an EA for exporting foreign-sourced LNG in August 2010. A

maximum of 210 LNG carriers per year are currently authorized to import or export foreign 

LNG at the two marine berths of the terminal at a rate of up to 12,000 m3 per hour per carrier 

over a 12- to 17-hour period. Both the frequency and number of LNG carriers can vary 

depending on the size of carriers calling on the Cameron LNG Terminal, with vessel sizes 

ranging from 125,000 to 217,000 m3

. LNG carriers destined for the LNG terminal take on pilots 

at the pilot boarding area approximately 30 miles offshore of Louisiana (CC Buoy). From that 

point the LNG carriers transit the gulf to the entrance of the Calcasieu Ship Channel and 

complete the transit at the berthing facilities of the LNG terminal at river mile (RM) 18.3 of the 

channel. The average frequency of LNG carriers that could call on the LNG terminal is about 

one carrier every 1.5 to 3 days.

 9 Authorized on September 11, 2003 (FERC Docket No. CP02-374) 10 Authorized on January 18, 2007 (FERC Docket No. CP06-422) 11 Authorized on January 20, 2011 (FERC Docket No. CP10-496)
Proposed Action 2-2

Figure 2.0-1 General Project Location
2-3 Proposed Action

Figure 2.0-2 Liquefaction Pipeline Site Map
Proposed Action 2-4

Figure 2.0-3 Pipeline Expansion Route and Facilities
2-5 Proposed Action
Proposed Action 2-6
2-7 Proposed Action

The existing Cameron LNG Terminal includes the following major facilities:

• one ship unloading slip with two berths on the Calcasieu Ship Channel, each 

equipped with mooring and breasting dolphins and four arms (including two 

liquid unloading arms, one vapor return arm, and one “hybrid” arm that would be 

capable of both loading/unloading LNG and vapor return);

• three LNG storage tanks, each with a usable volume of 160,000 m3; 

• LNG sendout facilities, including 17 pumps, 10 submerged combustion 

vaporizers, and three boil-off gas (BOG) compressors;

• hazard detection, control, and prevention systems, cryogenic piping and 

insulation, and electrical and instrumentation systems; 

• a firewater system;

• a natural gas liquids recovery unit; and

• ancillary utilities, buildings, and service facilities.

2.1.2 Cameron Interstate Pipeline

Cameron Interstate owns and operates the 36-mile-long, 42-inch-diameter natural gas 

sendout pipeline that was constructed in conjunction with the Cameron LNG Terminal. The 

pipeline extends from the existing terminal through Cameron and Calcasieu Parishes and 

terminates at the LA Storage, LLC’s (LA Storage) Ragley Compressor Station in Beauregard 

Parish.12 Associated pipeline facilities include mainline valves and interconnections with the 

Transco, TETCO, FGT, and TGP systems, through which gas is delivered to end users (Sempra 

2012). The existing Cameron Interstate Pipeline has an interconnection and a metering and 

regulation station at the existing Cameron LNG Terminal. 

2.2 PROPOSED FACILITIES

2.2.1 Terminal Expansion

The Terminal Expansion facilities would be constructed on about 502 acres, including

about 70 acres within the existing terminal boundaries (figure 2.0-2). Cameron LNG has not 

requested a change to the currently authorized size, number, or transit route of the LNG carriers

(discussed in section 2.1.1). 

2.2.1.1 Liquefaction Facilities

Trains, Utilities, and Systems

Cameron Interstate’s existing pipeline and its proposed Pipeline Expansion (see section 

2.2.2) would transport natural gas (feed gas) to the liquefaction facilities at the expanded 

terminal. The liquefaction facilities would consist of three liquefaction trains, each composed of 

 12 The Ragley Compressor Station is owned by LA Storage, and is not a Cameron Interstate asset. Both Cameron 

Interstate and LA Storage are affiliates of Sempra U.S. Gas and Power.
Proposed Action 2-8

a natural gas pre-treatment unit, heavy hydrocarbon removal unit, and liquefaction unit (figure 

2.0-2). Before liquefaction, the feed gas would be pre-treated for removal of mercury, hydrogen 

sulfide, carbon dioxide (CO2), and water. The heavy hydrocarbon removal unit would then 

remove components in the feed gas such as pentane, hexane, and benzene. During the heavy 

hydrocarbon removal process, hydrocarbons lighter than pentane (i.e., methane, ethane, propane,

and butane) would either be recycled to the beginning of the liquefaction process (described 

below) or routed to the fuel gas system. The heavier hydrocarbons (i.e., pentane and hexane, 

also known as stabilized condensate) that could freeze in the liquefaction process would be sent 

to the condensate storage, and a third party would transport it offsite, as discussed in section 1.4. 

After being treated to remove the contaminants and heavy hydrocarbon components, the 

liquefaction process would condense the natural gas into a liquid at -260 degrees Fahrenheit (

o

F). 

The liquefaction process would primarily consist of the Main Cryogenic Heat Exchanger, 

refrigeration units, and the End Flash Gas system. Cameron LNG proposes to use nitrogen, 

methane, ethylene, and propane as mixed refrigerants to liquefy the natural gas. The End Flash 

Gas system would essentially produce fuel gas for the turbines. Liquefaction utility components

would include a BOG system, fuel gas system, hot oil system, flares, instrument and utility air 

systems, and a demineralization water unit. The liquefaction process would generate BOG from 

the transfer of heat in system components that would be diverted to three new BOG compressors 

within the existing LNG terminal. The fuel gas system would receive compressed BOG, with

excess BOG recycling back through the liquefaction process. 

During normal operations, an amine unit (which is part of the pre-treatment process) 

would require demineralized make-up water to replace water losses to the feed gas stream. 

Cameron LNG would use water recovered from the inlet gas dehydration and demineralization

system to provide make-up water. Cameron Parish Waterworks, District 2 would also supply 

water from an existing water system connection.

Cameron LNG would install five flares on the northern portion of the Terminal 

Expansion site for venting excess natural gas, if necessary. Cameron LNG would construct three 

of the five flares on a common support structure, with the remaining two low-pressure flares on a 

separate structure (figure 2.0-2). 

2.2.1.2 LNG Storage

Cameron LNG would increase its LNG storage capacity by adding one 160,000 m3 LNG 

storage tank designed to store 1,006,000 barrels of LNG at a temperature of -260 °F at a normal 

pressure of 1 to 4 pounds per square inch gauge (psig). The proposed storage tank is the same 

size and design as the three existing LNG storage tanks at the terminal. As indicated on figure 

2.0-2, Cameron LNG would install the LNG storage tank within the boundaries of the existing 

terminal, adjacent to the existing storage tanks. The new tank would have a primary and a

secondary container capable of independently containing the stored LNG. The primary container 

would have a 9 percent nickel steel inner container with a secondary pre-stressed concrete outer 

container wall, reinforced concrete outer container bottom, reinforced concrete domed roof, and

an aluminum insulated support deck. The primary and secondary containers could hold 

cryogenic liquid under normal operating conditions, but the secondary container would also 

control vapor resulting if product were released from the primary container.
2-9 Proposed Action

2.2.1.3 Truck Unloading and Refrigerant and Condensate Storage 

Cameron LNG would construct and operate a trucking facility to unload make-up 

refrigerant (propane and liquid ethylene) transported to the expansion site for storage and use 

during the liquefaction process. Cameron LNG would store propane in two pressurized storage 

tanks, each with a maximum capacity of approximately 120,500 gallons, and would store liquid 

ethylene in a tank with a dedicated refrigerant system. The ethylene refrigerant storage would 

have a maximum capacity of 46,250 gallons. 

As discussed in section 2.2.1.1, the heavy hydrocarbon removal unit within each of the 

liquefaction trains would continuously produce stabilized condensate at an average rate of 

approximately 31 gallons per minute (gpm) during the liquefaction process. Cameron LNG 

would temporarily store the stabilized condensate in two low-pressure storage tanks prior to 

delivery to third-party customers by truck or by pipeline (see section 1.4). 

2.2.1.4 Power Generation

To provide electrical power to the Terminal Expansion, Entergy would build an 

approximately 12-mile-long double-circuit 230-kV electric transmission line in Calcasieu and 

Cameron Parishes. The electric transmission line would be considered non-jurisdictional, as 

discussed in section 1.4. Three 1.5-megawatt (MW), diesel-fueled stand-by generators would 

provide emergency backup power to all systems. Each generator would have the capacity to 

provide power for terminal start-up and power in support of pre-commissioning activities. 

Backup emergency power would also provide for critical uses such as instrument air, emergency 

lighting, heating, ventilation, and air conditioning for control systems. An on-site 55,000-gallon 

diesel storage tank (with proper secondary containment) would store enough fuel required for 3 

days of backup power generation. 

2.2.1.5 Work Dock

Cameron LNG would construct a work dock along the western bank of the Calcasieu 

Ship Channel north of the existing marine basin for barge delivery of large equipment, 

construction materials, and other construction loads. During operation, the work dock would

remain in-service for delivery of maintenance equipment and materials and as a base for 

maintenance dredging. The proposed dock is designed to accommodate two barges 

simultaneously, with the barges berthed parallel to the ship channel. The dock would have rollon roll-off capability to allow the use of modularization assembly for terminal facilities, if 

required.

Figure 2.2-1 provides a conceptual design for the proposed work dock, which would be 

about 700 feet long and 300 feet wide. Cameron LNG would construct the edge of the dock 

about 375 feet from the western edge of the maintained ship channel, providing at least 250 feet 

between a moored barge and the edge of the maintained channel. Creation of the berth would 

require dredging of about 205,000 cubic yards (yd3

) of sediment to a depth of 15 to 16 feet (-15.0 

feet North American Vertical Datum of 1988). 
Proposed Action 2-10

Figure 2.2-1 Work Dock
2-11 Proposed Action

Barges would deliver loads to the work dock during construction and operation using 

several potential transit routes before entering the Gulf Intracoastal Waterway and the Calcasieu 

Ship Channel. Transit routes are described further in section 4.9.6.1. 

In addition, Cameron LNG would use an existing barge dock on the Gulf Intracoastal 

Waterway near Old Highway 27 to receive materials and equipment during construction. 

Cameron LNG used the existing barge dock and adjacent laydown area for the delivery of

aggregate and concrete piles during construction of the existing LNG terminal and would use

these facilities in a similar manner during construction of the Terminal Expansion. Use of the 

existing dock would not require upgrading the dock, dredging, or modification of the adjacent 

land for a laydown area.

2.2.1.6 Modifications to Existing Terminal Facilities

Several minor modifications to facilities at the existing LNG terminal are proposed as 

part of the Terminal Expansion. These modifications consist of the following:

• installation of larger pumps at the three existing LNG storage tanks to achieve a 

loading rate of up to 12,000 m3 per hour; 

• installation of one additional loading/unloading arm at each berth (constructed on 

existing foundations) resulting in five total arms at each berth. The proposed 

loading/unloading arms would be used for spare capacity; and 

• installation of three BOG compressors within the existing LNG terminal. 

2.2.1.7 Associated Infrastructure

During construction, Cameron LNG would use nine ramps and roads for access to the 

Terminal Expansion site from Louisiana Highway 27 (LA-27). Cameron LNG would install 

gates across the access points to provide public safety, limit access to the site, and provide 

security. In addition, Cameron LNG would install a series of 20-foot-tall vapor fences along a 

portion of the southwestern property boundary to confine the vapor cloud and limit the extent of 

the vapor dispersion zones in the event of an LNG spill. The location of the vapor fence is 

depicted on figure 2.0-2.

2.2.2 Pipeline Expansion 

Cameron Interstate proposes to construct and operate new pipeline facilities to enable bidirectional (north/south) flow capability. The flow capacity would be increased to a rate of up to 

2.33 Bcfd of domestic natural gas to the expanded terminal for liquefaction, storage, and marine 

services for exportation of LNG from domestic sources. 

2.2.2.1 Proposed Pipeline

The expansion would include about 20.9 miles of new 42-inch-diameter pipeline 

extending from Cameron Interstate’s existing interconnection with the FGT pipeline in Cameron 

Parish to the proposed interconnection with the Trunkline pipeline in Beauregard Parish (see 

figure 2.0-1 and Appendix B). Cameron Interstate would construct its pipeline within or parallel 
Proposed Action 2-12

and adjacent to existing rights-of-way for 100 percent of the pipeline route. About 15.5 miles, or 

74 percent, of the proposed pipeline would be collocated with the existing Cameron Interstate 

and LA Storage Pipeline easements, while the remaining 5.4 miles would be adjacent to Conoco 

Phillips, Cheniere, and Transco pipeline easements. 

2.2.2.2 Aboveground Facilities

Aboveground facilities associated with the proposed Pipeline Expansion consist of the 

Holbrook Compressor Station, two pig receivers,

13 two pig launchers, one new interconnection

(Trunkline), and ancillary facilities at four existing interconnections and the existing terminal.

Holbrook Compressor Station

The Pipeline Expansion would transport natural gas to the Holbrook Compressor Station

at MP 8.4 (see figure 2.2-2), where Cameron Interstate would compress the gas for transport to 

the Terminal Expansion in the existing Cameron Interstate Pipeline. The compressor station 

would include 12 natural gas-driven compressors (CAT G3616) for a total of 56,820 horsepower, 

compressor buildings, an office, and a control building. Cameron Interstate would install a 

backup power system consisting of a 1,250-kilowatt (kW) diesel-fueled generator and a 2,400-

gallon diesel storage tank, with appropriate secondary containment. Two pig receivers would 

also be installed at the compressor station.

Pipeline Interconnection and Metering Facilities

The new interconnection with Trunkline is proposed at MP 20.8 (see Appendix B). In

addition, Cameron Interstate would construct a new meter skid, an electronic gas measurement 

building, and a pig launcher at this site. To increase capacity at four existing interconnections, 

Cameron Interstate would install additional appurtenant facilities adjacent to the existing 

Transco, TETCO, TGP, and FGT interstate pipeline system interconnects for flow metering and 

control. New metering facilities would be installed adjacent to the existing metering and 

regulation facilities within the existing LNG terminal. 

2.3 LAND REQUIREMENTS

Cameron would disturb about 823.6 acres of land and open water for construction of the 

Project and 590 acres for its operation. Operation of the Terminal Expansion would permanently 

impact 502 acres of land, and operation of the pipeline would require about 88 acres of 

permanent right-of-way. Land requirements for the Project are summarized in table 2.3-1.

2.3.1 Terminal Expansion 

Construction and operation of the Terminal Expansion facilities would require about 502 

acres of land. Of the proposed 502 acres, approximately 70 acres is within the boundary of the 

existing terminal. During operation, Cameron LNG would maintain all 502 acres with concrete 

and gravel cover and permanently convert them to industrial use.

 

13 A pipeline “pig” is a device used to clean or inspect the pipeline. A pig launcher/receiver is an aboveground 

facility where pigs are inserted or retrieved from the pipeline.
2-13 Proposed Action

Figure 2.2-2 Holbrook Compressor Station
Proposed Action 2-14

TABLE 2.3-1

Land Requirements for the Proposed Cameron Liquefaction Project a

Facility Land Affected During 

Construction (acres)

Land Affected During 

Operation (acres) b

Terminal Expansion

Total Terminal Expansion 502.2 502.2

Pipeline Expansion

Pipeline with Additional Temporary Workspace Areas 252.1 67.8

Holbrook Compressor Station 17.6 15.3

FGT Interconnection 1.5 1.5

TGP Interconnection 1.4 1.4

Transco and TETCO Interconnection c 0.7 0.7

Trunkline Interconnection 0.2 0.2

Contractor Yard 10.6 0.0

Access Roads 37.4 1.2

Total Pipeline Expansion 321.5 88.1

Total Cameron Liquefaction Project 823.7 590.3

a

 The numbers in this table have been rounded for presentation purposes. As a result, the totals may not reflect the sum of 

the addends. 

b

 The portion of construction impacts that Cameron would permanently maintain.

c Transco and TETCO would be within the same workspace.

2.3.2 Pipeline Expansion Project

Construction of the pipeline and associated facilities would affect a total of about 322

acres, with operation affecting a total of about 88 acres (68 acres for the pipeline and 20 acres for 

aboveground facilities). 

2.3.2.1 Right-of-Way and Temporary Workspaces

Construction Right-of-Way 

Cameron Interstate proposes to use a 100-foot-wide construction right-of-way, except in 

the areas listed in section 2.6.3.2, that would impact about 252 acres. A total of 15.5 miles of the 

construction right-of-way would overlap with the permanent rights-of-way of the existing 

Cameron Interstate and LA Storage pipelines, and about 4.1 miles of the right-of-way would be 

adjacent to foreign utility permanent rights-of-way (see section 4.8.1.2 for details). Figure 2.3-1 

depicts the typical proposed construction right-of-way cross section adjacent to an existing 
2-15 Proposed Action

Figure 2.3-1 Typical Right-of-Way Cross Section Adjacent to 

Existing Pipeline
Proposed Action 2-16

pipeline. The remaining distance (about 1.3 miles) would be crossed by the horizontal 

directional drilling (HDD) construction method which would not require a temporary or 

permanent right-of-way as discussed in section 2.6.3. 

Permanent Right-of-Way

The permanent right-of-way for operation and maintenance of the pipeline would impact 

about 68 acres. In areas where the new pipeline would overlap the existing permanent right-ofway, Cameron Interstate would maintain an additional 25-foot-wide permanent right-of-way. 

Cameron Interstate would maintain a 50-foot-wide right-of-way for the 4.1 miles adjacent to 

foreign utilities.

Additional Temporary Workspace

Cameron Interstate proposes to use about 34 acres of additional temporary workspace 

(ATWS) at road, railroad, wetland, and waterbody crossings to provide extra space for 

construction activities and for excavated materials (subsoil) storage. Additionally, Cameron 

Interstate may request ATWS at other areas if site-specific conditions require them during 

construction, including at the following locations:

• pipe stringing truck and other equipment turnaround areas;

• foreign pipeline and utility line, drain tile, and irrigation system crossings;

• steep side slopes to create level working areas; and 

• full right-of-way topsoil segregation areas.

Although Cameron Interstate has identified areas where extra workspace would be 

required, additional or alternative areas could be identified in the future due to site-specific 

construction requirements. Cameron Interstate would be required to file information on each of 

these areas for our review and approval prior to use.

2.3.2.2 Access Roads

Cameron Interstate would use 28 public and private roads that intersect or parallel the 

proposed pipeline route to access the right-of-way during construction. The roads were 

previously approved and used during the construction of the existing Cameron Interstate and LA 

Storage Pipelines. Minor modifications, such as grading ruts and replacement of gravel, may be 

required along the existing roads. No other improvements to these access roads are anticipated. 

Access roads are depicted on the maps in Appendix B. Cameron Interstate would construct a 

new 1,500-foot-long access road to the Holbrook Compressor Station adjacent to the pipeline 

right-of-way. This access road would impact about 1.2 acres (see figure 2.2-2). No other new 

access roads are proposed. 

2.3.2.3 Contractor Yard

Cameron Interstate would use one 10.6-acre site adjacent to the existing Ragley 

Compressor Station in Calcasieu Parish as the pipe storage yard, staging area, and contractor site 

during construction (see Appendix B). This site was used for similar activities during 
2-17 Proposed Action

construction of the existing Cameron Interstate Pipeline. Cameron Interstate would restore the 

entire 10.6-acre area to pre-construction conditions (open land) after completion of construction. 

2.3.2.4 Aboveground Facilities

Construction of the aboveground facilities would affect a total of about 21.4 acres, of 

which 20.3 acres would be permanently impacted during operation. Table 2.3-1 identifies the 

land requirements for the proposed aboveground facilities.

Cameron Interstate would permanently impact about 15.3 of the 17.6 acres required for 

construction of the Holbrook Compressor Station during operation. The new Trunkline 

Interconnection would impact about 0.2 acre of land and would use a portion of the existing LA 

Storage Interconnection site. Modifications at the existing interconnections and metering 

facilities at FGT, TGP, TETCO, and Transco would impact a total of about 3.6 acres within the 

previously certificated site boundaries. 

2.4 CONSTRUCTION SCHEDULE

Cameron LNG anticipates conducting construction and requesting in-service in three 

phases, with construction starting in late 2014 (assuming receipt of all certifications, 

authorizations, and necessary permits). The first liquefaction train and associated facilities are 

proposed to be completed and in service by 2017. Construction of the second liquefaction train 

would begin approximately 6 months after initiation of construction of the Terminal Expansion, 

and construction of the third liquefaction train would start approximately 6 months after that, 

with all three trains anticipated to be in service in 2018. Cameron LNG anticipates that the first 

full year of service would be 2019. 

Cameron Interstate would begin construction of the Pipeline Expansion in late 2014 with 

an anticipated in-service date of 2017, prior to completion of the first liquefaction train. 

Cameron Interstate would begin construction with the Holbrook Compressor Station, followed 

by construction of the pipeline. 

2.5 ENVIRONMENTAL COMPLIANCE

2.5.1 Compliance Monitoring

The FERC may impose conditions on any Certificate or authorization it grants for the 

Project. These conditions include additional requirements and mitigation measures 

recommended in this EIS to minimize the environmental impact that would result from 

construction and operation of the Cameron Liquefaction Project (see sections 4 and 5). We will 

recommend that these additional requirements and mitigation measures (bold type in the text of 

the EIS) be included as specific conditions to any approving Certificate or authorization issued 

for the Project. We will also recommend to the Commission that Cameron LNG and Cameron

Interstate be required to implement the mitigation measures proposed as part of the Project 

unless specifically modified by other Certificate or authorization conditions. Cameron LNG and 

Cameron Interstate would be required to incorporate all environmental conditions and 

requirements of the FERC Certificate, authorization, and associated construction permits into the 

construction documents for the Project. 
Proposed Action 2-18

Cameron would employ two environmental inspectors (EIs) for the Project, one for the 

Terminal Expansion and one for the Pipeline Expansion. The responsibilities of the EIs are 

described in the 2013 FERC Upland Erosion Control, Revegetation, and Maintenance Plan

(Plan) and Wetland and Waterbody Construction and Mitigation Procedures (Procedures).

14 

The FERC Plan and Procedures are a set of construction and mitigation measures developed in 

collaboration with other federal and state agencies and the natural gas pipeline industry to 

minimize the potential environmental impacts of the construction of pipeline projects in general. 

Cameron Interstate’s Environmental Plan (see Appendix C) includes its project-specific Plan 

(Cameron Interstate Plan) and project-specific Procedures (Cameron Interstate Procedures), 

while the Cameron LNG Environmental Plan15 includes the FERC Plan and Procedures which 

are adopted in their entirety. 

The EI’s responsibilities include ensuring the environmental obligations, conditions, and 

other requirements of permits and authorizations for the Project are met. Cameron’s EIs would 

inspect all construction and mitigation activities to ensure environmental compliance. EIs may 

also oversee cultural resource and/or biological monitors that monitor and evaluate construction 

impacts on resources as specified in this EIS.

The FERC staff would also conduct field inspections during construction. Other federal 

and state agencies may also conduct oversight of inspection to the extent determined necessary 

by the individual agency. After construction is completed, the FERC staff would continue to 

conduct oversight inspection and monitoring during operation of the Project to ensure successful 

restoration. Additionally, the FERC staff would conduct bi-annual engineering safety 

inspections of the LNG facility operations.

2.6 CONSTRUCTION PROCEDURES

The Project would be constructed in accordance with the Cameron Interstate 

Environmental Plan and its associated Plan, Procedures, and Spill Reporting Procedures (SRP)

(Appendix C) and the Cameron LNG Environmental Plan, including the FERC’s Plan and 

Procedures. Cameron Interstate requested several deviations from the FERC Procedures. Our 

evaluation and conclusions for the proposed deviations to the FERC Procedures are presented in 

table 2.6-1. Specific deviations that may impact wetlands that were not adequately justified are 

discussed in section 4.4.5.2.

Cameron also developed other Project-specific plans and measures to avoid or minimize 

environmental impacts during construction. These plans are discussed throughout this EIS. 

 14 The FERC Plan can be viewed on the FERC Internet website at 

http://www.ferc.gov/industries/gas/enviro/plan.pdf. The FERC Procedures can be viewed on the FERC Internet 

website at http://www.ferc.gov/industries/gas/enviro/procedures.pdf.

15 Provided on FERC Docket No. CP13-25-000 Accession No: 20121207-5141 with Cameron LNG’s application.
2-19 Proposed Action

TABLE 2.6-1

Cameron Interstate’s Requested Deviations from the FERC Procedures

Reference Description Proposed Revision FERC Staff Conclusion

Procedures

Section 

V.B.2.a.

Locate all extra work areas 

(such as staging areas and 

additional spoil storage 

areas) at least 50 feet away 

from water’s edge, except 

where the adjacent upland 

consists of actively 

cultivated or rotated 

cropland or other disturbed 

land.

Locate several 

workspaces within 50 

feet of the water’s edge.

Justified. Soil conditions require extra 

workspace to maintain slope stability 

of pipeline trench and to contain trench 

spoil within temporary construction 

right-of-way. Several areas are 

adjacent to roads, which require extra 

workspace.

Section 

VI.A.3

Limit the width of the 

construction right-of-way to 

75 feet or less in wetlands. 

A nominal construction 

right-of-way width of 100

feet through most 

wetlands, with several 

crossings using 125 feet.

Partially Justified. Due to sandy soil 

conditions that require a greater trench 

width to maintain slope stability. Areas 

that are not approved are discussed in 

section 4.4.3 of this EIS.

Section 

VI.A.6

Do not locate aboveground 

facilities in any wetland.

Location of the Holbrook 

Compressor Station and 

modified FGT 

Interconnection would be 

within a silviculture 

wetland.

Justified. The location for the 

Holbrook Compressor Station avoids 

high quality forested wetlands and 

alternatives would also impact 

wetlands. The FGT Interconnection is 

an existing facility, within a previously 

disturbed area.

Section 

VI.B.1.a

Locate all extra work areas 

(such as staging areas and 

additional spoil storage 

areas) at least 50 feet away 

from wetland boundaries, 

except where the adjacent 

upland consists of actively 

cultivated or rotated 

cropland or other disturbed 

land.

Locate several 

workspaces within 50 

feet or within wetland 

boundaries.

Justified. Soil conditions require extra 

workspace to maintain slope stability 

of the pipeline trench and contain 

trench spoil within the temporary 

construction right-of-way. Several 

areas are adjacent to roads, which 

require extra-workspace.

2.6.1 Terminal Expansion 

2.6.1.1 Site Preparation

Marking Site Boundaries 

The first step of construction would involve marking by flags and/or stakes the 

boundaries of the Terminal Expansion and foreign utility lines. Cameron LNG would also mark 

wetland boundaries and other environmentally sensitive areas with appropriate fencing or 

flagging at that time. 
Proposed Action 2-20

Clearing, Grading, and Fencing

For safety and to limit public access, Cameron LNG would cut and brace fences along the 

boundaries of the Terminal Expansion site and install temporary gates. Cameron LNG would 

also clear all construction work areas of shrubs and trees and other obstructions. In accordance 

with the FERC Plan, Cameron LNG would install temporary erosion controls immediately after 

initial disturbance of the soil to minimize erosion and maintain these controls throughout 

construction. The site would then be graded where necessary to create a reasonably level 

working surface to allow safe passage of construction equipment and materials. Cameron LNG 

would maintain a final grade elevation for the process areas of 13 feet above mean sea level 

(MSL), plus or minus 1 foot, depending on final engineering design. Additionally, Cameron 

LNG would fill the large pond on the site and retain the small pond for stormwater retention 

during construction. Cameron LNG would use on-site material as backfill; however, if 

additional backfill is required, Cameron LNG would import local, clean fill from commercial 

sources.

Trenching 

Cameron LNG would install any necessary underground pipe and utilities (for example, 

electrical conduits) approximately 3 feet below the finish grade. 

Work Dock 

Cameron LNG would construct the work dock prior to installation of major facilities as 

barges would use the work dock to deliver most major equipment to the site. Construction of the 

dock would commence with onshore cut-and-fill earthwork to provide a working surface at 

approximately 3 feet above MSL. Cameron LNG would then install 17 steel pilings and 425 

concrete piles on land for the dock platform and for installation of the sheet piling. About 976 

feet of sheet piling would be installed along Cameron LNG’s desired shoreline prior to

hydraulically dredging the shallow water and excavating the area between the waterline and the 

sheet piling for the berthing area. The dredged area would include about 9.4 acres of open water 

with depths up to 16 feet below MSL. Cameron LNG would dispose of dredged material in 

accordance with the amended CUP that LDNR issued to Cameron LNG on January 21, 2014 and 

the DA Permit issued by the COE on February 12, 2014. Cameron LNG would then install a

reinforced concrete platform, anchor rods, a mooring structure, and fenders. 

Facility Foundations and Piperack Installation 

Cameron LNG would use either pile supports or spread footings as foundations for 

facilities at the terminal, which it would install at an elevation of 15 feet above MSL, matching 

the design of the existing LNG terminal. Cameron LNG would drive piles about 110 feet below 

the ground surface (bgs) for the outer piles and 95 feet bgs for the inner piles for the LNG 

storage tank foundation. Cameron LNG would typically complete the foundations for equipment 

and machinery prior to its arrival on site to allow immediate setting of the equipment and 

machinery, thus reducing the need for temporary storage and staging areas. Piperack erection 

would commence as the foundations are installed. 
2-21 Proposed Action

2.6.1.2 Piping and Equipment Installation

Cameron LNG would fabricate pipe less than 2 inches in diameter on site. All pipe 

would be fabricated according to American Society of Mechanical Engineers (ASME) standards 

by ASME Section IX qualified welders. Cameron LNG’s design would minimize the use of 

flanges or other joints or valves on cryogenic pipes that may become the source of a leak.

Once process equipment is set in place on the foundations, roughly aligned, and secured 

to the foundations, pipe installation would begin. Cameron LNG would coat all piping and 

equipment with a material that resists corrosion and is compatible with the existing LNG 

terminal’s color identification system. 

When all process equipment is installed and electrical, mechanical, and other 

instrumentation work completed, the key pre-commissioning activities would commence, 

including the following:

• conformity checks on each part or piece of equipment to ensure proper 

installation; 

• flushing and cleaning of equipment; and

• nitrogen leak testing of all hydrocarbon piping and associated equipment. 

After all pre-commissioning activities are complete, Cameron LNG would clean and 

hydrostatically or pneumatically test piping in compliance with the applicable codes that govern 

pipe design, and purge the piping with nitrogen. In general, Cameron LNG would pneumatically 

test cryogenic piping and hydrostatically test non-cryogenic piping using clean water (see 

sections 4.3.1.2 and 4.3.2.2 for further information on hydrostatic test water).

2.6.1.3 LNG Storage Tank Installation

Cameron LNG would install the LNG storage tank on an elevated pile cap foundation. 

After the foundation is in place, construction of the tank would generally follow the sequence of 

activities listed below: 

• install outer tank and inner annular footer plates;

• construct inner and outer tank shell rings;

• install resilient blank on the outside of the inner tank shell; 

• install instrumentation inside the tank;

• construct the tank roof;

• install roof platforms, walkways, and external tank piping;

• test tank hydrostatically;

• install process piping from tank top to grade; 

• install LNG pumps; 
Proposed Action 2-22

• purge with nitrogen to a positive gauge pressure; and 

• cool down the tank.

Cameron LNG would hydrostatically test the LNG storage inner tanks in accordance with 

American Petroleum Institute (API) 620. Hydrostatic test water source and discharge are more 

fully described in sections 4.3.1.2 and 4.3.2.2.

2.6.2 Pipeline Expansion 

Cameron Interstate would construct the pipeline and associated facilities as described in 

this section and in accordance with its Environmental Plan and 49 CFR 192. Figure 2.6-1 is a

depiction of the typical pipeline construction sequence.

2.6.2.1 Marking the Right-of-Way

Prior to clearing the proposed right-of-way, a civil survey crew would stake the centerline 

of the pipeline route. Cameron Interstate would flag points of inflection,

16 environmentally 

sensitive areas (for example, wetlands), and other existing pipelines and utilities.

2.6.2.2 Equipment Bridges 

Cameron Interstate would install temporary construction bridges across intermittent and 

perennial waterbodies, including minor waterbodies (equal to or less than 10 feet wide) that have 

perceptible flow at the time of construction, with the exception of waterbodies that it would cross 

using the HDD method. Equipment bridges may consist of prefabricated construction mats, rail 

cars, flexi-float, or other structures. Clearing equipment and any equipment necessary for 

installation of equipment bridges may cross waterbodies prior to bridge installation; however, the 

crossing is limited to one per piece of clearing equipment per waterbody. Typically, equipment 

bridges are installed during clearing operations.

2.6.2.3 Clearing and Grading

Cameron Interstate would clear and grade the construction right-of-way and extra work 

spaces (including brush, trees, and roots), where necessary, to provide a relatively level surface 

for trench-excavating equipment and the movement of other construction equipment. Nonwoody vegetation, such as crops and grasses, in areas where grading is not required, would be 

mowed to avoid damage to root systems. Cameron Interstate would preserve natural drainage 

patterns to the extent possible. 

2.6.2.4 Trenching

Cameron Interstate would install the majority of the pipeline in uplands using 

conventional open-cut methods, which typically include the steps described below. Cameron 

Interstate’s proposed pipeline installation across waterbodies and wetlands, as well as other 

specialized construction procedures, are described in section 2.6.3.

 16 Change in the direction of the pipeline centerline, typically referred to as a PI.
2-23 Proposed Action

Figure 2.6-1 Typical Pipeline Construction Sequence
Proposed Action 2-24

Wheel ditching machines and/or backhoes would be used to excavate a trench to a depth 

that would allow coverage of the pipeline to meet or exceed DOT standards at 49 CFR 192.327. 

Cameron Interstate would install the pipeline to allow 30 inches of soil cover where 10 or fewer 

buildings intended for human occupancy occur within 220 feet of the pipeline along 1 continuous 

mile of the pipeline (DOT Class 1 Areas); in all other areas the cover depth would be 36 inches. 

Cameron Interstate would install the pipeline at least 36 inches bgs to the top of the pipe at 

drainage ditches and public roads, and 48 inches bgs in agricultural areas. In cultivated 

agricultural areas and residential lands, Cameron Interstate would strip and segregate up to 12

inches of topsoil, unless topsoil replacement is deemed more efficient. Cameron Interstate 

would typically store excavated materials (including subsoil and segregated topsoil) on the nonworking side of the trench, away from construction traffic and pipe assembly areas (see figure 

2.3-1).

Cameron Interstate would employ the best management practices (BMPs) described in its 

Plan and Procedures to minimize erosion during trenching operations and construction activities. 

Additionally, Cameron Interstate would install trench breakers to minimize free flow of water 

from the trench into waterbodies and from draining wetlands. To contain disturbed soils in 

upland areas and minimize the potential for sediment loss to wetlands and waterbodies, Cameron 

Interstate would install temporary erosion controls immediately after initial disturbance of soils 

and maintain them throughout construction. 

2.6.2.5 Pipe Stringing, Bending, and Welding

Cameron Interstate would deliver pipe segments to the contractor yard or place them 

along the construction right-of-way. Cameron Interstate would string the pipe segments, which 

involves positioning pipe sections along the prepared right-of-way parallel to the centerline of 

the trench, so they are easily accessible to construction personnel. Pipe sections are strung on the 

working side of the trench for bending, welding, coating, and lowering-in operations and the 

associated inspection activities.

Field bends of the pipe would follow the natural grade and direction changes of the rightof-way. Following stringing and bending, the ends of the pipe sections would be aligned and 

welded together. Cameron Interstate would visually inspect and test the welds to ensure 

structural integrity using non-destructive examination methods such as radiography (x-ray). 

Cameron Interstate would repair or replace any welds that do not meet DOT’s safety standards 

found in 49 CFR 192.

A factory-applied, fusion-bonded epoxy external coating would cover and protect the 

delivered pipe sections from corrosion. After welding, Cameron Interstate would coat the ends 

of the pipe at all joints with a material compatible with the factory-applied coating in preparation 

for installation. Cameron Interstate would then inspect the coating and repair any damaged

coating prior to lowering the pipe into the trench.

2.6.2.6 Lowering-In and Backfilling

Prior to lowering the pipeline, Cameron Interstate would remove debris and foreign 

material and dewater the trench as necessary. Cameron Interstate would pump accumulated 

groundwater or rainwater from the trench to stable upland areas in accordance with applicable 
2-25 Proposed Action

federal, state, and local permitting requirements, as well as its Procedures. If necessary, 

dewatering effluent would pass through sediment filters and energy dissipating devices to 

minimize sediment deposition and scour. 

Cameron Interstate would lower the pipeline into the trench by sideboom tractors 

working in unison to avoid buckling of the pipe. Trench breakers would be installed at regular 

intervals, where appropriate, to prevent subsurface erosion and flow of water between the trench 

and crossed waterbodies, wetlands, or near-surface groundwater.

After the pipeline is lowered into the trench and adequately protected, Cameron Interstate 

would place previously excavated materials into the trench. If the excavated material has 

significant amounts of rock that could damage the pipe coating, Cameron Interstate would install

a rock shield, obtain commercial fill for padding, or separate rocks from suitable material from 

the excavated trench spoil. Any excess rock deemed unsuitable for backfill would be disposed of 

in accordance with applicable regulations and landowner requests. In areas where topsoil has 

been segregated, Cameron Interstate would place the excavated subsoil into the trench first and 

top it with the topsoil. Backfilling would occur to existing grade or higher to accommodate 

future soil settlement.

2.6.2.7 Hydrostatic Testing

Once installation and backfilling are completed, Cameron Interstate would 

hydrostatically test the pipeline in accordance with DOT safety standards (49 CFR 192) to verify 

its integrity and ensure its ability to withstand the maximum allowable operating pressure 

(MAOP). Hydrostatic testing consists of installing a hydrostatic test cap and manifold, filling the 

pipeline with water, pressurizing the pipeline to 125 percent of its MAOP, and maintaining that 

test pressure for a minimum of 8 hours. Following welding and installation of the pipeline in the 

trench, Cameron Interstate would test the entire pipeline as one segment. If either leaks or loss 

of pressure are detected during the test, Cameron Interstate would excavate, remove, replace, and 

re-test the flawed segment. Section 4.3.2.2 provides additional information on hydrostatic 

testing.

2.6.2.8 Cleanup and Restoration

After the trench is backfilled, Cameron Interstate would remove all remaining debris, 

surplus materials, and temporary structures and dispose of them in accordance with applicable 

federal, state, and local regulations. In accordance with its Plan, Cameron Interstate would finish 

grade and restore all disturbed areas as closely as practicable to pre-construction contours within 

10 days after backfill, depending on weather conditions. During this phase, Cameron Interstate 

would also install permanent erosion control measures in accordance with its Plan and 

Procedures. 

Cameron Interstate would seed the right-of-way after pipeline installation and recontouring in accordance with its Plan and Procedures. The FERC would inspect the right-ofway after the first and second growing seasons to determine the success of revegetation. 

Cameron Interstate would implement additional restoration measures if deemed necessary by the 

FERC and/or other federal, state, or local agencies. 
Proposed Action 2-26

Finally, Cameron Interstate would install pipeline markers and/or warning signs along the 

pipeline centerline at line-of-sight intervals to identify the pipeline location, identify Cameron 

Interstate as the pipeline operator, and provide telephone numbers for emergencies and inquiries. 

In accordance with 49 CFR 192, Cameron Interstate would install cathodic protection for the 

new pipeline through a rectifier with a deep well anode system within the proposed right-of-way 

at MP 13.4.

2.6.3 Special Construction Procedures

2.6.3.1 Road, Railroad, and Foreign Pipeline Crossings

The proposed pipeline route crosses paved and unpaved roads, highways, railroads, and 

foreign pipelines. Cameron Interstate would construct across these features in accordance with 

its Environmental Plan (Appendix C) and the requirements of all applicable crossing permits and 

approvals. Cameron Interstate would use traffic warning signs, detour signs, and other traffic 

control devices as required by federal, state, and local departments of transportation.

In accordance with state and parish road and railroad crossing permit requirements, 

Cameron Interstate would bore all hard surface roads and railroads. Boring would result in 

minimal or no disruption to traffic at road or railroad crossings and would typically require 1 to 2 

days to complete for most crossings. Initially, Cameron Interstate would excavate a pit on each 

side of the feature, a hole would be bored under the road or railroad at least equal to the diameter 

of the pipe, and a prefabricated pipe section would be pulled through the borehole. For long 

crossings, Cameron Interstate would weld sections to create a pipe string and pull the string 

through the borehole.

Cameron Interstate would cross dirt and gravel surface roads by open-cut methods. 

Cameron Interstate would schedule construction activities at road crossings to avoid or minimize 

interruptions in the flow of traffic. 

Cameron Interstate would maintain a minimum clearance of 12 inches between the 

proposed pipeline and the crossing of foreign pipelines in accordance with 49 CFR 192 and in 

compliance with pipeline crossing agreements negotiated with the foreign pipeline operators. 

2.6.3.2 Wetland Crossings

Cameron Interstate would construct the pipeline and associated facilities across wetlands 

in accordance with applicable federal and state permits and its Procedures. Overall, the wetland 

crossing methods and mitigation measures identified in Cameron Interstate’s Procedures are 

designed to minimize the extent and duration of construction-related disturbance within 

wetlands. Site-specific crossing procedures used to install the pipeline across wetlands would 

vary based on the level of soil stability and saturation encountered during construction. 

Cameron Interstate stated that wetland soils in the area of the Pipeline Expansion are 

generally not sufficiently stable to maintain the stability of the trench or material excavated from 

the trench within a 75-foot-wide construction right-of-way and maintain a passing lane during 

the installation of a 42-inch-diameter pipeline. As a result, Cameron Interstate determined that it 

is not possible to limit the width of the construction right-of-way in wetlands to 75 feet and
2-27 Proposed Action

requested a 100- and 125-foot-wide construction right-of-way through wetlands, except where 

impacts would be avoided by using the HDD method. Table 2.6-1 provides information on 

Cameron Interstate’s requested deviations to the FERC Procedures. 

In addition, in response to our Recommendation Number 18 in the draft EIS, Cameron 

Interstate agreed to reduce the width of the construction right-of-way in four areas of concern. 

As a result, the width of the construction right-of-way would be reduced as follows: (1) from 

125 feet to 100 feet at MPs 1.55 and 2.25, and (2) from 100 feet to 75 feet at MPs 15.98, 18.46, 

18.79, 20.11, and 20.36. As a result of the righto-of-way width reduction, the draft EIS 

recommendation is no longer applicable and was removed from section 5.3.

Cameron Interstate would limit grading to the area directly over the trench line unless it 

determines that safety-related construction constraints require grading on the working side of the 

construction right-of-way. Construction procedures used to cross unsaturated “dry” wetlands 

would be similar to those used in dry, upland areas (figure 2.6-2). In accordance with its

Procedures, Cameron Interstate would minimize the length of time that topsoil is segregated and 

the trench is left open in wetlands. Additionally, upland soils would be stored at least 10 feet 

from wetland boundaries. Temporary erosion control devices would be installed as necessary 

immediately after initial disturbance of wetlands or adjacent upland areas to prevent sediment 

flow into wetlands; the devices would be maintained until revegetation is complete. Cameron 

Interstate would install trench breakers as necessary to maintain wetland hydrology.

In highly saturated areas, Cameron Interstate could use the push/pull technique to install 

the pipeline. This method involves either pushing the prefabricated pipe across the wetland or 

pulling the pipe across the wetland with a winch. Floats may be attached to the pipe to achieve 

positive buoyancy. Cameron Interstate would excavate the trench with a backhoe or similar 

equipment. If the pipe has floats attached to it, they would be cut or removed after the pipe is 

moved into place, and the pipe would settle to the bottom of the trench. Cameron Interstate 

would use concrete coated pipe or weights to ensure that the pipe does not float in saturated 

conditions. Excavated material would be used to backfill the trench.

Cameron Interstate would limit construction equipment operating in wetland areas to that 

necessary to clear the construction right-of-way, dig the trench, fabricate and install the pipeline, 

backfill the trench, and restore the construction right-of-way. If standing water or saturated soil 

conditions are present, mats would be installed within workspaces to prevent rutting and mixing 

of the topsoil and subsoil (see figure 2.6-3).
Proposed Action 2-28

Figure 2.6-2 Typical Unsaturated Wetland Crossing
2-29 Proposed Action

Figure 2.6-3 Typical Saturated Wetland Crossing Method
Proposed Action 2-30

2.6.3.3 Waterbody Crossings

The FERC defines a waterbody as any natural or artificial stream, river, or drainage with 

perceptible flow at the time of crossing, and other permanent waterbodies such as ponds and 

lakes. Cameron Interstate would maintain water flow at all waterbody crossings. Typically, 

Cameron Interstate would cross streams perpendicular to the flow. Grading at approaches to 

waterbodies might be required to create a safe work surface and to allow the necessary area for 

pipe bending. If grading is required, Cameron Interstate would direct it away from the 

waterbody to reduce the possibility of disturbed soils being transported into the waterbody by 

erosion or sedimentation. Cameron Interstate would implement the measures in its Procedures to 

minimize the extent and duration of construction disturbance on waterbodies (Appendix F). In 

order to limit the time required for construction of a stream crossing, the right-of-way would be 

prepared on either side of the stream prior to the construction of the actual crossing. 

Additionally, Cameron Interstate would weld and hydrostatically test an appropriate length of 

pipeline to cross the waterbody prior to initiating the crossing. When crossing through wooded 

stream banks, Cameron Interstate would preserve as many trees as possible.

Cameron Interstate would use the open-cut, dry crossing, or HDD methods to cross the 

waterbodies along the pipeline route. Except for nine waterbodies that would be crossed by the 

HDD method, Cameron Interstate would identify the specific type of open-cut or dry crossing 

based on site-specific conditions at the time of construction. If a stream channel is dry or is 

lacking perceptible flow at the time of crossing, conventional upland construction methods may 

be used. Any modifications during construction to the methods described in this EIS and 

Cameron Interstate’s filings would require review and approval by the FERC and other 

applicable agencies prior to their implementation. Illustrations of typical waterbody crossings 

are presented in Appendix F.

Open-cut Crossing Method

The open-cut crossing technique is a “wet” crossing method that is completed while the 

waterbody continues to flow across the work area (see Appendix F). The open-cut crossing 

method is typically used to cross non-sensitive minor and intermediate waterbodies (width 

greater than 10 feet but less than or equal to 100 feet between the water’s edges). In general, an 

open-cut crossing is accomplished using methods similar to conventional upland open-cut 

trenching. The open-cut construction method involves excavation of the pipeline trench across 

the waterbody, installation of a prefabricated segment of pipeline, and backfilling of the trench 

with native material without affecting or diverting flow at the time of crossing. Cameron 

Interstate would use a backhoe, clam dredge, dragline, or other similar equipment to excavate the 

trench within the water. Material excavated from the trench would be stored at least 10 feet from 

the water’s edge in accordance with Cameron Interstate’s Procedures. Cameron Interstate would 

minimize the introduction of sediment into waterbodies from disturbed upland areas by installing 

and maintaining sediment barriers (silt fences and/or straw bales) at stream crossings. Cameron 

Interstate would complete construction activities at these stream crossings within 24 hours of 

initiation of the crossing for minor waterbodies and within 48 hours for intermediate 

waterbodies, unless bedrock is encountered. 
2-31 Proposed Action

Dry Crossing Methods

The dry crossing method (flume or dam-and-pump) is used at waterbodies with 

perceptible flow that require flow to be diverted for a dry-ditch pipe installation. These methods

are appropriate only for waterbody crossings where pumps or flumes can adequately transfer 

streamflow volumes around the work area. 

A flume crossing consists of temporarily directing the flow of water across the 

construction work area within one or more flume pipes placed in the stream bed. After placing 

the flume pipes in the stream, temporary dams are constructed around the flume pipes upstream 

and downstream of the proposed trench to divert the stream flow through the flumes (see 

Appendix F). Once flow is isolated from the work area, backhoes on both banks of the stream 

would excavate a trench under the flume pipe(s) in the isolated streambed. Cameron Interstate 

would store the material excavated from the stream trench in an area with straw bale/silt fence 

containment at least 10 feet from the edge of the waterbody in accordance with its Procedures. 

Once the trench is excavated, a prefabricated segment of pipe would be installed beneath the 

flume pipes. Cameron Interstate would remove the flume pipes after completion of pipeline 

installation, backfill of the trench, and restoration of stream banks. This crossing method 

generally minimizes downstream turbidity during trenching by allowing excavation under 

relatively dry conditions. 

Similar to the flume crossing method, the dam-and-pump method involves installing 

temporary dams up and downstream of the waterbody crossing (see Appendix F). Dams are 

typically constructed using sandbags and plastic sheeting. Appropriately sized pumps transport 

the streamflow around the construction work area. Energy dissipation devices are placed on the 

downstream side at the discharge point to prevent streambed scour. Cameron Interstate would 

use additional pumps to dewater the area between the temporary dams during construction. 

Once the area between the dams is stable, backhoes on both banks would excavate a trench 

across the stream. Spoil excavated from the trench would be stored in a straw bale/silt fence 

containment area at least 10 feet from the edge of the stream banks, in accordance with Cameron 

Interstate’s Procedures. After completion of the trenching activities across the streambed, a 

prefabricated segment of pipe would be installed in the trench. Following completion of pipeline 

installation, backfill of the trench, and restoration of streambanks, Cameron Interstate would 

remove the temporary dams and restore flow through the construction work area.

Horizontal Directional Drill 

The HDD method is a trenchless crossing method used to avoid direct impacts on 

sensitive resources (such as waterbodies and wetlands) by conducting a deep bore beneath them. 

This method requires specialized equipment and personnel and has four general steps: (1) 

placement of guide wires over the anticipated path of the drill; (2) drilling a pilot hole on an arcshaped path that typically extends between 30 and 50 feet beneath the waterbody; (3) enlarging 

the pilot hole with a series of reamers to accommodate the pipeline; and (4) pulling a 

prefabricated section of pipe through the hole.

The HDD method involves an entry and exit pad on each side of the crossing. The initial 

step of placing HDD guide wires over the path of the drill may require minor hand clearing of 

woody vegetation and/or branches. A pilot hole is drilled under the waterbody and banks. The 
Proposed Action 2-32

head of the pilot drill string contains a pivoting head that can be controlled by an operator as the 

drill progresses. Typically, the pilot hole would be directed downward at an angle until the 

proper depth is achieved, then turned and directed horizontally for the required distance, and 

finally angled upward back to the surface. Throughout the process of drilling and enlarging the 

hole, mud slurry, consisting of bentonite and water, would be pressurized and pumped through 

the drill stem to lubricate the drill bit, maintain the hole, and remove drill cuttings. Bentonite is 

the commercial name for a nontoxic mixture of non-toxic clays and rock particles consisting of 

about 85 percent montmorillonite clay, 10 percent quartz and feldspars, and 5 percent accessory 

materials, such as calcite and gypsum. This slurry, referred to as drilling mud or drilling fluid, 

has the potential to be inadvertently released to the surface if fractures or fissures are 

encountered in the substrate during drilling.

The potential for an inadvertent release is generally greatest during drilling of the pilot 

hole when the pressurized drilling mud is seeking the path of least resistance and near the drill 

entry or exit pits where the drills are at their shallowest depths. The path of least resistance is 

typically back along the path of the drilled pilot hole. However, if the drill path becomes 

temporarily blocked or encounters areas such as large fractures or fissures that lead to the 

ground, then an inadvertent release could occur. Cameron Interstate developed a site-specific 

HDD plan for each drill site and an HDD Contingency Plan to monitor for, contain, and clean up 

any inadvertent releases of drilling fluid during HDD operations. These plans are included in its 

Environmental Plan (Appendix C). Additional information on waterbody construction, including 

the use of the HDD method, is presented in section 4.3.2.2.

2.6.3.4 Residential Areas

One residence is within 50 feet of the proposed construction right-of-way. Appendix D

contains Cameron Interstate’s site-specific plan for construction near this residence, and includes 

the following commitments:

• remove only those trees necessary for safe construction;

• restore all lawn areas and landscaping after construction; 

• reduce the width of the construction right-of-way to maintain at least 15 feet of 

undisturbed land between the right-of-way and the residence; 

• fence the edge of the construction work area for 100 feet on either side of the 

residence; and 

• maintain safety fencing throughout the open-trench phase of construction. 

In addition, Cameron Interstate would maintain clear access for emergency vehicles and 

minimize or avoid disruption of utility services. 

Construction would occur within 135 feet of three additional residences (see section 

4.8.1.3). Cameron Interstate has developed site-specific construction plans for each of these 

three residential areas as well (Appendix D). We are requesting the affected residents to 

comment on these plans.
2-33 Proposed Action

2.6.3.5 Agricultural Areas

Agricultural areas along the proposed pipeline route include pasture areas used for 

livestock grazing, hayfields, fallow fields, and rotated croplands such as cotton and corn. 

Cameron Interstate would implement its Plan in these areas to minimize impacts on current 

agricultural uses. Cameron Interstate would remove the topsoil to its actual depth, up to a 

maximum of 12 inches, and stockpile it separately from the subsoil excavated from the pipeline 

trench. Typically, topsoil would be stripped from directly over the pipeline ditch and the 

adjacent subsoil spoil storage area; however, topsoil segregation may be completed across the 

full construction work area if requested by the landowner. During construction, Cameron 

Interstate would maintain the natural flow patterns of all fields by providing breaks in the 

stockpiles of topsoil and subsoil.

After pipeline installation, Cameron Interstate would also test the compaction of topsoil 

and subsoil in all agricultural areas at regular intervals, using penetrometers or other appropriate 

devices, in accordance with the Cameron Interstate Plan (Appendix C). If any severely 

compacted areas are identified, Cameron Interstate would plow the area with a paraplow or other 

deep tillage device. In addition, if any drain tiles or systems are damaged during construction, 

Cameron Interstate would return the system to its original condition or better. Additional 

information on procedures used in agricultural areas is presented in sections 4.2.2.2 and 4.8.1.3.

2.6.4 Aboveground Facilities Construction Procedures

Cameron Interstate would construct the aboveground facilities concurrently with pipeline 

installation using special fabrication crews that would generally work separately from the 

pipeline construction crews. 

Construction of the Holbrook Compressor Station would begin with clearing, grading, 

and compacting the site where necessary. Cameron Interstate would then pour the concrete 

foundations for buildings and skid-mounted equipment supports. Cameron Interstate would 

assemble the prefabricated segments of pipe, valves, fittings, and flanges at the compressor 

station site. The compressor units and other large equipment would be mounted on their 

respective foundations, and the compressor enclosures erected around them. Cameron Interstate 

would install noise abatement equipment and emission control technology as needed to meet 

applicable federal, state, and local standards. Section 4.11.2 provides additional information on 

noise abatement and emission control technology. Electrical, septic system, and communications 

utilities would be installed as well. 

Cameron Interstate would hydrostatically test all facility piping, both above and below 

ground, before it is placed in service. Cameron Interstate would also ensure that controls and 

safety devices, such as the emergency shutdown system, relief valves, gas and fire detection 

facilities, and other protection and safety devices, are tested. Upon completion of construction, 

temporarily disturbed areas would be graded and seeded. All roads and parking areas within the 

boundaries of the compressor station would be graveled. Finally, Cameron Interstate would 

fence all aboveground facilities for security.

The proposed Trunkline Interconnection and modified interconnection facilities would be 

constructed in a similar manner to that described above for the compressor station; however, no 
Proposed Action 2-34

clearing and grading activities would be required within the boundaries of the previously 

disturbed or existing pipeline easements. The proposed Trunkline Interconnection would be 

within the permanent right-of-way of the Pipeline Expansion. 

2.7 OPERATION, MAINTENANCE, AND SAFETY PROCEDURES

2.7.1 Terminal Expansion 

Cameron LNG would operate its Terminal Expansion facilities consistent with federal 

requirements for LNG facilities (see table 1.5-1), which include operation, emergency, and 

security procedures. Cameron LNG would update all current manuals as necessary to include 

the expanded terminal operations and submit amendments to the agencies prior to 

commissioning the Terminal Expansion facilities.

Cameron LNG would modify its maintenance regime, which includes corrective and 

preventative maintenance plans, to include the expanded terminal facilities. The plans include 

written procedures consistent with corporate policy and federal standards, including DOT 

regulations at 18 CFR 127.401 and 49 CFR 193 (G). Cameron LNG would train its operators to 

respond to potential hazards associated with the liquefaction process and the proper operations 

and maintenance of all equipment. 

Cameron LNG would design, construct, operate, and maintain safety controls in 

accordance with DOT federal safety standards for LNG facilities at 49 CFR 193. The Terminal 

Expansion facilities would also meet NFPA 59A LNG Standards.

2.7.1.1 Spill Containment System

Cameron LNG proposes to construct two new concrete impoundment sumps, the 

Refrigerant Storage Sump and the Liquefaction Area Sump, to contain possible LNG and other 

hydrocarbon liquid spills from the refrigerant storage area and the liquefaction process area. 

Spill containment system operation, maintenance, and safety information is presented in section 

4.12. 

Hazard and Fire Detection System

The existing LNG terminal system provides alarm signaling and notification when a 

hazardous condition is present. Cameron LNG would expand the fire and gas detection system 

for the existing terminal to protect the expanded terminal and hardwire it to the main alarm 

control system. The following are design and operating features of the hazard detection system 

that would be installed throughout the expanded terminal:

• low temperature sensors at the Liquefaction Area Sump to shut down and/or 

prevent the storm water pumps from starting in the event of a hazardous fluid 

spill;

• ultraviolet/infrared fire and flame detectors to indicate ignition of flammable

vapors; 
2-35 Proposed Action

• high temperature detectors to detect a fire on the vent pipes of the LNG storage 

tank relief valves; 

• fiber optic leak detection;

• combustible gas detection; and

• smoke detection.

Firewater and High Expansion Foam System

The existing Cameron LNG Terminal has firewater supply and distribution systems for

extinguishing fires, cooling structures and equipment exposed to thermal radiation, and 

dispersing flammable vapors. Cameron LNG would install additional firewater supply and 

distribution systems for the Terminal Expansion facilities. A high expansion foam system 

similar to the system at the existing LNG terminal would also be installed for the Terminal 

Expansion facilities. 

Emergency Shutdown System

Cameron LNG would install an emergency shutdown system to allow the expanded 

terminal facilities to be shut down, if necessary, depending on the type of incident. The 

emergency shutdown system would consist of separate shutdown sequences that would result in 

total plant shutdown, shutdown of processes, and/or shutdown of individual pieces of equipment, 

depending on the type of incident. Audible and visual alarms would be throughout the facility to 

alert personnel in affected locations (inside and outside). 

2.7.2 Pipeline Expansion 

Cameron Interstate would operate and maintain all of its pipeline facilities in accordance 

with the DOT regulations in 49 CFR 192, other applicable federal and state regulations, and in 

accordance with industry standard procedures designed to ensure the integrity of the pipeline and 

minimize the potential for pipe failure. Cameron Interstate would inspect the pipeline for 

leakage as part of scheduled operations and maintenance in accordance with 49 CFR 192.

Cameron Interstate would install pipeline identification markers at line-of-sight intervals 

and other critical points (for example, road and railroad crossings). The markers would identify 

Cameron Interstate as the operator and provide telephone numbers for emergencies and inquiries. 

Cameron Interstate is also a member of the “One Call” and related pre-excavation notification

organizations in Louisiana.

2.7.2.1 Corrosion Protection and Detection System

During construction of the pipeline facilities, Cameron Interstate would install a cathodic 

protection system to prevent or minimize corrosion of the buried pipeline and aboveground 

facilities. The cathodic protection system impresses a low-voltage current on the pipeline to 

offset natural soil and groundwater corrosion potential. The condition of the pipe coating and the 

effectiveness of the cathodic protection system would be monitored during regularly scheduled 

cathodic protection surveys in accordance with federal standards and regulations. Cathodic 

protection surveys usually require walking the pipeline right-of-way with monitoring 
Proposed Action 2-36

instruments. If defects are detected during the monitoring, Cameron Interstate would repair the 

pipe, pipe coating, or the cathodic protection system.

2.7.2.2 Pipeline Emergency Response Procedures

The DOT regulations at 49 CFR 192 (Transportation of Natural and Other Gas by 

Pipeline: Minimum Federal Safety Standards) are intended to ensure adequate protection for the 

public and prevent natural gas pipeline 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 prescribes the minimum standards for operating and 

maintaining pipeline facilities, including the requirement to establish a written plan governing 

these activities. 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 the following:

• 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;

• making personnel, equipment, tools, and materials available at the scene of an 

emergency;

• protecting people first and then property, and ensuring safety from actual or 

potential hazards; and 

• emergency shutdown of the system and safe restoration of service.

Part 192 also requires that each operator establish and maintain a liaison with appropriate 

fire, police, regulatory, 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. Cameron Interstate 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.

2.8 FUTURE PLANS AND ABANDONMENT

Cameron LNG and Cameron Interstate have not identified any specific plans for future 

expansion. However, a June 7, 2013 article (Downstreamtoday 2013), noted that the president of 

Cameron LNG’s parent company had expressed interest in adding a fourth liquefaction train, 

which would require an additional LNG storage tank, at the Terminal Expansion site. To the 

extent that expansion of the facilities would be warranted in response to additional demand for 

liquefaction services, any new facilities would be compatible with the Project facilities and 

Cameron LNG and Cameron Interstate must obtain the appropriate authorization from the FERC

(including environmental analyses) and other federal, state, and local agencies at that time.
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Neither Cameron LNG nor Cameron Interstate have any foreseeable plans to abandon the 

existing LNG terminal and associated pipeline facilities. If the Project facilities are abandoned 

in the future, Cameron LNG and Cameron Interstate would need to comply with the appropriate 

federal, state, and local regulations in effect at that time (including the FERC’s abandonment 

regulations, environmental requirements, and non-environmental requirements).